At this time, 4:45 AM ET, there are only 4 comments posted on the Federal Housing Finance Agency website. “The current population of the United States of America is 329,784,810 as of Thursday, November 14, 2019, says WorldoMeters. There are some 22 million Americans living in mobile or manufactured housing, roughly 3/4th of those would be HUD Code manufactured home owners.
4 out of all those millions.
The odds are that the vast majority simply:
- don’t know about the issue,
- don’t have the time, based on other priorities,
- don’t think their comments matter if they did send them in.
Alexandria Ocasio-Cortez unseated in a primary an incumbent Democrat. Low voter turnout gave her an opportunity to become a Democratic Representative from her district in New York.
The FHFA isn’t a vote. But the voices and points made could carry an outside significance. Comments are due by midnight tonight and can be submitted electronically.
- Those comments can be viewed, or you can submit your own, via this link.
https://www.fhfa.gov/PolicyProgramsResearch/Programs/Pages/DTSPlanModificationsRFIList.aspx
Here is how that page looks.
Here are the current comments, per the FHFA website.
Here are those 4 as a download.
- Robert ‘Bob’ Van Cleef
- L. A. ‘Tony’ Kovach
- Mark Weiss, Manufactured Housing Association for Regulatory Reform (MHARR)
- Emily Thaden, Grounded Solutions
As the screen capture reflects, this could be hyper-simple. The Housing and Economic Recovery Act (HERA) of 2008 law requires Fannie Mae and Freddie Mac to provide lending and a secondary market to manufactured housing. It is mandatory. Most manufactured home lending is currently home only lending, it is said to be approaching 80 percent. Loans in a manufactured home land-lease community are certainly easier to achieve with a personal property loan, but could be done with a mortgage and a long-term land-lease too.
Fannie Mae and Freddie Mac could and should do this.
- Promptly establish a home-only (a.k.a. personal property, chattel) lending program that applies to all manufactured homes on an equal footing basis. No special advantages to the so-called ‘new class’ of homes. The law recognizes the HUD Code manufactured homes, and they should get robust support.
- Promptly establish a mortgage loan program that could include mortgages made in a land-lease with certain common-sense provisions. Millions don’t realize that conventional housing in Hawaii, Maryland and Chicagoland – to name some examples – are on a land-lease. Mortgages in a land-lease has been done by the GSEs before – and reportedly successfully so.
It may be useful to specifically reject the current branded programs of each GSE that supports the so-called new class of manufactured homes, that were recently called “CrossModTM Homes” by Skyline Champion’s Mark Yost in his Senate testimony. That is favoritism, and who does it benefit? The Big Three builders, not the millions of Americans who already own a manufactured home and may want to refinance, or those consumers who want to buy their first or next manufactured home.
Summing up.
- Enforce the law as written. Fannie Mae and Freddie Mac should supply lending for all HUD Code manfuactured homes, from the least expensive to the highest priced.
- No special programs for special types of HUD Code homes.
What does the current status of the submissions tells us?
The Manufactured Housing Institute (MHI) and their minions are so far silent, per the FHFA page above. That is unlikely to be so by midnight tonight (11.15.2019) which is the submission deadline. Don’t worry, we’ll fact-check and unpack their statements, which will reveal if they are serious about enforcing the law, or if they are playing favorites for a few big boy members.
Ladies and gentlemen, or those trying to make up their minds, the high and mighty MHI has had to pivot on several things in recent months. MHI have made what could be described as tactical retreats. That doesn’t mean that MHI and their masters have lost, nor does that mean that we who favor law enforcement and white hat behavior have won. It does mean that we, MHARR, and people like Bob Van Cleef are beginning to have their voices heard.
It means that “We the people” can win.
These are vexing times, but they are exciting times too.
Do You Want More Competitive Lending for Manufactured Housing?
If you want more competitive lending for manufactured housing, ponder these three options.
You can:
- Submit a letter than can say whatever you’d like (look closely at Bob Van Cleef’s folksy and fact-based, but essentially simple core message), but open and close with this following simple point. The existing plans by Fannie and Freddie are clearly favoring a few big companies, not the millions of Americans that the DTS plan is supposed to support by federal law. Reject the plans by Fannie and Freddie. Make Fannie and Freddie fully comply with the law by supplying lending on manufactured housing with both personal property and mortgage lending.
- You could skip the comments entirely but write your congressional Representative and 2 Senators. We’ll look at that soon, perhaps next week. When you write your Senators and Representative, make that simple and folksy too. Enforce the law. Say why you want to enforce the law. But enforce the law.
The video below makes it clear that Superior Choice credit union was able to successfully enter the manufactured housing market by partnering with Triad Financial Services. As a disclosure, Triad has previously done some business with our publication. But that fact doesn’t change the realities of what those lenders who sat down with our publisher had to say on camera. They weren’t paid to do a video interview, nor did Triad pay for this video. It is a genuine, unscripted video.
What isn’t in that video is where one of the officials from Superior said they thought the GSEs were missing out, and they lauded Triad’s program. Triad has had a successful lending platform in manufactured housing for some 50 years.
The GSEs have no good excuses, as our publisher L. A. ‘Tony’ Kovach said in his letter. The GSEs of Fannie and Freddie don’t have a good excuse. But keep it simple. Bob Van Cleef in his message linked other items, which is certainly permitted. You could link other letters, or link this article or others if you wanted to do so.
But the bottom line is this. Ask the FHFA – which has the authority to do this – to mandate that Fannie and Freddie supply full support for all HUD Code manufactured homes. And/or wait until later, and write your congressional representative and your 2 senators. Make them ask the FHFA to force the Fannie and Freddie to fully enforce the law.
That’s your food for thought on this pre-dawn installment of manufactured housing “Industry News, Tips, and Views Pros Can Use,” © where “We Provide, You Decide.” © ## (News, fact-checks, analysis, and commentary.)
Soheyla is a managing member of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and MHLivingNews.com. Connect with us on LinkedIn here and and here.
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