The U.S. Department of Housing and Urban Development’s (HUD) Office of Policy Development and Research (PD&R) has published notice in the Federal Register of an impending study designed to identify and assess local barriers to the siting and utilization of HUD Code manufactured homes. Such a study was specifically proposed and requested by MHARR in an April 4, 2019 meeting with PD&R officials and in a subsequent April 24, 2019 communication to HUD Secretary Ben Carson ( copy attached ).

A study of local barriers to the use and placement of mainstream HUD Code manufactured housing could be a significant first step in addressing one of the two major national post-production impediments to the greater use and utilization of manufactured housing that MHARR has consistently emphasized to the White House, HUD and the Federal Housing Finance Agency (FHFA) from the start of the Trump Administration. These two major barriers, as stressed by MHARR, are: (1) exclusionary and discriminatory zoning against manufactured homes and manufactured housing consumers; and (2) the availability of consumer financing – and particularly personal property consumer financing – supported on a parity, market-significant basis by both Fannie Mae and Freddie Mac. Nearly four years into the Trump Administration, neither of these issues has yet been addressed by concrete, on-the-ground, significant action. Thus, MHARR is pleased that PD&R has taken the first step of announcing this study.

In its April 4, 2019 meeting with PD&R, and in its April 24, 2019 letter, MHARR emphasized that discriminatory local land use, zoning and placement restrictions and exclusionary ordinances are among the key drivers in keeping inherently affordable manufactured homes out of large areas of the United States and simultaneously depriving millions of Americans of the affordable homeownership that they need and want. This has had devastating consequences not only for the availability of affordable housing and homeownership for moderate and lower-income American families, but for the industry as well, which has seen production levels fall far below its historic baseline over the past decade-plus.

And while HUD — as MHARR noted both at the time and in its recent comments to the White House Council on Eliminating Regulatory Barriers to Affordable Housing — has all the statutory authority that it needs in order to overcome and invalidate such baseless restrictions, there has never been an authoritative federal study on the extent and negative impacts of these discriminatory edicts that could serve as the basis and underpinning for such action by HUD or possibly others.

Given the fact that this important step is finally being undertaken, MHARR will continue to follow-up with HUD to ensure that PD&R’s study is paired with concrete, actionable activity to address local barriers to the use and utilization of mainstream HUD Code manufactured housing.  At the same time, MHARR will continue to press FHFA, Fannie Mae and Freddie Mac to take their own concrete, actionable steps to expand the availability of consumer financing for HUD Code homes.

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