Attached is a September 10, 2012 MHARR letter to Rep. Darrell Issa (R-CA), Chairman of the House of Representatives Oversight and Government Reform Committee, responding to a June 20, 2012 letter from the Chairman inviting MHARR to provide information to the Committee regarding regulatory activity that negatively impacts job growth within the manufactured housing industry. The MHARR letter details the decline of the industry over the past decade with its corresponding negative impacts on job creation and affordable housing opportunities, and ties that decline to specific federal policies and actions that have either failed to implement or have otherwise undermined key reforms contained in the good laws enacted by Congress over the same period, negatively affecting both public and private manufactured home financing and the production process. With this letter, the Association is moving forward on the fourth element of a multi-pronged plan of intensive congressional engagement originally set in motion by the Board of Directors in November 2010
By way of background, in the immediate aftermath of the 2010 elections, which changed the dynamics of Congress, the MHARR Board concluded that the industry (with the single exception of reform legislation to correct specific issues with the SAFE Act and Dodd-Frank law) currently has the beneficial laws it needs and does not require additional legislation to reverse its decade-long decline. Instead, recognizing that the industry as a whole is notorious for failing to implement the good laws passed by Congress for the benefit of the industry and its consumers, the Board determined that MHARR should seek congressional oversight and intervention regarding the failure of multiple federal agencies to fully and properly implement those laws. The Board thus established this congressional engagement phase of its plan, with initiatives designed both to alert Congress to those failures in all their relevant aspects and to establish a full, detailed record on those issues as a springboard for follow-up phases.
The four areas of engagement and oversight targeted by the Board for the congressional engagement phase of its plan included: (1) a detailed overview of the operation of the federal program and specifically its non-implementation of the 2000 reform law; (2) accountability for excessive program spending, budgets and appropriations; (3) the specific impact of the non-implementation of such laws on the industry’s small businesses; and (4) an examination of the intricate details and combined impact of the failure of various federal agencies and affiliates — including but not limited to, HUD, the Federal Housing Administration (FHA), the Federal Housing Finance Agency (FHFA), Fannie Mae, Freddie Mac, Ginnie Mae and others — to fully and properly implement those laws or alter existing policies that discriminate against the industry and its consumers.
As has been reported at each step, the first three aspects of this congressional engagement phase have already gone forward, paying substantive dividends, as Congress has held oversight hearings regarding the federal program and its implementation of the 2000 law; has held a hearing to examine the condition of the industry; has acted for the first time to hold HUD accountable for its program budgets and expenditures; and has triggered a Government Accountability Office (GAO) investigation of the HUD program.
As for the fourth aspect of the congressional engagement phase, MHARR’s initial engagement with Chairman Issa and the Oversight and Government Reform Committee had to be deferred due to the Committee’s intensive involvement with other major national issues. As noted above, however, Chairman Issa wrote to MHARR on June 20, 2012, specifically renewing this engagement and inviting MHARR to update and expand on its original communication – which MHARR is now doing through the attached package.
Now that all four aspects of MHARR’s congressional engagement phase are being fully addressed, and the non-implementation of key reforms contained in the industry’s beneficial laws with their corresponding negative impacts have been, are being, and will be documented and revealed before Congress, MHARR has already started to initiate other follow-up phases of the Board’s plan, as discussed at the MHARR March 2012 Board of Directors meeting. Complete details of these follow-up phases, intended to address and ultimately remedy government discrimination against the industry and its consumers, as well as efforts to have manufactured housing included in the nation’s major housing programs, will be addressed at the November 2012 meeting of the MHARR Board of Directors.
