Washington, D.C.
OCTOBER 28, 2025
TO: HUD CODE MANUFACTURED HOUSING INDUSTRY MEMBERS
FROM: MHARR
RE: MHARR PRESSES FHFA FOR ACTION ON DUTY TO SERVE
The Manufactured Housing Association for Regulatory Reform (MHARR), in written comments to the Federal Housing Finance Agency (FHFA) and in a related October 21, 2025 communication to FHFA Director William Pulte (copies attached), has again called for FHFA to fully implement the statutory Duty to Serve Underserved Markets (DTS) mandate within the mainstream manufactured housing consumer lending market including, specifically, the personal property (chattel) lending market. MHARR encourages industry members to review this package closely, as full implementation of the DTS directive is the easier to remedy of the two main policy bottlenecks that have wrongfully suppressed the availability of inherently affordable manufactured housing for American consumers, but have not been resolved by the industry’s post-production national association.
The comments, filed in connection with FHFA’s Draft Strategic Plan for Fiscal Years 2026-2030 (Draft Strategic Plan), point out that the Plan mentions DTS only once, in passing, without setting out or even mentioning a timeline or framework for full DTS implementation within all segments of the manufactured housing market, including the personal property sector, which historically comprises nearly 80% of the entire manufactured housing consumer lending market.
This failure to address the full implementation of DTS – nearly 20 years since its enactment as part of the Housing and Economic Recovery Act of 2008 (HERA) — in a market significant manner, within the largest single segment of the affordable manufactured housing market, must be unacceptable to every industry member and must be remedied as an urgent priority if FHFA, Fannie Mae and Freddie Mac policy is to be consistent with President Trump’s commitment to expand the supply and availability of truly affordable housing and home ownership. Put differently, the ongoing failure to serve the vast bulk of the manufactured housing consumer financing market represented by personal property loans represents not only a failure to implement DTS in any meaningful manner, but also a de facto repudiation of Congress and its authority.
Accordingly, MHARR’s comments call for the Draft Strategic Plan to be modified, in its final form, to:
- More fully recognize DTS and its central role in the mission of FHFA, Fannie Mae and Freddie Mac;
- More fully detail FHFA’s commitment to the full and robust implementation of DTS for all segments of the mainstream manufactured housing consumer financing market; and
- Establish a timeline for the full and robust implementation of DTS for all segments of the mainstream manufactured housing consumer financing market.
MHARR, as a representative of HUD Code industry producers and manufacturers in the nation’s capital – and as it has consistently since the enactment of DTS — will continue to seek the full implementation of DTS within the manufactured housing market, including personal property loans, and will continue to seek engagement with FHFA to advance that objective. Toward this end, MHARR has also prepared and proposed a legislative amendment to ensure the full implementation of DTS, but without the support or assistance – to date – of the industry’s post-production representation in Washington.
MHARR urges all industry members to submit comments to FHFA seeking the full recognition and implementation of DTS. Comments concerning the Draft Strategic Plan are due on or before November 5, 2025.
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: MHARRDG@AOL.COM
Website: www.
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MHARR’s press releases are available for re-publication in full (i.e., without alteration or substantive modification) without further permission and with proper attribution and/or linkback to MHARR.
The featured image shown was generated using artificial intelligence, as is shown above. The featured image for this article edited the AI typos to correct them as shown for this MHARR article.
Scannable PDFs of the MHARR attachments above are linked here and here.
