There are some reports that happen to fit like a glove with another on the same day. That can happen by coincidence. It can also happen as a result of planning.
The White House has issued an RFI – Request for Information – something similar to what has recently been published by the FHFA with regards to the Duty to Serve manufactured housing by the government sponsored enterprises of Fannie Mae and Freddie Mac.
In a release from the Manufactured Housing Association for Regulatory Reform (MHARR), the Washington, D.C. based trade group said the following.
WHITE HOUSE COUNCIL REQUESTS INPUT ON REGULATORY BARRIERS TO AFFORDABLE HOUSING
NOVEMBER 25, 2019
TO: MHARR MANUFACTURERS
MHARR STATE AFFILIATES
MHARR TECHNICAL REVIEW GROUP (TRG)
FROM: MHARR
RE: WHITE HOUSE COUNCIL REQUESTS INPUT ON
REGULATORY BARRIERS TO AFFORDABLE HOUSING
The White House Council on Eliminating Regulatory Barriers to Affordable Housing (Council), in a Request for Information (RFI) published in the November 22, 2019 Federal Register (copy attached), has requested information and input from interested parties on “federal, state [and] local laws, regulations, land use requirements and administrative practices that artificially raise the costs of affordable housing development and contribute to shortages in housing supply.”
The White House Council, as previously reported by MHARR (see, MHARR June 26, 2019 memorandum titled, “White House Announces Council on Eliminating Regulatory Barriers to Affordable Housing”), was established by President Trump pursuant to Executive Order 13878 (June 25, 2019) in order to provide recommendations for means and methods to reduce regulatory burdens at both federal Executive Branch agencies and the state and local level which negatively impact the cost and availability of affordable housing and homeownership. This mandate, as described in Executive Order 13878 and the RFI, specifically includes and encompasses not only regulatory burdens imposed by federal agencies, such as HUD (and, potentially, the U.S. Department of Energy – DOE — via “excessive energy … efficiency mandates”) but also state and local requirements, including, but not limited to, “overly restrictive zoning and growth management controls.”
The opportunity to provide comments and related input for consideration by the White House Council, which is chaired by HUD Secretary Dr. Ben Carson and is comprised of officials and designees representing the White House and Executive Branch agencies including, among others, DOE and the Environmental Protection Agency (EPA), is of vital importance to both the industry and consumers of affordable, mainstream manufactured housing. This is because while the Trump Administration and Secretary Carson have pursued regulatory reform initiatives within the federal government (with MHARR having submitted extensive comments and other input in 2017 and 2018 under Executive Orders 13771 and 13777), those initiatives remain pending and must be completed and fully implemented with respect to HUD Code manufactured housing. Just as importantly, such action within the federal government must be matched with equally targeted, aggressive and effective action to end and reverse decades of discrimination against affordable manufactured housing and manufactured housing consumers at the state and, even more particularly, the local level.
MHARR, accordingly, will submit comprehensive comments on behalf of the industry and, more importantly, smaller independent industry businesses, addressing not only the extremely damaging impacts of ongoing excessive and unnecessarily costly HUD (and potential DOE) regulation, but also the devastating effects of discriminatory and exclusionary zoning edicts against manufactured housing, as well as the indefensible and inexcusable failure of relevant federal entities to support the availability of fully-competitive consumer financing for manufactured home purchases.
As usual, MHARR’s comments will be submitted in advance of the filing deadline of January 21, 2020 and will be made publicly available on MHARR’s website (www.manufacturedhousingassociation.org) for the use and reference of other interested parties. In this regard, MHARR urges all interested parties, including industry members, industry state associations, and consumers of affordable housing (and their representatives) to file comments in connection with this critical White House initiative.
The Manufactured Housing Association for Regulatory Reform is a
Washington, D.C.-based national trade association representing the views and
interests of independent producers of federally regulated manufactured housing.
cc: Other Interested HUD Code Industry Members
Manufactured Housing Association for Regulatory Reform (MHARR)
1331 Pennsylvania Ave N.W., Suite 512
Washington D.C. 20004
Phone: 202/783-4087
Fax: 202/783-4075
Email: MHARR@MHARRPUBLICATIONS.COM
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In terms of ‘interesting timing,’ the report published this morning on MHProNews is quite relevant.
There are several common roadblocks that explain the historic underperformance of HUD Code manufactured homes during an affordable housing crisis. Local regulatory barriers are one of them.
However, for those who ‘get it,’ that’s prohibited by federal law. Regrettably, that law is going under-enforced. What the White House Council wants is easy to provide, so long as it includes some key words. Enforce good existing laws, including the Manufactured Housing Improvement Act of 2000, and its enhanced preemption clause.
That’s so simple that no other serious trade media in our industry will touch it – why not? See who is scatching who’s back, and you may found out.
Maybe clarity of insight and useful research to pros and advocates are why readers like you have made us the industry’s big #1? That’s it for now on your second chapter today of manufactured housing “Industry News, Tips, and Views Pros Can Use,” © the #1 most-read and largest professional information resource, where “We Provide, You Decide.” © (News, fact-checks, analysis, and commentary.)
Soheyla is a co-founder and managing member of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and MHLivingNews.com. Connect with us on LinkedIn here and here.
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