http://www.mhmarketingsalesmanagement.com/blogs/industryvoices/action-alert-action-needed-by-72210/
I think MHI did a fine job of giving us a ‘go by’ and some resources to contact both FHFA and Congress regarding the pending Request for Modification of the Enterprise Duty to Serve Underserved Markets Proposed Rule (Action Needed by July 22, 2010). Please see the link above for some information.
I’m getting packed for the trip to Washington for the MHI Summer Meeting, but I have to take the time to write, and I urge you to do the same! Here are two of the sample letters I wrote.
The Honorable Representative Mark Kirk
U.S. House of Representatives
Washington, DC 20515
Dear Representative Kirk,
As a member of the Manufactured Housing Institute, and on behalf of the http://www.MHMSM.com factory built housing industry trade journal, I am writing to seek your assistance in serving the more than 18 million Americans served by the manufactured housing industry and respectfully ask you contact:
1. The Federal Housing Finance Agency (FHFA) and request they amend their recently released Enterprise Duty to Serve Underserved Markets proposed rule (75 FR32099) to include personal property lending in the duty government-sponsored enterprises (GSEs) have to serve the manufactured housing market
2. Leaders of the House Financial Services Committee and ask they specifically request FHFA amend its proposed rule to consider personal property lending in the GSE duty to serve manufactured housing requirement that was outlined by Congress in the Housing and Economic Recovery Act of 2008 (HERA; P.L. 110-289)
The manufactured housing industry serves a vital segment of the housing market. Since 1989, it has accounted for 21 percent of all new single family housing sold in the United States. A significant portion of this is in the form of affordable housing, specifically:
• In 2009, 43 percent of all new home sales under $150,000 and 23 percent under $200,000
• 73 percent of manufactured households earn less that $50,000
• 45 percent of manufactured housing borrowers earn 80 percent of less of Area Median Income (AMI)
Originally established to enhance the availability, efficiency and transparency of capital in targeted, economic sectors, including housing, and to reduce the cost of credit in these sectors, government-sponsored enterprises (GSEs) Fannie Mae and Freddie Mac have had done little to support the manufactured housing market. In fact, less that one percent of their business comes from manufactured housing.
In order to increase the liquidity of mortgage investments and improve the distribution of investment capital available for mortgage financing, Congress (through HERA) specifically established a duty for the GSEs to serve underserved markets, including manufactured housing.
This service included developing loan products, flexible underwriting guidelines and a secondary market for mortgages. Congress further specified that FHFA, in assessing GSE fulfillment of this duty to serve obligation, consider loans secured by both real and personal property.
In its proposed rule, FHFA —contrary to Congressional intent—has indicated it will only consider manufactured homes loans secured by real property for purposes of evaluating whether GSE are conforming to their duty to serve the manufactured housing market requirement.
More than 60 percent of manufactured home owners have relied on a personal property loan in order to finance their home purchase. It is exceptionally difficult to faithfully serve any market if more than half of it is excluded from consideration.
I would also add that manufactured housing, being a federally regulated industry, should not be harmed by the actions or inactions of its regulators.
It is for these reason I urge you:
1) contact FHFA and request they amend their proposed rule to consider personal property lending in GSE’s duty to serve manufactured housing; and
2) contact authorization committee leaders and ask they request FHFA amend its proposed rule to include personal property lending in the duty to serve requirements Congress has outlined for GSEs.
Thank you for your consideration of this request.
Sincerely,
Tony Kovach – Editor and Publisher, www.MHMSM.com
tony@mhmsm.com
PS: Many in our industry have lost everything over the challenge of a lack of financing. Factory built housing is an industry that creates and sustains jobs in the United States, and that is very much needed! As an editor for an Industry trade journal, I can tell you that this is perhaps the single most important topic our industry members are concerned about – financing availability to retail customers.
———————————–
Dear FHFA Staffer,
As a member of the Manufactured Housing Institute, and on behalf of the http://www.MHMSM.com factory built housing industry trade journal, I am writing to seek your assistance in serving the more than 18 million Americans served by the manufactured housing industry and respectfully ask that:
1. The Federal Housing Finance Agency (FHFA) amend their recently released Enterprise Duty to Serve Underserved Markets proposed rule (75 FR32099) to include personal property lending in the duty government-sponsored enterprises (GSEs) have to serve the manufactured housing market
The manufactured housing industry serves a vital segment of the housing market. Since 1989, it has accounted for 21 percent of all new single family housing sold in the United States. A significant portion of this is in the form of affordable housing, specifically:
• In 2009, 43 percent of all new home sales under $150,000 and 23 percent under $200,000
• 73 percent of manufactured households earn less that $50,000
• 45 percent of manufactured housing borrowers earn 80 percent of less of Area Median Income (AMI)
Originally established to enhance the availability, efficiency and transparency of capital in targeted, economic sectors, including housing, and to reduce the cost of credit in these sectors, government-sponsored enterprises (GSEs) Fannie Mae and Freddie Mac have had done little to support the manufactured housing market. In fact, less that one percent of their business comes from manufactured housing.
In order to increase the liquidity of mortgage investments and improve the distribution of investment capital available for mortgage financing, Congress (through HERA) specifically established a duty for the GSEs to serve underserved markets, including manufactured housing.
This service included developing loan products, flexible underwriting guidelines and a secondary market for mortgages. Congress further specified that FHFA, in assessing GSE fulfillment of this duty to serve obligation, consider loans secured by both real and personal property.
In its proposed rule, FHFA —contrary to Congressional intent—has indicated it will only consider manufactured homes loans secured by real property for purposes of evaluating whether GSE are conforming to their duty to serve the manufactured housing market requirement.
More than 60 percent of manufactured home owners have relied on a personal property loan in order to finance their home purchase. It is exceptionally difficult to faithfully serve any market if more than half of it is excluded from consideration.
I would also add that manufactured housing, being a federally regulated industry, should not be harmed by the actions or inactions of its regulators and the various departments of the federal government.
It is for these reason I urge the FHFA:
1) amend the proposed rule to consider personal property lending in GSE’s duty to serve manufactured housing.
Thank you for your consideration of this request.
Sincerely,
Tony Kovach – Editor and Publisher, www.MHMSM.com
tony@mhmsm.com
PS: Many in our industry have lost everything over the challenge of a lack of financing. Factory built housing is an industry that creates and sustains jobs in the United States, and that is very much needed! As an editor for an Industry trade journal, I can tell you that this is perhaps the single most important topic our industry members are concerned about – financing availability to retail customers.
—————-
You get the idea. This was just a quick job, but an important one for our Industry. Let’s not be apathetic, or wait for the next person to do it. I did it, so I can look you in the eye and say, please do it too. # #
L. A. ‘Tony’ Kovach
MHMarketingSalesManagement.com or MHMSM.com
847-730-3692 tony@mhmsm.com
