Perhaps 'dual track' would be a better phrasing here than 'two step,' but sometimes you just have to have the headline that makes you smile, look and read. There has been behind the scenes whispers and words in the weeks since the late February MHI Legislative Session. Those whispers have been about an effort to engage a lobbying firm in DC to communicate directly to the CFPB on behalf of manufactured housing regarding parts of Dodd-Frank and the SAFE Act. More details were confirmed on Tuesday (5.22.2012, when I'm drafting this), and received a fuller clarity as well. My thanks to those expert sources.
Having been asked to 'please hold up' on running the story until we had the 'official' word from MHI on Friday, click here to read the article.
Let me emphasize that the plan envisaged is ideally a call for 'parallel paths' or a 'dual track.' This is NOT either lobby the CFPB or lobby Congress. It MUST be BOTH. We can't have all our eggs in a single basket.
Too Much At Stake
So while the professional lobbyists are doing what is important to protect the equity and value of manufactured home owners, and to protect the Industry in our ability to produce, finance and sell manufactured homes, the rest of us at the 'grass roots level' MUST be engaged in doing a full court press of EVERY Congressman and U.S. Senator (find yours at this link) on HR 3849.
- Here is what is at stake, as it stands today, according to my understanding of the experts that tell me. MH Loans over $50,000 that are 9% or more, will likely vaporize – or will require some form of seller participation – if we don't amend Dodd-Frank.
- Loans under $50,000 that are 11% or more, ditto.
Don't think for a second that if you never use that type of financing that this won't impact you! And it most certainly will impact millions of pre-and-post HUD Code MH home owners, which also impacts you. Our 8 month plus trend of increasing sales is good, but it could vaporize overnight when CFPB implements regulations that will dramatically harm our industry and millions who live in manufactured homes.
One pro I spoke with put some interesting color and context to this. To paraphrase, imagine you are living in Washington, DC. Very modest homes start on the low end at around $300,000 and run to a million bucks pretty quickly. Some have never seen a manufactured home. Some can't imagine that you might have an older, pre-owned home that is livable starting under $10,000. When that is shared with a staffer in a DC office that has no first hand experience of our industry, the question has come up, “Does it have indoor plumbing and facilities?”
This lobbying effort of the CFPB is critical, so well intentioned but uniformed people don't make a mistake, with serious unintended consequences that destroy home values, along with a loss of more jobs and businesses. Whatever you do in manufactured housing this impacts you, along with millions of our customers.
Please. Let's not look back at this time next year and say, 'I wish I would have picked up the phone, emailed and invested an hour in advocacy with my U.S. Representative and Senators.' We've created this summary of what you need on HR 3849, or use MHI's more in depth material. Lobbyists will work with the CFPB. We can't relax on HR 3849. So or in concert with your state association, please take Nike's slogan's advice and “Just Do It.”##
Post by
L. A. 'Tony' Kovach
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Whether you think you can or whether you think you can't, you're right. – Henry Ford
