Strong coffee please? Maybe an energy drink? Where is the sense of urgency at MHI? If sweet talk and ‘go along to get along’ behavior was all that was needed in what has been described by some as The Washington, D.C. Swamp, then the Duty to Serve (DTS) manufactured housing ‘mandate’ would have been a realized program a decade or more ago. Goal and solution-oriented minds should never forget that Manufactured Housing Institute (MH) CEO Lesli Gooch has a doctorate, a Ph.D. You shouldn’t forget her degree because MHI often won’t let you forget their CEO Gooch’s ‘doctorate’ degree if you read their stuff. Obviously, that doctoral degree lady Gooch has doesn’t make her a doctor that could diagnose a medical or mental illness and recommend a course of treatment that could result in a cure for a bodily ailment. Gooch’s doctorate is in political science. By analogy, a Ph.D. in political science might in theory be able to recommend in her area of expertise a plan and action steps that could cure the ills manufactured housing faces in the political and lobbying arenas. The Wisconsin Housing Alliance (WHA), an MHI affiliate, said Dr. Gooch joined MHI in 2014. Doing the math, some 9 years later, the Housing and Economic Recovery Act (HERA) of 2008 mandated in DTS for manufactured housing is still not being properly enforced? What exactly is Dr. Gooch doing to fix this troubling situation? After all, Cavco’s CEO William “Bill” Boor told members of Congress about an array of woes that beset manufactured housing. Industry production, said Boor, is down sharply in 2022.

Here are parts of what Boor said in his address, speaking on behalf of MHI.

• “Rather than artificially making it more difficult for us to produce quality, affordable housing we believe there are things that Congress and federal agencies can do to facilitate the availability of manufactured housing.”
• “Manufactured housing offers affordability and quality to consumers because of technological advancements, cost savings, and efficiencies associated with the factory-built process.”
• “The manufactured housing industry is at a critical crossroads due to regulatory barriers and market forces. Cumulative shipments from January 1 through April 30, 2023, decreased by 30 percent compared to the same time period of 2022. April 2023 shipments were down 34 percent compared to April 2022 shipments.”

His full testimony with analysis are linked here. But in about 103 words quoted above, Boor summed up much of what MHProNews/MHLivingNews have been reporting in 2023. Thanks, Bill.

So, one question in part that should be asked after Dr. Gooch’s remarks below is this.

• What is MHI’s CEO Gooch – a ‘doctor’ in political science’ who is supposed to have clear ideas on how to fix things in her field, akin to what a medical doctor would do for a patient in their field?

Another question might be this.

• What words of magical wisdom did Dr. Gooch share with the Federal Housing Finance Agency, the regulator and conservator of Fannie Mae and Freddie Mac? FHFA could mandate that Fannie and Freddie enforce the Duty to Serve (DTS) mandate. Did Dr. Gooch say as much?

Let’s see what was actually said in Part I of today’s report is MHI provided DTS comments as they say they prepared them.

Then in Part II, it may make sense why we labeled this a periodic installment of Saturday Satire in MHVille. It will be a ‘You Just Can’t Make This Up’ MHProNews Analysis and Commentary.

Part III is our Daily Business News on MHProNews macro- and manufactured housing connected market report. Note that those manufactured housing connected stocks might be much higher if not for the hijinks and monkey business occurring at some of the top companies at MHI, and MHI’s apparently overpaid and underperforming top staffers.

 

Part I

Duty to Serve Listening Session –
Manufactured Housing Market

July 18, 2022

Remarks by Dr. Lesli Gooch, CEO,
Manufactured Housing Institute

 

Thank you to the team from FHFA, Fannie Mae and Freddie Mac, and everyone joining today.

I am Lesli Gooch, CEO of the Manufactured Housing Institute.

 

Who We Are

MHI is the only national trade association that represents every segment of the factory-built housing industry. MHI’s members are responsible for close to 85 percent of the manufactured homes produced each year.

In 2022, our industry produced over 112,000 homes, accounting for over 11 percent of new single-family home starts and 7 percent of total housing starts.

Duty to Serve

Duty to Serve took a long time to stand up but is now beginning to kick in and I commend the teams at FHFA, Fannie Mae and Freddie Mac for their efforts.

So far, there are some bright spots, but overall Enterprise performance with respect to DTS in the manufactured home space is at best mixed.

GSEs Should Continue to Increase Volume for Real Property Manufactured Home Loans

• MHI believes that the volume of securitized real property manufactured home loans could be substantially increased.
• MHI commends both Fannie and Freddie for several policy changes and variances to its MH products to increase volume and we encourage continued strategies to support real property loans going forward.
• I also want to commend both Fannie Mae and Freddie Mac for the work they have done with respect to the MH Advantage and Choice home programs for Cross Mod homes.
• One area under Duty to Serve we see room for improvement is LLPAs. Fannie and Freddie charge a 50 basis point LLPA for manufactured home loans, except when the borrower has an income below median income.
• We don’t think there is a basis for that LLPA – unless there is clear historical evidence for higher risk, we think this should be eliminated.

Community Loans

With respect to commercial loans for the purchase of manufactured housing communities, these loans have been important, particularly for providing capital so that new owners can purchase aging communities in need of substantial infrastructure improvements.

This preservation function of existing manufactured home communities is critical, both for affordable housing and to preserve home values for homeowners living in those communities.

As I will testify about in tomorrow’s Listening Session, these loans have FHFA requirements for tenant lease protection – which are substantive and cover all the essential land lease protections – but should not be expanded, as this will undermine the critical role these loans serve.

 

Personal Property Loans

The one area that there is universal agreement on that Fannie and Freddie have failed in Manufactured Housing Duty to Serve is personal property – sometimes referred to as chattel – loans.

The Duty to Serve statute does not require Fannie and Freddie to purchase personal property loans – but does say explicitly that they QUOTE – “may consider” such loans.

Fannie and Freddie cannot be considered to be fulfilling their Duty to Serve Manufactured Housing statutory responsibility without purchasing such loans since personal property loans constitute the vast majority of all new manufactured homes.

There is a robust – and profitable – market for manufactured home personal property loans.  But particularly in an era of rising long-term interest and mortgage rates, what is needed is a robust secondary market for such loans – and Fannie and Freddie are uniquely qualified to play this role.

I want to emphasize that the commitment MHI is calling on Fannie and Freddie to make with regard to personal property loans is not simply to buy a few one-off loans, to test the waters, so to speak.

The objective of Enterprise efforts to get back into the personal property loan sector is to create a flow model, under which they agree to purchase all loans that meet underwriting requirements (the way real property loans work) – and to securitize them to gain the significant benefits of accessing secondary mortgage markets.

In closing, I appreciate the opportunity to testify today. ##

 

Part II – Additional Information with MHProNews Analysis and Commentary

Oh, wise and wonderful Dr. Gooch! CEO of “Got Clout?” MHI! How unworthy we in MHVille must seem to you! But somehow you managed to inspire FHFA, Fannie Mae, and Freddie Mac to do what she called: “The one area that there is universal agreement on that Fannie and Freddie have failed in Manufactured Housing Duty to Serve is personal property – sometimes referred to as chattel – loans.” Amazing! After almost 15 years, Gooch’s inspired Listening Session address made FHFA issue a formal letter to Fannie Mae and Freddie Mac. That letter MANDATES that each put – how exactly did Dr. Gooch say it? “Fannie and Freddie cannot be considered to be fulfilling their Duty to Serve Manufactured Housing statutory responsibility without purchasing such loans since personal property loans constitute the vast majority of all new manufactured homes.” Wow! Amazing!

Except that other than the quotes above, which are what MHI said Dr. Gooch said, that isn’t what happened at all.  For all of MHI’s self-proclaimed “Clout,” there are rumors of yawns secretly captured of some FHFA, Fannie and Freddie officials. There are other rumors of FHFA, Fannie Mae and Freddie Mac officials laughing as they made sure that their microphones were muted as Dr. Gooch spoke. Because nothing will happen as a result of her words. Why not? Because the amazingly wise Dr. Gooch said this: “The Duty to Serve statute does not require Fannie and Freddie to purchase personal property loans – but does say explicitly that they QUOTE – “may consider” such loans.” Is that what MHI has been saying in press releases on this topic? Is that why Dr. Gooch and MHI have been telling the industry in the last 15 years? Hardly. This is just one example of many from Dr. Gooch in 2021.

Oh, my oh my…”MHI is disappointed that Fannie Mae and Freddie Mac have not carried through on their Duty to Serve Market Plans to resume purchases of chattel  [loans on] manufactured homes…’ Disappointed? Like, you spilled a little water on the tablecloth at a nice restaurant in front of snooty friends disappointed?

Dr. Gooch is still playing junior high school kissy kissy with those who are failing to enforce the law or do their mandated duty? So, have we waited long enough to ask: where is Dr. Gooch’s cure? Is she using reverse psychology on FHFA, Fannie or Freddie when she wrote:

“The Duty to Serve statute does not require Fannie and Freddie to purchase personal property loans – but does say explicitly that they QUOTE – “may consider” such loans.”

You can’t make this stuff up. Since MHI just released this document earlier this week, it is a fine choice for this periodic installment of Saturday Satire.

MHI’s use of paltering and posturing has been demonstrably significant for years. Recall this quotable quote when it comes to MHI: ‘Forget what they told you. You want the truth, follow the money.’ – Roxanne Bland, J.D. and author.

What is the truth? Gooch said it. Manufactured Home Community operators are getting access to “commercial loans for the purchase of manufactured housing communities, these loans have been important, particularly for providing capital so that new owners can purchase aging communities…” Those loans are reportedly in the billions of dollars.  So, why is it that MHI’s consolidators are getting their loans, but street retailers and their consumers or homebuyers on a land lease can’t get their financing in the billions of dollars a year?

Do you see the massive disconnect between the facts and her kissy kissy junior high school remarks? Was the younger version of Dr. Gooch in junior high on the debate team, where she might hone her skills at motivating people with words? Or was she on her junior high school cheerleading team?

 

Facts and Evidence on DTS

Manufactured home community (MHC) operators have had access to ‘cheap money’ under the guise of DTS for years. Reportedly billions of dollars in such community-secured loans have been made in recent years.  But as the Lincoln Institute’s George “Mac” McCarthy said, those loans in a practical sense are making living in those communities less affordable.

McCarthy: ‘Missions of Fannie Mae and Freddie Mac to Help Preserve Affordable Housing-They’re Doing Exactly the Opposite’–Updated 2023 MH Communities Total, New Manufactured Housing Infographics

 

Paul Bradley, with ROC USA and an MHI member, agreed with McCarthy in statements to MHProNews earlier this summer.

 

 Communities

The DTS money is flowing to communities. So is it any surprise that Gooch said:

With respect to commercial loans for the purchase of manufactured housing communities, these loans have been important, particularly for providing capital so that new owners can purchase aging communities in need of substantial infrastructure improvements.

This preservation function of existing manufactured home communities is critical, both for affordable housing and to preserve home values for homeowners living in those communities.”

No need for MHI’s Dr. Gooch to ask for DTS in that sector, is there? That’s because there is plenty of dollars already flowing there.

How about MHI’s branded CrossMod^© plan? Even MHI admitted in writing that CrossMods have been failing to attract developers (or others in any serious volume). It is their -meaning MHI with Clayton Homes (BRK), Skyline Champion (SKY), and Cavco Industries (CVCO) supported – plan. Who can they possibly blame for the obvious CrossMods market failure? Are there any mirrors in Arlington, VA? The numbers on CrossMods are so bad, meaning so low, that neither Lady Gooch nor others in leadership at MHI won’t provide them when repeatedly asked. Per sources, total CrossMod sales are less than 100 units total nationally over the course of several years, during a time when several hundred thousand new HUD Code manufactured homes have been built. CrossMod sales a tiny fraction of a 1/16th of a single percent – a laughable rounding error. Why bother even mentioning it? Where is the benefit for mainstream manufactured housing sellers or consumers? Where is the brilliance of a Ph.D.?

 

Someone could go line by line and point out that most of these remarks are distractions and self-serving drivel. The key point, which Good started off fine with was the following.

“The one area that there is universal agreement on that Fannie and Freddie have failed in Manufactured Housing Duty to Serve is personal property – sometimes referred to as chattel – loans.” So said Gooch, per the MHI provided document shown above.  But then, Gooch gives them an excuse to do NOTHING.

Quoting DR. GOOCH.

“The Duty to Serve statute does not require Fannie and Freddie to purchase personal property loans – but does say explicitly that they QUOTE – “may consider” such loans.” Pardon me? Whose side is Dr. Gooch on? Compare and contrast what Gooch said with what Mark Weiss, J.D., President and CEO of the Manufactured Housing Association for Regulatory Reform said. Read Gooch’s remarks carefully, then do the same with MHARR’s Weiss.

Mark Weiss, J.D., President and CEO of Manufactured Housing Association for Regulatory Reform (MHARR) Remarks on Duty to Serve to FHFA, Fannie, Freddie, Industry Stakeholders; plus MHStocks Update

 

But then Gooch flip flops again. Quoting: “Fannie and Freddie cannot be considered to be fulfilling their Duty to Serve Manufactured Housing statutory responsibility without purchasing such loans since personal property loans constitute the vast majority of all new manufactured homes.” Excuse me again?  Much like MHI seems to want to insist on periodically giving the Department of Energy (DOE) a lifeline, so too she has done the same within a matter of seconds on DTS! A mandate that the GSEs “may” want to do? What is that supposed to mean? We don’t think you have to do this, wink wink, but pretty please with sugar on top? Is that what the millions of dollars that MHI has paid Gooch, with millions more given to MHI’s other top staff, in recent years is buying for the independents who count on MHI doing what they claim to represent “all segments” of the manufactured housing industry? Meanwhile, who benefits? How about Clayton Homes, 21st Mortgage Corporation, and Vanderbilt Mortgage and Finance (VMF), per CFED turned Prosperity Now’s Doug Ryan?

 

 

 

Independent retailers have been vanishing at a steady clip through much of the 21st century. Along with the vanishing street retail base has been a dramatically lower level of manufactured housing retail sales. Where is the surprise? Dr. Gooch, do we need a Ph.D. to understand that thousands of fewer retailers may play a role in the loss of hundreds of thousands of fewer new HUD Code manufactured home sales?

Notice: the graphic below can be expanded to a larger size.

See the instructions below the graphic below or click the image and follow the prompts.

 

 The [Bad] MHI Joke is on Independents, Employees Hoping to Earn Bonuses, Smaller Investors, Taxpayers…

Is it any wonder that thousands of manufactured housing employees, apparently a majority, are unhappy? Those working for 10 of prominent MHI member brands are detailed with evidence in the report below.

 

1000s Unhappy Working at Clayton Homes, Skyline Champion, Cavco, Sun, ELS, RHP, Flagship, Impact, Yes!, Havenpark Communities-What Will They Do? Facts, WalkOut Threat Op-Ed; plus MHMarkets Update

 

Gooch and MHI Vice Chair William “Bill” Boor likely reviewed the remarks made by Boor to Congress prior to their being delivered. After all, it was being made on behalf of MHI. So, why didn’t MHI’s Gooch mention that manufactured housing sales are falling and that third-parties to the industry, as well as industry insiders, have fingered the lack of DTS as a significant contributing factor? So, why didn’t MHI’s doctor of political science think to mention the falling production in her remarks to the FHFA? Why didn’t she rattle some sabers – perhaps threatening using their congressional “champions” to launch an investigation into what’s gone wrong with DTS?

The Cat’s Out of the Bag

Once the cat escapes from the proverbial bag, it becomes more obvious that Gooch is just part of the theater that MHI is playing on behalf of consolidators. Years of talk. Years of promises. Years of no results. But don’t forget to bonus Lady Gooch, Ph.D., and her colleagues!

It will be interesting to see what excuses, err, defenses that purported con artist Chimene Van Gundy will used if her case goes to trial. But in the meantime, look carefully. Do you see the similarities between what Dr. Gooch, Ph.D., does for MHI on behalf of their consolidators and what Van Gundy did for her own enrichment?

 

‘Ever Dream of Being Own Boss, Filling Need in Society?’ Claims of Alleged Multi-Million Dollar Fraudster Chimene Van Gundy-Queen of Mobile Homes-Charged by SEC-Facts, Analysis MHVille Lessons

A scheme to monopolize or consolidate the industry is arguably an ongoing conspiracy that violates various federal laws, said legal Knudson Law researcher Samuel “Sam” Strommen. Said Strommen, he: “submits that the MHI’s conduct in obfuscation of judicious decision-making by the [FHFA and HUD] constitutes a conspiracy to restrain trade under Section 1 of the Sherman [antitrust] Act, and by virtue of the misrepresentative nature of the conduct, should not be afforded Noerr protection.” Applying Strommen’s logic, because that pattern of the “misrepresentative nature of the conduct” by MHI – meaning people like Gooch and others – has been ongoing for years, it is an ongoing conspiracy, by definition.

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See the instructions below the graphic below or click the image and follow the prompts.

Strommen said that in his legal judgment, this is a possible felony case, not merely a civil case involving fines.

Notice: the graphic below can be expanded to a larger size.

See the instructions below the graphic below or click the image and follow the prompts.

 

Until manufactured home professionals, consumers, public officials, and others organize a series of legal challenges to the apparent corruption, the joke is on those who have watched their part of the American Dream slide while a few insiders are consolidating the industry. The good news is that there have been cases brought against some of MHI’s member brands in recent years. But the case can be made that those legal challenges against key MHI organizations and/or officials, including MHI itself, need to be taken up a few notches.

 

Part III. Daily Business News on MHProNews Markets and Headline News Segment

 

Headlines from left-of-center CNN Business – from the evening of 7.28.2023

• A lifeline
• An aerial view shows wind turbines during a tour for the dedication of the Limestone Wind Project in Dawson, Texas, on February 28, 2023.
• Mark Felix/AFP/Getty Images
• Wind and solar are propping up the Texas power grid amid a brutally long heat wave
• Prosecutors urge judge to jail Sam Bankman-Fried, saying there are no conditions to stop him from witness tampering
• DOT proposes new car standards that would modestly raise fuel economy and push the sale of EVs
• Newly unveiled banking regulation wouldn’t have prevented this year’s US bank failures
• Tupperware shares are up 165% this week as meme stock mania takes hold
• IMF, Argentina reach staff deal on loan reviews to unlock $7.5 billion
• World Cup helped Qatar Airlines score a $1.2 billion profit
• The Fed’s favorite inflation measure cooled down even further in June
• Americans continue to feel better about inflation and the economy
• WhatsApp unveils new video messaging feature
• Adidas clearing out more Yeezy shoes in second wave
• Why oil prices are on their strongest run since before Russia invaded Ukraine
• US paychecks aren’t growing as quickly. That’s good for the Fed — but not for workers
• ExxonMobil earnings fell on sinking oil prices
• Why is the US dollar losing its shine?
• Europe’s recession may already be over
• Japan sends yen soaring and stocks tumbling with hint it could join rate-hiking party
• Bollywood film ‘Bawaal’ accused of trivializing Holocaust and demeaning victims
• The real reason Republicans are forcing Mark Zuckerberg to turn over thousands of pages of Facebook documents
• ‘Barbenheimer’ is stimulating the economy
• Ford’s EV losses climb but overall profits rise
• Oreo maker increases growth forecast thanks to demand for cookies, sweets
• Billionaire investor Leon Black is accused of raping teen in Jeffrey Epstein’s NY townhouse

 

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Headlines from right-of-center Newsmax 7.28.2023

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