As part of the follow-up to the previously-reported May 24, 2012 meeting with officials of the Federal Housing Finance Agency (FHFA) seeking to advance a program of volume securitization and/or purchase (S/P) support for manufactured home chattel lending by the Government Sponsored Enterprises (GSEs), MHARR has filed comments (attached) in an FHFA rulemaking calling on that agency to provide full credit for manufactured home chattel loans under proposed affordable housing goals (AHG) for 2012-2014. Because the FHFA rulemaking specifically addresses AHG credit for manufactured home chattel loans (see below), the rulemaking links AHG credit and the broader issue of S/P support for home chattel loans, thereby providing MHARR (and other industry members) with a prime opportunity to once again press for full federal S/P support for manufactured home chattel lending that would increase the availability of those loans and the number of participating lenders.
As the FHFA rulemaking currently stands, the proposed 2012-2014 AHG goals would totally exclude credit for manufactured housing chattel loans – more than 70% of the manufactured housing market — continuing a policy change first adopted in the final AHG rule for 2010-2011. If left unchanged, this policy would have three major impacts. First, it would exclude from the affordable housing goals the nation’s mostaffordable housing, while providing AHG credit for loans on much more costly site-built homes, thus discouraging and undermining truly affordable home ownership. Second, it would continue and re-trench the hostility to manufactured housing – and particularly manufactured housing chattel lending — that has been the rule at the GSEs, as reflected by their support for the exclusion of chattel loans from the proposed FHFA Duty to Serve (DTS) rule. Third, it would leave the industry with a limited number of chattel loan issuers, which has drastically bottlenecked the flow of both public and private chattel financing for the industry’s most affordable homes sought by lower and moderate-income homebuyers.
In its comments, MHARR debunks, yet again, the worn-out myths originated by the GSEs and now parroted by FHFA to rationalize the exclusion of chattel loans from AHG credit and federal S/P support, citing successful models within the industry which show that with proper underwriting and pricing, chattel lending can (and will) be a profitable business for the GSEs.
Comments from other industry members – and particularly members from the industry’s post-production sector — on the AHG goals, focused on support for chattel financing, as explained in MHARR’s attached comments, are vitally important precisely because the industry cannot allow the GSEs and FHFA to simply pile one negative supposition on another in the administrative record – with no supporting data – and then use those suppositions to deny volume S/P support for chattel loans, without an industry response at every opportunity showing the true facts regarding those loans. Consequently MHARR is making its detailed comments available at an early date to serve as a model for linking the issue of chattel lending support to the AHG goals.
MHARR, accordingly, urges industry members (again, especially members within the post-production sector) to file their own individual comments regarding the importance of chattel lending to the industry and the need for volume S/P support for such loans as a prelude to even more intensive upcoming efforts on this front. The filing deadline for comments is July 26, 2012.
Editor’s Note:
Email: Comments to Alfred M. Pollard, General Counsel, may be sent by email to RegComments@fhfa.gov. Please include ‘‘RIN 2590–AA49’’ in the subject line of the message.
Please see the attached
MHARR.affordablehousinggoalscomments
