HUD Code Industry Manufacturers, Retailers and Communities


MHARR has called on HUD Secretary, Dr. Benjamin Carson, to withdraw – pending further review and follow-up action – a proposed “Interpretive Bulletin” (IB) concerning “frost-free” and frost-protected manufactured housing foundations in freezing climates, issued by the pdf-images.-2jpgHUD manufactured housing program on June 23, 2017.

Citing the regulatory “freeze” order issued by the Trump Administration on January 20, 2017, MHARR’s June 29, 2017 communication to Secretary Carson (copy attached), asks HUD: (1) to state whether the proposed IB was reviewed and approved by an agency head or designee appointed by President Trump after Noon on January 20, 2017, as required by the “freeze” order; (2) to identify any such official(s) or designee(s) who reviewed and approved the proposed IB; and (3) to state whether that official was aware of the multiple fatal defects in the proposed IB that are detailed by MHARR in its communication.

Absent informed approval by an appropriate Trump Administration appointee, in accordance with the January 20, 2017 regulatory freeze order, MHARR’s communication calls for the proposed IB to be withdrawn in toto.

The publication of the proposed IB by the current HUD manufactured housing program administrator — an Obama Administration holdover — despite unanimous stakeholder opposition expressed through the Manufactured Housing Consensus Committee (MHCC) and directly to HUD, is just the latest example of “deep state” action by the program administrator and entrenched regulators to damage the competitive interests of the manufactured housing industry (with no corresponding — or even claimed — benefit to consumers) and undermine President Trump’s regulatory relief agenda.

This action – and others – in recent months by the holdover program administrator, demonstrate, yet again, the urgent need for her re-assignment within HUD and replacement, as manufactured housing program administrator, by a properly qualified individual, with industry knowledge and experience, in accordance with the Manufactured Housing Improvement Act of 2000.

MHARR will aggressively follow-up on this action with HUD.  Industry members, however, should remain prepared to file comments on the proposed IB by the August 21, 2017 deadline.  MHARR will file comprehensive comments in advance of the deadline, which will be made public for information and reference by 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


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