This week, MHI submitted formal comments in response to the Federal Housing Finance Agency’s (FHFA) Enterprise Duty to Serve Underserved Markets notice of proposed rulemaking (75 FR 32099).

In its comments, MHI points out that there is a long history of Fannie Mae and Freddie Mac failing to serve the needs of the manufactured housing market. Ultimately, this hurts consumers and those most in need of affordable housing. This is why Congress, through the Housing and Economic Recovery Act of 2008 (HERA; P.L. 110-289), specifically established a duty for the GSEs to serve underserved markets, including manufactured housing.

Unfortunately, as previously reported, FHFA’s proposal only considers “manufactured home loans titled as real property for the purposes of the duty to serve the manufactured housing market.” Despite dozens of meetings with industry members and MHI over the past 18 months stressing the importance of personal property home loans, and despite a Congressional mandate to consider such loans, FHFA continues to ignore the needs of millions of home buyers who rely on these loans. A manufactured home financed with a personal property home loan is among the most affordable forms of homeownership as no land is involved in the loan transaction. Today, the industry estimates that personal property home loans account for at least 60 percent of manufactured housing lending.

In its comment letter, MHI also urges FHFA to amend the proposed rule for land/home or conforming mortgages transactions, as well as broadening existing business in the financing of entire land-lease communities.

As a result of the grassroots efforts of many MHI members, including state associations and land-lease community owners, thousands of retailers, community residents, and other manufactured home consumers submitted comments to FHFA stressing the need for increased participation by the GSEs in the manufactured housing sector, particularly in regards to personal property home loans.

Thank you to all industry members who submitted comments and helped make the consumers voices heard. In particular, thanks to the leadership of the MHI National Communities Council for pushing this suggestion at the MHI Summer Meeting and Legislative Conference last week and getting their residents involved.