However, the DTS credit will not be available under the proposal for manufactured home chattel loans, similar to the reasoning used in its original 2010 proposed DTS implementation rule. The DTS credit under the proposed rule “would be provided for regulatory activities that Fannie Mae and Freddie Mac undertake related to financing manufactured homes titles as real estate and not “chattel” loans … because real estate loans perform better, have greater borrower protections, and have lower default rates than chattel financing.”
While the proposal offers a 90-day public comment, MHARR states FHFA’s revisiting the 2010 rule was supposedly to reassess the addition of manufactured home chattel loans. After a meeting with FHFA in 2014, MHARR thought the agency would include chattel loans, “which provide consumer financing for the vast bulk of industry production and provide lower and moderate-income buyers with access to the industry’s most affordable homes.”
At a meeting with the FHFA in Sept. 2015, MHARR says the agency admitted to having closed door meetings with consumer and other industry representatives, but MHARR senses manufactured home chattel loans will not be included as part of the proposed new DTS rule.
MHARR says industry members should submit comments to FHFA detailing the need for MH chattel loans. ##
(Image credit: Manufactured Housing Association for Regulatory Reform)
