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Manufactured Housing Association for Regulatory Reform (MHARR) Targets Fannie and Freddie Chattel Manufactured Home Lending Failure in DTS “Listening Session” Comments.
MHARR-nearly 80% of all manufactured home loans are chattel but despite Congressional mandate some 15 years after Duty to Serve (DTS) federal law not enforced.
— Mark Weiss, J.D., President and CEO of MHARR.
WASHINGTON, D.C., UNITED STATES, July 22, 2023/EINPresswire.com/ — In a media release to manufactured housing professionals, public officials, and others concerned about affordable housing issues, the Manufactured Housing Association for Regulatory Reform (MHARR) provided comments that their president and chief executive officer (CEO) Mark Weiss, J.D., delivered to the recent Federal Housing Finance Agency (FHFA) “Listening Session” on implementation, or the lack thereof, of the “Duty to Serve” mandate for manufactured housing, underserved, and rural markets.
Manufactured Housing Association for Regulatory Reform (MHARR) ‘Targets’ Fannie Mae and Freddie Mac ‘Failure’ in FHFA Duty to Serve Listening Session
JULY 20, 2023
MHARR, in comments (copy attached) delivered to a Federal Housing Finance Agency (FHFA) “Listening Session” on July 18, 2023, has called for the immediate “market-significant” support of manufactured home personal property or “chattel” loans under the statutory “Duty to Serve Underserved Markets” (DTS) mandate.
While chattel loans represent (and have consistently represented) nearly 80% of all new manufactured homes financed in the United States – and are specifically authorized by law for inclusion within manufactured housing sector DTS compliance programs – not a single manufactured home personal property loan has been supported by Fannie or Freddie under DTS since its enactment 15 years ago.
As MHARR made clear in its comments, this impasse, which leaves the vast bulk of the manufactured home financing market completely unserved in violation of the DTS mandate, is unacceptable and cannot continue. That is especially the case with the manufactured housing market having entered a severe downturn, beginning with the third quarter of 2022, which has seen the production of new HUD Code homes plummet year-over-year by a factor of more than 30%.
Consistent with its discussion of this matter with FHFA Director Sandra Thompson at a meeting on June 20, 2023, MHARR stated that the time for further alleged “research” and study by Fannie Mae and Freddie Mac is long past, and that both instead must begin now to provide market-significant support for manufactured home chattel loans, consistent with the explicit directive of Congress in DTS.
Otherwise, MHARR emphasized, if Fannie, Freddie and/or FHFA are unclear on what Congress meant by including chattel loans within the DTS mandate, they should be prepared to take this entire matter back to Congress for clarification that DTS means the entire HUD Code market, as well as a specific, close-in deadline for such market-significant chattel support.
As MHARR made quite clear, the time for delay and obfuscation is over. DTS means what it says, and now is the time for Fannie, Freddie and FHFA itself to live up to the obligations imposed upon them by law.
cc: Other Interested HUD Code Manufactured Housing 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: [email protected]
Website: www.manufacturedhousingassociation.org
The remarks as prepared by attorney and MHARR CEO Weiss included the following remarks.
Re: July 18, 2023 FHFA Listening Session – Duty to Serve Underserved Markets – Manufactured Housing Market…
…Manufactured homes are specifically recognized – and protected – under federal law as a source of inherently-affordable homeownership, and are regulated under a system that is expressly designed to maintain their affordability in a manner that is also consistent with both quality and consumer safety.
Unfortunately, this marks, at least the fifth time that MHARR has addressed one of these Duty to Serve (DTS) “listening sessions.” It is “unfortunate” because DTS should have already been fully implemented within the manufactured housing market by now.
Instead of highlighting the glaring deficiencies and full-blown defiance of Congress and the law by Fannie Mae and Freddie Mac within the HUD Code market, and the Enterprises’ failure to serve, at all, the vast bulk of its consumers, we should instead be here talking about the success of DTS and talking about how DTS-based lending helped to ease the nation’s affordable housing crisis.
Fifteen years later, however, that is not the case and it appears that the entire matter is at an impasse. Whether Fannie and Freddie (or FHFA for that matter) like it or not, the vast bulk of new HUD Code manufactured homes – close to 80% on an ongoing basis per U.S. Census Bureau data– are financed through chattel, or personal property loans.
Financing a manufactured home as chattel may not be the preferred choice of Fannie or Freddie (or even FHFA). But it IS — and has been — the preferred choice of millions of American consumers. And the data is remarkably consistent over time. Going back ten years or more, the census data shows the percentage of chattel loans to all new manufactured home purchase loans fluctuating within a very narrow range, just under 80%…
…whether Fannie and Freddie (or FHFA) like it or not – is that chattel lending predominates and has predominated for many years.
That is the reality and Congress’ directive to Fannie, Freddie and FHFA, through DTS, was to serve that reality – to serve the HUD Code market as it actually exists, not as they or some others would like to see it in some ideal world that has never, in fact, been known to exist.
We are now 15 years down the road since the enactment of DTS and still, nearly 80% of the manufactured housing market remains completely unserved. That is the key fact. Everything else is window dressing and distraction…”
The presenters and organizations, per the FHFA, included the following.
Leslie Gooch-Manufactured Housing Institute
Dave Anderson-National Manufactured Home Owners Association
Rachel Siegel-The Pew Charitable Trusts
Adam Rust-National Community Reinvestment Coalition
Mark Weiss-Manufactured Housing Association for Regulatory Reform
Mary O’Hara-ROC USA
Kaitlyn Garfield-Housing Land Trust of Sonoma County
Amy Bliss-Wisconsin Housing Alliance
Stacey Epperson-Next Step
Deb Campbell-MH Action
Kathleen Paradis-New Hampshire Community Loan Fund
Kyle Lucas-Resident Action at Western Plaza MHP
Thomas Heinemann-MH Advisors
Willie Fleming-Chicago Anti Eviction Campaign
Jill Borders-Borders Family
L.A. “Tony” Kovach-MHProNews.com
RE-Factual-Evidence-for-chattel-is-nearly-80%-of-manufactured-home-lending-and-no-chatte-loans-by-Fannie-Mae-Freddie-Mac-under-DTS-references, see these sources=https://www.urban.org/sites/default/files/2022-07/The%20Role%20of%20Manufactured%20Housing%20in%20Increasing%20the%20Supply%20of%20Affordable%20Housing.pdf=https://www.fhfa.gov/Media/PublicAffairs/PublicAffairsDocuments/Chattel-Pilot-RFI.pdf=https://www.fhfa.gov/Media/Documents/MarkWeiss-remarks.pdf=https://www.pewtrusts.org/-/media/assets/2022/03/alternatives-to-mortgage-financing-for-manufactured-housing.pdf
More About MHARR
https://manufacturedhousingassociationregulatoryreform.org/category/manufactured-home-shipments/
https://manufacturedhousingassociationregulatoryreform.org/category/mharr-issues-and-perspectives/
Mark Weiss, J.D., President & CEO
Manufactured Housing Association for Regulatory Reform
+ +1 202-783-4087
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