The rebranded Bureau of Consumer Financial Protection – formerly the CFPB, now the BCFP – has produced a January 2019 report that contains new data regarding manufactured housing lending.
There are over 200 pages. We’ll simplify that for busy readers.
MHProNews will hereby provide the entire document here as a download, while give readers like yourself the most relevant pull-quotes for manufactured housing.
After the quoted sections and tables, the Daily Business News on MHProNews will provide a brief and relevant analysis for manufactured home industry professionals, investors, affordable housing advocates, plus public elected or appointed officials. The graphics are from the name of the report, that included the following quoted items.
7.2.1 Data and methods
This analysis uses the non-public HMDA data described in Chapter 1.350 In the context of this chapter, any reference to “lender(s)” or “creditor(s)” only refers to HMDA reporting lenders. Estimates of small lenders in this analysis are not the complete universe of mortgage originators. The Bureau estimates that there are over 4,000 depository institutions which originate mortgages but are not HMDA reporters. Most, if not all, of HMDA non-reporters would qualify as small creditors due to their small size…
Table 38 reports mortgage originations by small and non-small creditors in rural counties.366 Among small creditors, the share of total originations occurring in rural areas is much larger than for non-small creditors. This appears to be consistent with the higher likelihood that small creditors operate only or predominantly in rural or underserved areas compared to non-small creditors. The 2016a columns suggests that without the 2016 threshold amendments, the rural share of small creditor originations would have stayed the same instead of decreasing to 21…
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Foonote 366) The Bureau publishes a yearly list of rural and underserved counties that are exempt from certain regulatory r equ irements of the Truth in Lending A ct. Bureau of Con sumer Fin. Prot., Rural and Underserved Counties List, available at https://www.consumerfinance.gov /policy-compliance/guidance/implementation-guidance/rural-andu n derserved-counties-list/ (last v isited Dec. 31, 2018) (for the current and previous y ear’s lists).
…percent in 2016 with the amendments. The 2016 amendments did however increase the share of small creditors operating in rural areas due to being more inclusive of larger lenders. The amendments in 20
Table 39 reports manufactured housing mortgage originations by small and non-small creditors. Manufactured housing loans make up a larger share of small lenders’ originations compared to non-small lenders. Similar to rural loan originations, these patterns are consistent with small creditors being more likely to provide access to mortgage credit for manufactured housing compared to larger creditors although the share or manufactured originations that make up a small creditor’s lending has been declining since 2012.
What Does This Reveal for MHPros, Policy Wonks, and Advocates?
Lenders in the manufactured housing space has declined during the period reported.
Put differently, manufactured lending has contracted, just as the number of retailers have shrunk. Here is the key line.
“…small creditor’s lending has been declining since 2012.”
This has occurred in the aftermath of Warren Buffett led Berkshire Hathaway’s acquisition of Clayton Homes, other producers, retailers, and associated lenders, notably 21st Mortgage Corp and Vanderbilt Mortgage and Finance (VMF).
While making noise for several years about making the Duty to Serve by the Government Sponsored Enterprises (GSE) a reality, what the BCFP data reflects is that the opposite is taking place.
Manufactured housing professionals, investors, and advocates? This is another wake up call. For more details, see the related reports, linked below the byline and notices. That’s this afternoon’s Manufactured Housing “Industry News, Tips, and Views Pros Can Use,” © where “We Provide, You Decide.” © ## (News, analysis, and commentary.)
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