Facts-Evidence-Manufactured Home Industry Expert News Analysis. There is no single factor that explains why the manufactured housing industry is underperforming during an affordable housing crisis. There are several factors, which researchers and manufactured housing industry pros alike agree include the challenges of barriers in zoning and inequalities in finance. That noted, this report and analysis will ‘unpack’ or critically and analytically examine what part, if any, has been played by the CrossMod® Homes in the contemporary underperformance of manufactured housing during an affordable housing crisis.
As part of the context for this analytical journalistic article, the press release (PR) published by Clayton Homes 12.14.2023 is provided below in Part I. That Clayton Homes press release included a version of a video apparently produced by ManufacturedHomes.com for Clayton Homes. Both Clayton Homes and ManufacturedHomes.com are ‘award winning’ Manufactured Housing Institute (MHI) members.
Part II of this report with analysis is the transcript of that Kevin Clayton-Clayton Homes-ManufacturedHomes.com video. That transcript was generated by YouTube as shown on 12.15.2023 of the video, which is also provided in Part II. The YouTube version of that video features the voice and image of Kevin Clayton, President and CEO of Warren Buffett led Berkshire Hathaway (BRK) owned Clayton Homes. That slick-looking 2:28 second video is also provided below.
Part III is a recent HUD News release. It was referenced by Clayton Homes press release, so it helps round out a complete picture of what Clayton Homes and others at MHI are putting forth in their ongoing pitch regarding CrossMods.
Part IV will be still more related information, including sources and insights not previously raised in the ongoing fact-checks and analysis by MHProNews/MHLivingNews with regards to the apparently low-low production performance of CrossMods. How CrossMods has impacted the overall production of manufactured housing will be considered in the light of trends in manufactured housing in the late 20th and the 21st century. In short, there will be an array of facts and evidence provided.
As part of the preface for this article, it is useful to understand what analytical journalism is.
According to left-leaning Wikipedia: “Analytic journalism is a field of journalism that seeks to make sense of complex reality in order to create public understanding. It combines aspects of investigative journalism and explanatory reporting.”
Academic-Accelerator.com similarly stated: “Analytical journalism is the branch of journalism that seeks to understand complex realities in order to generate public understanding.” (Bold emphasis apparently generated by Google in the search used for these definitions). That source also stated: “The main purpose of analytical journalism is to explain. Provide context for your subject matter by providing background, historical details, and statistical data. The goal is a comprehensive description that shapes the viewer’s perception of the phenomenon. Analytical journalism seeks to collect disparate data and establish connections that are not immediately apparent.”
As noted, Part IV of this analytical journalistic report will be additional information that are not part of the press release or video provided by Clayton Homes nor from HUD’s release, but both of those will be explored. As a factual teaser, Part IV includes insights and information generated by MHI which are NOT provided by Clayton or ManufacturedHomes.com as further context for examining the 12.14.2023 Clayton Homes PR. Part IV will also include information from Equity LifeStyle Properties (ELS) owned MHVillage’s MHInsider. According to MHVillage, they are “endorsed” by MHI. The MHInsider trade publication has featured several MHI member firms. MHInsider has also featured the writing of MHI CEO Lesli Gooch. As a disclosure, none of this should be considered an endorsement of Kevin Clayton, Clayton Homes, Berkshire Hathaway, MHI, ManufacturedHomes.com, ELS, MHVillage, or MHInsider. ManufacturedHomes.com will also be explored in this context, as closing credits for the Clayton video reflects that they produced the video used in the Clayton release which was posted on YouTube.
As this is an analytical journalistic article, none of those named above should be construed are being endorsement in any sense as a result of this MHProNews report.
Stockholders and Investors – Take Note
Furthermore, because other MHI members beyond Clayton, ELS, MHVillage, and Manufactured Homes have been involved in the CrossMods adventure, this report may prove to be relevant to the shareholders of several publicly traded firms. The question should be asked and answered: do MHI member firms which are publicly traded and involved in this CrossMods venture which have not completely disclosed the kind of information found herein constitute a material breach of their duties to investors?
To shed further light on the CrossMods subject, insights from the Modular Home Builders Association’s (MHBA) Tom Hardiman, and the Manufactured Housing Association for Regulatory Reform (MHARR) is also included, along with fresh insights from other sources as shown herein in Part IV.
It should be noted that investors are not the only ones potentially harmed by CrossMods. There is an evidence-based case to be made that the employees of manufactured housing industry firms, as well as smaller businesses may also be harmed.
Tom Hardiman, in comments that will be provided, alleged that CrossMods could hurt the valuation of other manufactured homes that aren’t a CrossMod®. But the harms go beyond that, according to fresh insights from sources which will be provided.
Indeed, due to the creation of MHI branded and Clayton Homes, Skyline Champion (SKY) and Cavco Industries (CVCO) supported CrossMods, would there be a need for MHARR to refer to all other manufactured homes as “mainstream” manufactured housing?
Finally, Part V of this article is our Daily Business News on MHProNews updates on manufactured housing industry connected equities report. In the light of the information provided, one might ask: how much higher might manufactured home industry connected equities be if CrossMods had never existed and a broader and long-overdue promotion of ALL manufactured homes had occurred instead of investing years of efforts and untold total dollars in trying to get traction for CrossMods, which was pitched early on – and again by Kevin Clayton below – as a way of growing the manufactured housing industry and its housing market share?
With that plan for this facts and evidence-based exploration of “CrossMods,” Kevin Clayton, et al, let’s begin.
Part I
Clayton Applauds New FHA Appraisal Requirements Improving Valuation of Off-Site Built Homes
Clayton’s CrossMod® Homes Offer an Attainable Housing Solution that Provides Long-term Wealth Building Opportunities for Homeowners
MARYVILLE, Tenn., Dec. 14, 2023 /PRNewswire/ — Clayton, a leading national builder of single-family attainable housing, is positioned to help home buyers benefit from new appraisal guidelines recently issued by the Federal Housing Administration (FHA), which vastly improve the valuation criteria for CrossMod® homes. With the FHA’s updated policy, CrossMod homes will now appraise alongside site-built homes and other CrossMod homes, instead of older off-site built homes without CrossMod features, providing homeowners the opportunity to build equity and wealth over time.
Learn more about Clayton CrossMod homes and the features that make them indistinguishable from traditional site-built homes.
CrossMod homes are challenging zoning restrictions and regulatory barriers where off-site built homes have historically been limited.
Experience the full interactive Multichannel News Release here: https://www.multivu.com/players/English/9130255-clayton-fha-appraisal-requirements/
“We join housing leaders across the country in applauding FHA for their new appraisal guidelines that improve the valuation accuracy for CrossMod homes,” said Kevin Clayton, CEO. “These homes will play an essential role in addressing the affordable housing crisis. We continue to leverage the off-site building process and its sustainable construction efficiencies to help increase housing supply in cities, rural areas, and everything in between – ultimately making homeownership more attainable.”
In growing areas across the country, CrossMod homes are challenging zoning restrictions and regulatory barriers where off-site built homes have historically been limited. For example, two CrossMod homes were placed within city limits in Atlanta earlier this year. The city of Atlanta allows off-site built homes that are secured to a permanent foundation – a zoning ordinance ideal for CrossMod that showcases how flexible policies can increase attainable homeownership opportunities in high-growth cities.
Clayton CrossMod homes include features such as a permanent foundation, an elevated roof pitch, garage, covered porch, drywall interiors and energy-efficient features. These features help make them indistinguishable from traditional site-built homes.
“Increasing the supply of affordable homes in this country will require us to use every tool available to us. That includes innovative solutions like manufactured housing,” said HUD Secretary Marcia L. Fudge in a press release issued November 2, 2023 by the Federal Housing Administration. “The critical step we’re taking today ensures HUD is in alignment with our industry partners, and it will make more quality affordable housing available to people across the country.”
CrossMod homes are built to HUD (U.S. Department of Housing and Urban Development) code and blend the advantages of off-site and site-built construction. With CrossMod, developments can be completed at a more efficient pace, allowing for increased affordable home inventory.
All new Clayton CrossMod homes are eBuilt™, which are homes built to the U.S. Department of Energy’s Zero Energy Ready Home™ specifications and are estimated to save homeowners up to 50% on their annual energy costs1, allowing homeowners to save more money over the lifetime of their home.
Clayton’s CrossMod eBuilt homes are built to add a renewable energy system, like solar, which can offset up to 100% of the home’s energy consumption. The homes are also optimized with energy-efficiency features, like a Rheem® hybrid water heater, low-E windows with argon gas, ENERGY STAR® certified appliances, LED lighting throughout, an ecobee® smart thermostat, and additional insulation.
1 energy.gov ZERH guidelines
About Clayton
Founded in 1956, Clayton is committed to opening doors to a better life and building happyness® through homeownership. A Berkshire Hathaway company, Clayton is a leading single-family, values-driven home builder dedicated to attainable housing, sustainable practices, and creating a world-class experience for customers and team members. The company’s portfolio includes a comprehensive range of site-built, off-site, Tiny, CrossMod® and modular housing. In 2022, Clayton built 62,620 homes across the country. For more information, visit claytonhomes.com.
CrossMod is a registered trademark of the Manufactured Housing Institute.
ENERGY STAR® is a registered trademark owned by the U.S. Environmental Protection Agency.
SOURCE Clayton
Part II – Transcript of Kevin Clayton – Clayton Homes – ManufacturedHomes.com Production of Video Above, per YouTube.
MHProNews Notes: in this transcript that follows, one word is struck (crossbow) and the word CrossMod appears after it in brackets. That is an apparent typo in the YouTube generated transcript which we have corrected for the clarity of the reader. Other typos, including, but not limited to the lack of punctuation, are as in the original transcript generated by YouTube. That noted, “412” below should be 4/12, a reference to the degree of roof pitch.
Transcript
0:00
[Music]
0:06
as we look back at manufactured housing
0:09
historically it’s been nine to ten
0:11
percent of single-family housing in
0:14
America it’s an important 10 percent but
0:17
the question became why can’t
0:19
manufactured housing be a higher
0:21
percentage and so the industry embarked
0:24
on study and if they found that if
0:28
you’ll add the Aesthetics roof pitch
0:30
permanent foundation covered porch a
0:33
garage or a carport people would
0:35
consider a manufactured home as a viable
0:39
housing Choice the number jumps from 10
0:41
percent when surveyed to 46 percent
0:45
so cross mod home means that it has to
0:48
have steeper pitch roof 412 minimum
0:51
covered porch carport or garage area
0:55
it’s going to have permanent foundation
0:58
around the home and Landscaping full
1:01
drywall and so with those qualities
1:03
which are not that difficult to
1:06
accomplish then it gets labeled as a
1:08
cross mod home appraisers are looking
1:11
for that so when they see that it’s in a
1:13
crossbow [i.e.: CrossMod] they know that they’ve either
1:15
got to appraise against other cross mods
1:19
or find site built and that’s really
1:21
what helps
1:25
cross mod will play an important role in
1:28
helping us overcome some hurdles and
1:30
challenges that our industry has
1:32
historically faced and those would be
1:34
getting parity on the zoning lending and
1:37
Appraisal aspects and in many townships
1:41
including my hometown once they saw a
1:44
cross mod they immediately said we want
1:46
these zoned into our area and that’s can
1:49
really now happen across the country you
1:51
know these are built the same building
1:53
materials as a site-built home we’ve got
1:55
the same aesthetic features of the site
1:57
built home I’m really happy and
2:00
everybody in this industry can do their
2:03
part at promoting the cross mod to their
2:05
local officials the consumers will
2:08
dramatically benefit from a cross-mod
2:10
home achieving more for their money
2:13
[Music]
2:18
foreign
##
Part III – HUD Press Release Referenced and Linked by Clayton Homes’s PR Above, Reproduced Below for Ease of Reading and Enhanced Clarity of the Issues Explored Herein
HUD No. 23-251 HUD Public Affairs (202) 708-0685 |
FOR RELEASE Thursday November 2, 2023 |
Federal Housing Administration Changes Appraisal Requirements for Certain Manufactured Homes to Enhance Financing Flexibility for Borrowers
Updated requirements for valuation of manufactured homes contribute to FHA’s efforts to increase the availability and affordability of manufactured housing as part of the Biden-Harris Administration’s Housing Supply Action Plan.
WASHINGTON – The Federal Housing Administration (FHA) today announced the publication of updated appraisal requirements for the valuation of manufactured homes certified under Fannie Mae’s MH AdvantageTM and Freddie Mac’s CHOICEHome® programs. Federal Housing Commissioner Julia Gordon made the announcement this morning at the Manufactured Housing Institute’s National Communities Conference Fall Leadership Forum in Chicago, IL.
The updates align FHA appraisal requirements with those of other industry participants and will improve the valuation of these homes for borrowers seeking FHA-insured mortgages. These changes also contribute to FHA’s efforts to increase the availability and affordability of manufactured housing as part of the Biden-Harris Administration’s Housing Supply Action Plan.
“Increasing the supply of affordable homes in this country will require us to use every tool available to us. That includes innovative solutions like manufactured housing,” said HUD Secretary Marcia L. Fudge. “The critical step we’re taking today ensures HUD is in alignment with our industry partners, and it will make more quality affordable housing available to people across the country.”
“Updating FHA appraisal requirements to align with the Fannie Mae and Freddie Mac certification programs supports our comprehensive efforts to increase both the supply and affordability of manufactured homes,” said Federal Housing Commissioner Julia R. Gordon. “Today, we’ve removed another roadblock limiting the effectiveness of FHA programs in serving buyers of these manufactured homes. We hope it will facilitate the continued growth and adoption of this important source of affordable and energy-efficient housing.”
Effective immediately, FHA’s updated policy for the valuation of manufactured homes certified under the Fannie Mae and Freddie Mac programs requires appraisers to use the most appropriate site-built-home comparable sales when there are less than two comparable sales of these certified manufactured homes available. Manufactured homes certified under the Fannie Mae and Freddie Mac programs, also known as CrossMods, include design features that make them nearly indistinguishable from many site-built homes and address regulatory barriers in effect in some jurisdictions that have historically restricted the placement of manufactured homes.
Among the remarks posted in the comments on the video are the following.
It is worth mentioning that there are several veterans in manufactured housing, including Marine veterans. One might wonder what ties, if any, this purported veteran might have with manufactured housing? According to YouTube: Channel details
Another comment was posted by this writer for MHLivingNews/MHProNews.
@manufacturedhomesyoutubevi3450
11 months ago (edited)
Learn more
4) One of those links above (#6) is to a post on ModularHomeSource.com, which features the writings of “Modular Home Coach,” who per their website is a.k.a.: “Gary Fleisher, Modular Construction Industry Observer and Information Gatherer.” That post provided by Bing AI is dated May 29, 2021, per that website. In a prior post by Fleisher linked here and dated March 5, 2020, are the following remarks. “Last year MHI (Manufactured Housing Institute) introduced the CrossMod manufactured home into the new home marketplace. At the time no-one was taking this seriously… now, everyone should be.” (MHProNews Note: emphasis in the original, hot links removed from MHI and CrossMod, because on this date and time it seems to errantly take the reader to a different website than the Modular Home Coach’s and has nothing visible about CrossMods there. Obviously, the thoughts are his and/or those shared by his website).
Going to the ModularHomeSource.com search tool an article can be found that cites the words of the Modular Home Builders Assocation Executive Director Tom Hardiman on the subject of CrossMods. Hardiman has been cited by ManufacturedHomeLivingNews.com (MHLivingNews.com) previously on this topic, as has ManufacturedHomeProNews.com (MHProNews.com or MHProNews) multiple times. More on Hardiman further below.
5) Fleischer made it plain that he viewed CrossMods as a possible threat to modular builders: “Well, at least those modular home factories and the modular new home builders that are intent on surviving and thriving over the next 10 + years should be [concerned/worried] anyway!” (Again, a hot link is removed, as it goes to a website that is seemingly unrelated to the subject).
From an apparent guest post on Fleischer’s site dated March 1, 20220 is this from: “Shawn Corkrean, Griffith Homebuilders.”
The modular world is rightfully upset about manufactured housing’s new product and marketing effort using the term CrossMod. It is a blatant attempt by HUD manufacturers to blur the line between two very distinctly different levels of construction specifications. They seem to be trying to lay claim to higher spec quality of modular by adding a few features and grabbing the name. I support the modular industries effort to fight this. But, I think there is something much more powerful going on that isn’t being talked about.
CrossMod is really about the total vertical integration of the manufactured housing industry. It is also about an effort to move factory built housing into the mainstream via affordable spec homes built in new single family developments. Clayton seems to be the primary driver of this. (I have no inside knowledge, just reading on the internet) They have the capital backing of Berkshire Hathaway. Clayton has been buying local stick builders across the country. Berkshire Hathaway now has under its umbrella the country’s dominant HUD manufacturer, developable land with local contractor networks, and everything from real estate agents to consumer real estate financing to home insurance companies.
It looks to me like they are setting the stage to control the entire process from buying a 100 acre parcel of undeveloped land to selling you the insurance on your new home. My guess is they can probably sell you a 1,500 square foot CrossMod on a 65’ wide lot for under $190K in many parts of the country. You can also now get traditional 30 year financing with a 3% down payment via the MH Advantage loan product. The only thing in their way currently is local zoning. If they can figure out how to get CrossMod into R-1 Zoning, they will dominate new home construction in the US.”
A pause for some context is useful. It is an open question if Fleisher and/or guest writer on Fleisher’s site Corkrean are aware of the “Manufactured Housing Improvement Act of 2000” and its so-called “enhanced preemption” provision. What is more certain is that a site-search of Fleisher’s site does not reveal any results using this search: “Manufactured Housing Improvement Act of 2000” “enhanced preemption.”
6) After a couple of errors in Bing AI’s response (errantly giving results for the search inquiry shown above on MHProNews, but confusing it with ModularHomeSource.com, this question and the following reply was provided by Bing AI/Bing CoPilot.
Learn more
7) For clarity, there may be no specific need for Fleisher or Griffith Homebuilders’ Shawn Corkrean to know about the subject of the Manufactured Housing Improvement Act of 2000 (MHIA) and its so-called “enhanced preemption” provision. After all, that is obviously a manufactured home industry subject, not one that would be absolutely necessary for a modular builder and/or blogger to be aware of as a key topic. That said, let’s return to Corkrean’s guest post on Fleisher’s site.
Clayton appears to have acknowledged that the independent, lot retailer that has been the core of their scattered site sales strategy for decades is not the path of the future. They are innovating by developing a new sales channel and business model.
I would state that the single family modular industry is facing all the same challenges as Clayton, yet it seems very limited innovation is occurring. The single family modular industry has a drastically lower builder count from ten years ago. Of the builders that remain, it seems few have viable succession plans. The supply of 30, 40 and 50 somethings in the business is very low. Manufacturers seem content with current sales levels and have limited interest in exploring innovation in any areas. There is a wise old saying about things deteriorating: “How do you go broke? Two ways: Gradually and then suddenly”. From my days developing land in 2003-2010, I can attest to the dead-on accuracy of this statement.
I don’t pretend to know the answer. I also know that if I had the level of capital that Berkshire Hathaway brings, it would probably be a lot easier to try a few things. …”
Some Takeaways from Corkrean and Fleisher
8) Let’s focus in on some of remarks made by Corkrean and Fleisher before moving into statements and concerns about CrossMods raised by MHBA executive director Hardiman.
9) In the manufactured housing industry following the formal, direct entry of Warren Buffett led Berkshire Hathaway (BRK) into manufactured housing (see report linked below for details and insights), not only did the number of street retailers dwindle sharply, but perhaps not surprisingly, so too did the number of independent HUD Code manufactured home producers.
10) Note for context and understanding that Barron’s recently cautioned that Buffett was in danger of losing his “good guy” image. To the degree that he had such an image, Barron’s concerns – backed up by additional research using artificial intelligence as shown below, that financial and business news publication may have a valid point. Berkshire brands face several significant legal actions.
11) It should be kept in mind that the Clayton-backed CrossMods initiative involving MHI and other mainly two other MHI brands, i.e.: Skyline Champion (SKY) and Cavco Industries (CVCO), has apparently produced very few actual sales. Per a source with ties to MHBA, MHProNews said that one reason that the MHBA trade association hasn’t pursued the CrossMods issue much is because they too perceive the total number of CrossMods sold as low. Seemingly, too low to fuss over.
12) Let’s pivot back to some follow up inquiries with Bing AI.
Learn more
Learn more
13) To confirm what Bing AI/Bing CoPilot said, the search terms used on 12.15.2023 was: “Tom Hardiman” “Modular Home Builders Association” “sabotage” “monopoly” and there are no specific matches, per Google.
Note: to expand this image below to a larger or full size, see the instructions
below the graphic below or click the image and follow the prompts.
Note: to expand this image below to a larger or full size, see the instructions
below the graphic below or click the image and follow the prompts.
16) MHProNews has noted that Clayton’s estimate on the number of street retailers lost may be low. It could be more like 10,000 to 20,000 retailers that have vanished since the end of the late 20th century and the dawn of the 21st century. The precise number of street retailers is not known, and much of the data stated now by producers like Clayton Homes (BRK), Skyline Champion (SKY), and Cavco (CVCO) appears to be a mix of street retailers and land-lease communities that also sell HUD Code manufactured homes. That number of street retailers may be around 800 to 1000 nationally, but that is just a rough estimate.
To skip to the chase while illustrating the point, Bing AI said: “I could not find any information on the number of manufactured home street retailers that are not developers or communities licensed to sell HUD Code manufactured homes.”
17) Corkrean aptly noted what MHProNews has numerous times. Namely, that Clayton has been buying site builders. It is no secret that Clayton has said that they aim to blur the lines between various types of factory building and site building. Would it be a stretch to ponder the potentially massive size of the housing market that Clayton Homes might upend, given Berkshire Hathway’s backing? To properly understand the concerns that ought to be considered, someone must go to longtime Buffett friend and ally, William “Bill” Gates and the observations of self-proclaimed longtime Buffett admirer, Robin Harding. Per CNBC, Gates said: “I didn’t even want to meet Warren because I thought, ‘Hey this guy buys and sells things, and so he found imperfections in terms of markets, that’s not value added to society, that’s a zero-sum game that is almost parasitic.’ That was my view before I met him … he wasn’t going to tell me about inventing something.”
Harding also indicated that Buffett undermine markets to thwart competition once he enters rather than invests in them in a more traditional notion.
18. Those remarks might be downplayed as less significant than they appear to be, save for Kevin Clayton’s own musings about Buffett, his loathing of competition, and his apparent desire for monopoly style profits. Per Clayton in a video with transcript linked here and here (the second posted on 12.26.2023) are the following remarks.
19. Buffett himself has stressed how important the moat is to Berkshire thinking and their various brands business models. Note the example Buffett used? Piranhas and crocodiles can be man eaters. Indeed, the image many conjure in pondering those man eaters is often an ugly one. When Buffett himself, one of his CEOs – Kevin Clayton, Bill Gates, and Robin Harding are all making the same observations, it is hardly a conspiracy theory. It seems to be, to put it bluntly, the reality of the moat principle that Clayton said Buffett preaches.
20. To further illustrate the relevance of the moat in Buffett led Berkshire’s world-view, this inquiry was put to Bing AI.
Learn more
MHProNews has used these illustrations of Buffett and his moat principles off and on for years.
21. Put differently, it would seem foolish and perhaps irresponsible to write or talk much about what is occurring in manufactured housing unless someone grasps the meaning and intent of the moat that Buffett preaches and which Kevin Clayton said they teach their team and follow. Yet, there is an odd silence among manufactured housing trade media and/or bloggers in discussing Buffett and Clayton’s prized concepts about the anti-competitive cudgel that can be described as “the moat.” To illustrate, the following from Bing AI/Bing CoPilot.
Learn more
22. The moat principle, its methods and its goals, are one of those ‘truths that are hiding in plain sight.’ When exploring the CrossMods and wondering why Clayton Homes, MHI, and to a lesser degree Skyline Champion and Cavco Industries are pushing an apparently market-failed approach, it should be noted that deeper pockets make it possible to maintain a program that may not be profitable on its own, or may even lose money. To illustrate some remarks and investor-related pitches by the others among MHI’s so-called “Big Three” producers are the following.
24. Perhaps after several fact checks and analyses by MHProNews of Berkshire owned Clayton Homes annual reports, this year Clayton Homes failed to publish such a document. Wonder why?
25. This is sufficient foundation to now more closely examine what Clayton had to say in their latest press release and their shared video with transcript. That will occur in the light of the above, but also HUD’s press release, which was dated November 2, 2023. Note that HUD said the following.
That seems to contradict what Kevin Clayton said about a year ago per the transcript of the video that is part of their 12.14.2023 press release. Quoting from the video transcript, sans the time markers. After citing some CrossMod features, Kevin said: “which are not that difficult [features] to accomplish then it gets labeled as a cross mod home appraisers are looking for that so when they see that it’s in a crossbow [i.e.: CrossMod] they know that they’ve either got to appraise against other cross mods or find site built and that’s really what helps.” Meaning, that may be true NOW, but in what sense was it true when Clayton shared those remarks in that video in 2022?
26. MHProNews previously fact-check that specific video and prior remarks by MHInsider. There was also a usual admission in a document to HUD by MHI, in which MHI said that developers are moving away from CrossMods. Part of the reason, per MHI’s document, was that there was no equal comp treatment by most appraisers.
27. Per a letter signed by MHI CEO Lesli Gooch, Ph.D., to the general counsel at HUD dated 12.5.2022: “FHA should fix its appraisal policies with respect to FHA Title II loans for
CrossMod® homes, which offer manufactured homes with amenities at affordable prices.” It took HUD nearly a year after that letter from MHI’s Gooch to “fix” those FHA policies. But once again, that clearly implies that Kevin Clayton was to some degree exaggerating is misrepresenting the facts about CrossMods and appraisals when he made that video with ManufacturedHomes.com a year ago.
But here is more from that letter by Gooch to HUD. The letter header and Gooch’s signature are added to frame and illustrate, and the letter itself is found in the report linked above in the second linked report in #26 above.
The relevant portion of the MHI letter about CrossMods is found below.
FHA Action is Needed to ensure Accurate Appraisals for CrossMod Homes
CrossMod® homes represent the blending of features characteristic of site-built homes with the innovative, efficient methods used in off-site home construction to create a new class of homes for the manufactured housing industry. CrossMod® homes are placed on a permanent foundation, qualify for conventional financing, help challenge exclusionary zoning ordinances, and are virtually indistinguishable from higher-priced, site-built options.
Unfortunately, FHA guidance to appraisers regarding comparable sales to CrossMods® has unintentionally undermined the objective of providing consumers with the amenities of site-built homes at affordable prices commensurate with them being manufactured homes. Without improved guidance, appraisers will continue to consistently undervalue CrossMod® homes, which will threaten the broad adoption of CrossMods® in the market – and thereby prevent CrossMod® homes from achieving their full consumer potential. That is why we seek your immediate attention to address this issue.
Since CrossMods® are still relatively new in the market, nearby CrossMod® homes often are not available for appraisers to use as comparables for an Enterprise-backed CrossMod ® mortgage loan. While CrossMod® homes are the best and most appropriate comparable for an appraiser to utilize for other CrossMod® homes, when such comparables are not available, site-built homes, along with the appropriate adjustments that are made with any appraisal, are the most appropriate option. Despite FHA guidance suggesting that site-built homes can be used as comparables when no CrossMod® comparables exist, in practice, appraisers instinctively are reverting to using traditional Department of Housing and Urban Development (HUD) Code manufactured homes as comparables, which is permitted by the current FHA guidance.
As a result, the existing FHA CrossMod® appraisal guidance is clearly undermining the programs’ intended effect as appraisals for CrossMod® homes are typically inaccurate – well below true market values. This has caused the utilization of CrossMods® by developers to be stymied because the artificially low appraisal values do not support the necessary loans for purchase. Developers therefore are moving away from CrossMods®, as they do not want to take the risk of transactions failing to close due to faulty appraisals.
Given that FHA manufactured housing CrossMod® programs were created to facilitate manufactured housing that is specifically built to meet construction and architectural design standards that are consistent with site-built homes, it is inappropriate for the programs to be undermined because appraisers are using traditional manufactured homes as comparables. Site-built homes are more physically similar to CrossMod® homes than are traditional manufactured homes. Providing clear appraisal guidelines that require the use of site-built comparables for CrossMod® homes, but only when other CrossMod® homes are not available, will result in clarity for appraisers to ensure they select appropriate sales comparables that are the most physically similar to the subject property.
We urge you to address this problem as soon as possible by changing the language in your guidance for appraisers, so that they have clarity about how to value CrossMod® homes. …”
The document was signed by Lesli Gooch, MHI’s CEO, as shown.
28. Presuming the accuracy of this admission by Gooch and MHI, which is de facto confirmed by the HUD release shown in Part II above, several things are now increasingly clear. Among them? Consider the following.
29. To illustrate the first bullet in 28 above, after an error by Bing AI/Bing CoPilot, the following follow up was provided to obtain a more accurate response.
Learn more
Manufactured Housing Product Matrix
Fannie Mae invests in manufactured housing (MH) loans to serve its mission of expanding affordable housing by providing liquidity to a market segment that is crucial to many Americans. MH offers a low-cost alternative to site-built homes for millions of American households, especially in high-cost and rural areas. We purchase eligible mortgage loans secured by manufactured housing titled as real estate via our approved lender partners.
The matrix below summarizes our eligibility guidelines for standard MH and MH Advantage®. For detailed information, refer to the Selling Guide B-5-2.
(Single- and Multi-Width)
NOTE: The sales price of a new manufactured home may include bona fide and documented costs associated with transportation, site preparation, and dwelling installation at the site.
To be eligible for MH Advantage financing, the home must have an MH Advantage sticker applied by the home’s manufacturer pursuant to an agreement with Fannie Mae (see MH Advantage Appraisal Requirements summary).
Note: Single-width MH is not eligible for MH Advantage.
*Note: Single-width MH is not eligible for cash-out refinance
Second Home (1 Unit, Multi-Width Only) Purchase/Limited cash-out refinance: 90% LTV/CLTV
Investment Property: Not Eligible
<=20 year term for COR
Single-width: Minimum of 2 similar MH comparable sales; one of the MH comparables must be a sale, active listing, or under contract sale with the same single-width configuration; third comparable may be site-built or modular home.
The Manufactured Home Appraisal Report (1004C) or Appraisal Completion Report (1004D) must include photos of the MH Advantage Sticker, HUD Data Plate, HUD Certification Labels, and the site showing all driveways, sidewalks, and detached structures located on the site. Lender must review the appraisal photos to confirm MH Advantage eligibility.
Refer to the MH Advantage Appraisal Requirements summary for more information.
85.01–90.00%
90.01–95.00%
25%
30%
85.01–90.00%
90.01–95.00%
95.01–97.00%
12%
25%
35%
25%
30%
35%
Multi-width: Only SFC 235
Single-width manufactured homes must be located in a Fannie Mae-approved subdivision or PUD when the project is a new project or when it is subject to resale restrictions or located on leasehold estate or a community land trust. If the property is located in a condo, co-op, or PUD, the related project data points are also required.
31. It should be obvious that the vast majority of manufactured homes are not a CrossMod® or what Fannie Mae calls MH Advantage® qualified homes, and what Freddie Mac calls a CHOICEhome®. The obvious implication is that all other manufactured homes which are not a CrossMod®, MH Advantage®, CHOICEhome® are placed at a disadvantage. Instead of MHI, Clayton, et al pressing for the full and proper implementation of the Duty to Serve (DTS), the Big Three – via MHI – has pressed the case for their new class of manufactured homes called CrossMods.
Put differently, MHI et al involved have undermined the vast majority of HUD Code manufactured homes. The Manufactured Housing Association for Regulatory Reform (MHARR) has made the case against CrossMods numerous times since the dawn of the MHI program. Their headline below spoke volumes, it is better to fight than switch.
32. MHARR doesn’t hide that it fights for independent producers of HUD Code manufactured homes, and by extension, of the consumers of affordable HUD Code manufactured homes. Per MHARR: “Since MHARR’s establishment, the production of manufactured housing has become increasingly competitive and complex. As the industry has matured, numerous state and federal agencies have sought to impose rules and regulations that could significantly impact its cost and availability as a prime non-subsidized housing resource for Americans at every rung of the financial ladder.” MHARR also said: “Within the industry, the voice of manufacturers — the segment of the industry most directly affected by federal regulation — has tended to be merged with that of other segments of the industry, including retailers, suppliers, finance companies and community developers. Each such segment has its own specific interests and perspective, but unless manufacturers’ views can be articulated, published and advocated independently, the representation of those views is unavoidably weakened by being merged into an “umbrella” representation [i.e.: the Manufactured Housing Institute], which necessarily must be the lowest common denominator among various diverse segments of the industry.”
MHARR also said: “Necessarily, though, the interests of manufacturers – and consumers – are unavoidably impacted by activity and developments affecting the post-production sector of the industry (i.e., activity and developments affecting manufactured homes and consumers once such homes leave the factory). Such activity – by government or quasi-governmental actors – can negatively impact both the utilization and availability of manufactured homes for large segments of the public and can significantly constrain that availability, to the extreme detriment of all concerned. Current examples of this phenomenon include the failure of the Government Sponsored Enterprises (GSEs) to provide securitization and secondary market support for manufactured home loans in accordance with existing law and discriminatory and exclusionary zoning and placement restrictions on manufactured homes in many more densely-populated areas of the United States.”
That has demonstrably proven to be true. MHARR is not only ‘fighting’ HUD, FHFA, DOE, and other federal agencies to get existing federal laws fully and properly enforced. MHARR regrettably also find themselves in the position of having to struggle against MHI and its dominating brands, perhaps the most prominent of which is Berkshire Hathaway owned Clayton Homes.
33. With the advent of CrossMods, the Modular Home Builders Association (MHBA) Executive Director Tom Hardiman apparently felt that they had to weigh in on the controversies related to both consumers and smaller business interests. That was reported by Fleischer’s modular focused website, but also by MHProNews/MHLivingNews. From a report linked on MHLivingNews here, are the following remarks by Hardiman.
“I will never make a disparaging remark about a manufactured home. It is a viable and affordable housing solution that is much needed in this country and has provided decent living accommodations for countless people…If this [MHI and Clayton Homes supported] CrossMod™ [home] is built to the federal HUD code, it’s a manufactured home. Calling it something else is just dishonest, disingenuous, and intentionally misleading. We [MHBA] are calling on the Manufactured Housing Institute [MHI] to stop marketing this product and to stop misleading the public.”
“What happens to the value of tens of thousands of “regular” manufactured housing units when the industry itself turns its back on them…”
Hardiman hit several key issues.
“You may have recently heard about a new trademarked housing product from the Manufactured Housing Institute (MHI) called CrossMod™. According to their sales literature, the home:
Please read that paragraph again, let it sink in, and fully understand exactly what is going on. The term “manufactured home” only appeals to nine percent of potential home buyers. But add the “undefined use of mod” to the name and suddenly it jumps to 46%!”
35. To drill this down to the blunt, there is an array of evidence that could lead to this conclusion. Clayton Homes, with the support of others at MHI, have deliberately undermined several aspects of their own industry. That is the essence of what Minneapolis Federal Reserve researchers broadly call sabotaging monopoly tactics. It is also what outsider looking into manufactured housing Samuel “Sam” Strommen, then with Knudson Law, now an attorney with Goodsell Oviatt Law Firm in Rapid City, South Dakota 1, called “felony” antitrust violations. Strommen’s concerns are summarized in part through this Q&A with Bing AI.
Learn more
36. At best, what Kevin Clayton and Clayton Homes apparently paltered in their video and press release. At worst, they have deliberately misled numbers of manufactured housing industry professionals, arguably including their own employees and investors. Something similar could be said about Lesli Gooch, Skyline Champion, ELS, MHVillage, MHInsider, and ManufacturedHomes.com. The later ought to be either embarrassed and/or ashamed of themselves, given that for years the bulk of their income has come from MHARR member companies. Yet, they seem to have ‘sold out’ to the interests of MHI and their consolidators.
Note that each of the organizations named herein have been given repeated opportunities to respond to the evidence and allegations. They have maintained their silence. So be it. They can respond or debate their respective performance with respect to manufactured housing in a public or online event. We’ve invited that many times, many of them contacted as recently as last week.
37. The question remains. Why would firms undermine the performance of their own industry? The short answer is to more easily consolidate it. Underperformance in manufactured housing acts as a barrier for entry, persistence, and exit. Consider the point that two billion dollars (plus?) have been invested in factory-built housing in the U.S. in recent years. Where are the startups in HUD Code manufactured housing?
38. This isn’t mere hypothesis. It isn’t wild speculation. Rather, there are scores of quotes and documents that directly support the notion that originate from the consolidators themselves. Note that this first document was once available on the MHI website. Now? It’s no longer publicly available, since we at MHProNews/MHLivingNews began to use it to demonstrate the consolidation trends. If it was easy to disprove this factual and evidence-based thesis, don’t you think Clayton, Berkshire, MHI, et al would have done so years ago?
Note: to expand this image below to a larger or full size, see the instructions
below the graphic below or click the image and follow the prompts.
Note: to expand this image below to a larger or full size, see the instructions
below the graphic below or click the image and follow the prompts.
39. Shawn Corkrean, Gary Fleisher, and Tom Hardiman are outside of manufactured housing looking in. They may not have the exposure, time, or insights that MHARR and others who have contributed to these insights have. But each has made useful points that undermine whatever trust that the non-consolidators in manufactured housing may have in what Clayton et al have said about CrossMods.
42. Instead of sending manufactured home production soaring, CrossMods have been part of the 21st century history of sustained downturns in the industry.
43. As a different MHI producer than the one cited above indicated to MHProNews, the math for CrossMods doesn’t pencil out. He explained that the added costs are not ‘paid for’ by the lower interest rates. Someone can buy a residential style manufactured homes add a pitched roof and be considerably less and cost. Residential style manufactured homes have existed for decades. HUD Code builders have often produced modular homes on the same production lines that turn out HUD Code product.
Note: to expand this image below to a larger or full size, see the instructions
below the graphic below or click the image and follow the prompts.
44. Clayton has billions of dollars that they could tap into to regrow manufactured housing, if they wanted to do so. They have the array of resources and influence that Berkshire could bring to whatever it is that they want to do. Who said so? Warren Buffett, per Kevin Clayton. What that means is that they want the status quo, at least for now.
Note: to expand this image below to a larger or full size, see the instructions
below the graphic below or click the image and follow the prompts.
45. Like the DOE report linked below, this has been a DEEPER dive than normal. But on an array of issues, some of them linked herein and below, the Clayton and the industry prove the “illusion of motion” that Mark Weiss, J.D., from MHARR wrote about.
46. Nor should HUD or FHFA be left off the hook. Look at the reports linked below to learn more.
Summary and Conclusion
Part V – is our Daily Business News on MHProNews stock market recap which features our business-daily at-a-glance update of over 2 dozen manufactured housing industry stocks.
This segment of the Daily Business News on MHProNews is the recap of yesterday evening’s market report, so that investors can see at glance the type of topics may have influenced other investors. Thus, our format includes our signature left (CNN Business) and right (Newsmax) ‘market moving’ headlines.
The macro market move graphics below provide context and comparisons for those invested in or tracking manufactured housing connected equities. Meaning, you can see ‘at a glance’ how manufactured housing connected firms do compared to other segments of the broader equities market.
In minutes a day readers can get a good sense of significant or major events while keeping up with the trends that are impacting manufactured housing connected investing.
Reminder: several of the graphics on MHProNews can be opened into a larger size. For instance: click the image and follow the prompts in your browser or device to OPEN In a New Window. Then, in several browsers/devices you can click the image and increase the size. Use the ‘x out’ (close window) escape or back key to return.
Headlines from left-of-center CNN Business – from the morning of 12.14.2023
Note: to expand this image below to a larger or full size, see the instructions
below the graphic below or click the image and follow the prompts.
Headlines from right-of-center Newsmax 12.14.2023
Note: to expand this image below to a larger or full size, see the instructions
below the graphic below or click the image and follow the prompts.
and Finance, other manufactured home industry linked firms (MHC brokerage, suppliers, etc.).
of communities sold by Tricon Capital Group Inc.
(MHCs).
marketplaces. They acquired listing service Homes.com.
marine slips holdings. Also has captive manufactured home retail operations, and parent to Datacomp/MHVillage.
Housing Communities.”KEY = KeyCorp – manufactured home community financing and manufactured home single-family mortgage financing.
homes and modular homes.
2023 …Berkshire Hathaway is the parent company to Clayton Homes, 21st Mortgage, Vanderbilt Mortgage and other factory-built housing industry suppliers.
· LCI Industries, Patrick, UFPI, and LP each are suppliers to the manufactured housing industry, among others.
· AMG, CG, and TAVFX have investments in manufactured housing related businesses. For insights from third-parties and clients about our publisher, click here.
2022 was a tough year for many stocks. Unfortunately, that pattern held true for manufactured home industry (MHVille) connected stocks too. See the facts, linked above.
====================================
Disclosure. MHProNews holds no positions in the stocks in this report.
· For expert manufactured housing business development or other manufactured housing professional services, click here.
· To sign up in seconds for our industry leading emailed headline news updates, click here.
That’s a wrap on this installment of “News Through the Lens of Manufactured Homes and Factory-Built Housing” © where “We Provide, You Decide.” © (Affordable housing, manufactured homes, stock, investing, data, metrics, reports, fact-checks, analysis, and commentary. Third-party images or content are provided under fair use guidelines for media.) (See Related Reports linked herein. Text/image boxes often are hot-linked to other reports that can be access by clicking on them.)
By L.A. “Tony” Kovach – for MHProNews.
Tony earned a journalism scholarship along with numerous awards in history. There have been several awards, honors and numerous public recognitions for his achievements in manufactured housing. For example, he earned the prestigious Lottinville Award in history from the University of Oklahoma, where he studied history and business management. Kovach is a managing member and co-founder of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and MHLivingNews.com, which is ranked as the runaway most read trade media in modern manufactured housing history. This article reflects the LLC’s and/or the writer’s editorial views and may or may not reflect the views of sponsors or supporters.