MY EPIPHANY, and sadly, more…


‘It’s the Issues, Stupid!’ & sadly, more…

What’s an epiphany? It’s ‘a sudden, intuitive perception of or insight into reality or the essential meaning of something, often initiated by some simple, commonplace occurrence.’ Random House Webster’s College Dictionary

First the issues, both macro (‘large, great’) and micro (‘very small’) in size & import.

The macro issue as of February 1, 2010? Amazingly, it’s the same issue today (Now, read this carefully…) as in 1990, when the Hiler Amendment (Our industry’s first legislative initiative to modernize the HUD Code) fell to political skullduggery (Guess by whom?); a decade later, when the Manufactured Housing Improvement Act of 2000 passed, but has never been fully implemented (e.g. Still awaiting the much needed non – career administrative appointee!); and now, another decade later, as manufactured housing ‘fights’ (Wrong word choice there; think instead…) ‘flounders’ toward Free Enterprise oblivion, with bane – like assistance from federal regulators and career bureaucrat(s) at the Department of Housing & Urban Development. The macro issue?

Modernize and segue HUD Code manufactured housing away from its’ trailer heritage of the 1960s,’ mobile home’ image of the 1970s, and manufactured housing identity of the 1980s & 90s, to compete on a level playing field with every other type housing in the U.S.! This is the macro issue that’s failed to materialize in years 1990 and 2000; and now, with dawning of year 2010, unless elected and salaried leaders of this industry bring us together collectively, effectively, and soon, to face known challenges, the micro issues before us today, we’ll indeed fail to survive by year 2020; or as has been said frequently of late: ‘Imagine No New HUD Code Manufactured Homes by Year 2020!’. With that said, what’re the micro issues? List begins here, in no particular order:

• Non – Career Administrative Appointee by HUD
• Residential Fire Sprinklers in Manufactured Homes & Other Types of Housing
• Installation Program & Installation Standards Implementation
• DOE Oversight re MH Energy Standards (Think loss of federal preemption!)
• MHCC Member Composition (No MHARR or MHI staff presence; more later)
• Lack of Secondary Market for Manufactured Housing Sales
• Carried Interest
• Finance (Consumer/Inventory); Fannie Mae & Freddie Mac; FHA Title I Reform
• MHCC/HUD Program
• GSE Duty to Serve Provision
• Weather Radios/disaster Alert Systems
• Formaldehyde – CARB standards
• Energy Tax Credit Extender Legislation
• Pre – 1976 Replacement Home Legislation
• FEMA Emergency Housing Specifications
• FEMA Accountability/Disposal of Temporary Housing Units
• Homebuyer Tax Credit
• Water Submetering
• Frost Free Foundations

So, where to go from here? It’s pretty simple really. Besides motivating and directing our elected and salaried leadership – no small challenge in itself*1; focus their and our attention and action, not inaction, on the macro issue; as well as, identifying, evaluating and confronting, not evading, the micro issues, as new information and legislative initiatives become known and evolve over time! And it’s vital these micro issues be widely and regularly publicized and openly discussed; but no longer in confusing point – and – counterpoint MHARR – MHI Press Release battles played out in the trade press! Speaking of the trade press. Guess how many were represented at MHI’s Winter meeting in Savannah, during early February? One. Our last advertising – supported tabloid, though registered as a Special Guest, was absent; as were all the online ezines and reports. Only the Allen Letter professional journal and the Allen CONFIDENTIAL! business newsletter were represented!

Speaking of the Allen Letter; if we, as an industry, are to continue floundering with two disparate national advocacy bodies attempting to do manufactured housing’s bidding inside the Washington beltway, let’s regularly post their views on macro & micro issues, side – by – side, in the professional journal! The first example of this surprisingly simple, but illustrative, exercise occurred in the January 2010 issue of the business newsletter. What happens if one or both bodies decline to publish their position on a micro issue? Think about it. February’s issue of the new Allen Letter professional journal introduces M.H. Ronin, penname for an articulate, 30 year experienced, and highly motivated observer (No, not me!) of the manufactured housing scene. His/her job is to take MHARR & MHI’s published public positions on macro & micro issues, parse them, then attempt to ‘make sense’ of them for you and me!*2

And here’s the ‘sadly more’ part, referenced in the blog title; my take on what was experienced and not experienced at MHI’s Winter meeting in Savannah, GA., on 1 & 2 February 2010. Bottom line first? I’m no longer confident MHI is worthy of efforts and resources to keep it going as the manufactured housing industry’s primary advocate! Huh? You read that right; so now, by way of explanation:

• Only 108 MHI members, non – members and guests registered in advance to attend this meeting. There were several ‘no shows’, and a few add – ons, like Brian Mills, real estate mortgage originator, now correspondent with Centerline Capital Group in St. Petersburg, FL., and the only RE lender present! MHI’s 2009 Individual (print) Directory contains 650 entries. And did you know? MHI’s 2010 Directory will likely be in electronic format? Anyone ask your preference?

• Manufactured Housing Division meeting featured an agenda containing ten specific micro issues and this macro one: ‘Other Goals & Priorities for 2010 for Industry Recovery!’ Care to guess which issue wasn’t even mentioned during their meeting? Yep; the macro one which coulda – woulda – shoulda address The Near Perfect Storm Manifesto’s premise: ‘Imagine No New HUD Code Homes Manufactured by the Year 2020!’ Why? My guess is manufacturers simply didn’t care to discuss the matter. After all, they shipped 49,000+ HUD Code homes during all of 2009 didn’t they?

• Then there was the less than stirring monologue by William W. Matchneer, III; Associate Deputy Assistant Secretary for Regulatory Affairs & Manufactured Housing at the Department of Housing & Urban Development. Challenged on at least three issues: 1) HUD’s failure to appoint a non – career administrator to replace him; 2) restaffing the Manufactured Housing Consensus Committee (‘MHCC’) so there’s no MHARR & MHI technical staff representation on this body for the first time since its’ inception ten years ago; and 3) ‘Why change the rules by which the MHCC functions now?’ Responses? Not worth repeating. But will tell you this. Post – luncheon remarks were more telling than those from the podium, e.g. “A code body (‘MHCC’) needs an industry expert (staffer from MHARR or MHI) on board to examine and communicate the impact of code changes on the MHIndustry!” Guess which advocacy body no longer has anyone on staff with technical expertise? And this, from individuals who insisted on speaking privately: “Thanks for asking the hard questions most of us don’t have the guts to ask!” Faint comfort there.

• Other voiced but unanswered questions from this same meeting? ‘Where’s the much ballyhooed Manufactured Housing Congressional Caucus of years past? Why aren’t they helping us now with our macro and micro issues?”

So, where does all this leave us? For starters, and it pains me to announce this, but I’m not going to waste time and resources organizing and effecting the ‘hinted at’ meeting on February 26th, 2010, at the RV/MH Heritage Foundation Hall of Fame facility in Elkhart, IN. Many reading this blog have been agitating for a National State of the Asset Class (In this case, industry wide) type gathering, a la 2/27/08 in Tampa, FL., to caucus, discuss, agree upon, and widely publish a grassroots – generated Plan of Action to Save Our Industry! So, why no meeting? For the first time in 30 plus years, I’m convinced we do not have national advocacy bodies capable or willing to effectively ‘Carry our coals to New Castle!’, even if we were to create and codify what entrepreneur businessmen and women in this industry and asset class demand they do on our behalf!

Here’s one further example addressing that very point. Is it the Manufactured Housing Association for Regulatory Reform (‘MHARR’) that’s the answer to manufactured housing industry and landlease community asset class travails inside and outside the Washington beltway? No! And here’s why. Read the following paragraph, quoted directly from an MHARR Press Release dated 3 February 2010, one day after MHI’s Winter meeting concluded; then answer the pointed question posed at the end:

“It is…not surprising an increasing number of grassroots industry members
(particularly MHRetailers and LLCommunities), baffled by such delays and
tired of excuses from half of the industry, in Washington, D.C., have become
disenchanted (when) an industry, such as manufactured housing, a leading source
of affordable, non – subsidized housing and jobs throughout the United States,
is being ignored, neglected, penalized and discriminated against in the Nation’s
Capitol – and are looking for strong pressure to be applied in Washington,
D.C. to break this logjam.” (lightly edited. GFA)

The pointed question. ‘How can MHARR apply ‘strong pressure’ on anyone’s behalf, outside HUD Code home manufacturing circles, when every other segment of the industry (e.g. suppliers, financiers, MHRetailers, LLCommunities, and state MHAssociations, a.k.a. ‘the aftermarket, in MHARR’s vernacular) is pointedly excluded from membership in that organization?!’ Accordingly, sufficient ‘strong pressure’ simply isn’t going to occur or come from one shrinking segment of the manufactured housing industry!

So, what’re your views on these end time events, issues and circumstances plaguing the HUD Code manufactured housing industry; and by extension, the landlease community real estate asset class? I’d like to know! Contact me via this website, respond to this blog, or simply phone the MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764 or (317) 346-7156. Again, there’s no meeting planned for 26 February 2010; unless, something unexpected, inspiriting, and compelling (to do so) happens in the meantime..

End Notes.

1. One of the unsolicited responses, to this leadership issue, first raised in the blog: ‘Sarah Palin & ManuFractured Housing!’ put it succinctly: “MHIndustry leaders, & by default – our industry per se, are care – less & leaderless.”

2. To obtain a Free copy of January’s new Allen Letter professional journal, &/or to subscribe to the business newsletter – to also receive a Free copy of the 21st ALLEN REPORT, a.k.a. ‘Who’s Who Among Portfolio Owners/operators of Landlease Communities in North America!’ (By itself, the report retails for $250.00), phone the MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764 or (317) 346-7156, or respond directly to this blog via the website. Never heard of a ronin before? It’s ‘a covert operations specialist with no governmental ties.’ Can you think of a better handle for a columnist writing about a federally regulated industry? Neither could I!

George Allen, Realtor®, CPM®, MHM c/o Box # 47024, Indpls, IN. 46247

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