What’s Going On With MHI? More on FHFA, DTS & GSEs…

Blog # 426 Copyright 2016 COBA7 @ 25 December 2016; community-investor.com

Perspective. ‘Land-lease communities, previously manufactured home communities, & ‘mobile home parks’, comprise the real estate component of manufactured housing.’

This blog posting is the sole national advocate voice, official ombudsman & historian, research report & online communication media for North American LLCommunities.’

To input this blog &/or affiliate with Community Owners (7 Part) Business Alliance, a.k.a. COBA7, use Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764.

COBA7 Motto: ‘U Support US & WE Serve U!’ Goal of its’ print/online media = to ‘Not only inform & opine, but to transform & improve MHBusiness model performance!’

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INTRODUCTION: Have you noticed? Ever since COBA7 was founded in early 2014, MHI has redoubled its’ membership recruiting efforts (That’s a good thing); hired more staff (To what end? Little to no change in services); and now lays fallacious claim to more housing representation than warranted. Why? Maybe out of fear of losing ground to the other two national advocates for manufactured housing in general, land-lease communities in particular.

Why not be content with being primary LOBBYIST for HUD-Code home manufacturers, already controlling more than 85 percent of manufactured housing national market share? Encourage MHARR to continue to OPPOSE INCREASED REGULATION of smaller, regional home manufacturers! And, leave COBA7 to focus on PRODUCTS & SERVICES, such as statistical research & reporting, information sharing, print & online communication, interpersonal networking & realty deal-making, as well as professional property management training & certification of LLCommunity owners/operators throughout North America?

Perhaps year 2017 will come to be viewed as the ‘shakeup year’, when national advocate identities are established, foci identified and prioritized, to the greater good of the industry and its associated realty asset class!

Here’re additional details…

I.

What’s Going On With MHI?

This, directly from the Manufactured Housing Institute’s (‘MHI’) rejuvenated website:www.manufacturedhousing.org

“MHI – REPRESENTING THE FACTORY-BUILT HOUSING INDUSTRY”

When one accesses the ‘Who We Are’ prompt, there’s this misleading message: “The factory built housing industry produces about 70,000 homes a year and contributes about $2.6 billion to the U.S. economy.” NOT. That’s just the number, and production value, of new HUD-Code homes shipped annually (i.e. 70,544 during year 2015) – and not inclusive of three other types of factory-built housing; all four of which are described here:

• Panelizers. Command 50 percent of national (new housing) market share. These builders use factory-fabricated ‘sheathed external & open interior’ wall panels when building new homes on-site

• Production site builders. Garner 39 percent of national market share. These are the site builders who routinely use factory-built components (e.g. pre-hung windows & doors; floor & ceiling trusses, & more) when building new homes.

• HUD-Code manufactured housing accounts for roughly five percent of national market share, where this type factory-built housing is concerned. And…

• Modular housing accounts for another five percent of national market share where this unique type factory-built housing (i.e. using modules) is concerned.

This is bold overreach on the part of MHI, claiming it represents ALL factory-built housing; when in reality, it might claim just 10 percent of the national (new housing) market share; 10 percent comprised near equally of HUD-Code and modular homes.

Perhaps this of overly broad boast is indicative of an emerging, albeit unfortunate, self-centered mindset at the institute. How so? As you read Part II (following here), listing the plethora of recent Press Releases, blog postings, and commentaries describing ‘FHFA’s DTS Rulemaking & GSEs’, pay close attention to quoted content from MHI’s HOUSING ALERT, dated 19 December 2016. It’ll likely surprise, if not shock, you.

II.

More on FHFA/s DTS Rulemaking & GSEs

In just seven days, including one weekend, no fewer than eight public pronouncements!

12/13 = MHI’s Press Release, couched as a HOUSING ALERT, on this timely topic.

12/14 = MHARR’s Press Release. In our opinion, an apt counterpoint to MHI’s alert.

12/14 = Six pre-Webinar Questions posed to FHFA by Ken Rishel of Rishel Consulting

12/16 = FMHA Memorandum summarizing DTS Rulemaking information to date…

12/18 = Blog Posting # 425 @ community-investor.com, summarizing and comparing published views of three national manufactured housing advocates: MHI, MHARR, & COBA7.

12/19 = FHFA receives business model summary from a land-lease community portfolio owner/operator, describing 60 new HUD-Code homes financed within four properties, during the past decade, with only four defaults. Secret to Success? “Every one of (the) buyers/borrowers was qualified, based on their 10-15% down payment, rental history, and strict adherence to minimum front and back end debt-to-income ratios.”

12/19 = MHI’s HOUSING ALERT. Summarizes its’ earlier Press Release of 12/13, and from all appearances, takes full credit for the recent DTS rulemaking progress – wholly ignoring contributions by other manufactured housing national advocates attending same FHFA’s public meeting, and their respective submissions of comment letters. Lest you think we exaggerate:

• “The final rule is the culmination of a multi-year effort by MHI to educate Fannie Mae, Freddie Mac, and FHFA on the fundamentals of the manufactured housing finance market….” No one else advised FHFA on these matters? Several did!

• MHI efforts included the following: “Extensive discussions with consumer groups initially hostile to manufactured housing loans…but in press reports are now being referred to as ‘advocates’ for chattel lending.” How ’bout MHARR’s meetings with consumer group leaders? And COBA7’s affiliate ROCs*1?

• MHI again, “Participating in working groups with the GSEs, to educate them about chattel loan operations issues….” MHARR & COBA7 also participated.

• MHI and again, “Submitting an extensive comment letter that rebutted concerns about the risk of chattel loans…&…made an aggressive argument for a stronger duty to serve rule.” One among more than a thousand such comment letters…..

12/19 = Web Conference re Duty to Serve. More than 120 individuals participated in this hour long conference. Rulemaking, as it applied to the three underserved markets (i.e. manufactured housing, affordable housing, rural housing) was presented at length. This webinar to be followed by three Listening Programs, sponsored by FHFA; in Chicago on 25 January; Washington, DC., on 8 February, and in San Francisco, CA. For more information and to register, visit www.fhfa.gov/dts

Yes, it’s truly been a hectic and exciting week, since the FHFA (that’s short for Federal Housing Finance Agency) announced, 13 December 2016, that ‘GSEs Will Receive Duty to Serve Credit for Manufactured Housing Chattel Loans’. And yes, there’s much work to be done, as GSEs now select and assemble the ‘nuts & bolts’ of the chattel capital programs to serve manufactured housing in land-lease communities throughout the U.S.

But, you know what would HELP a LOT going FORWARD? If the three national manufactured housing advocates, i.e. MHI, MHARR, & COBA7, would ‘work together’ to influence and assist FHFA and GSEs in this timely and important task of converting policy into procedure – instead of grandstanding separately. Will it happen? Only if YOU, as a member of one or more of these entities, suggest – no, insist, they do so for your business benefit and theirs! Your request falls on deaf ears? Then perhaps it’s time to align with another of the national advocates – for the greater good of the manufactured housing industry! Think about it. How many other times will such a challenge and opportunity be presented to us? Let’s not squander this means to positively influence our collective business future!

If you’d like to make your opinions known on this heady topic, i.e. access to chattel capital for manufactured housing sited within land-lease communities, write gfa7156@aol.com and let us know soon! GFA

End Note.

1. ROC = resident-owned communities via ROC USA.

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George Allen, CPM & MHM
Box # 47024, Indpls, IN. 46247
(317) 346-7156

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