Major and Continuing MHARR Accomplishments for the HUD Code Manufactured Housing Industry and Consumers of Affordable Housing

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  • Led the industry in securing the enactment of the Manufactured Housing Improvement Act of 2000(2000 reform law), which mandates specific accountability-based program reforms for the federal manufactured housing program, directed the appointment of a non-career program administrator, established an enhanced level of federal preemption, created the Manufactured Housing Consensus Committee (MHCC)[1]to curb the program’s runaway regulatory activity and ensure cost-effective regulation, and, ultimately, was designed to transform the treatment of HUD Code homes from the “trailers” of yesteryear to legitimate, modern, affordable permanent “housing” for all purposes.
  • Led the industry in developing and securing enactment of the Duty to Serve Underserved Markets (DTS)provision of the Housing and Economic Security Act of 2008 (HERA), in order to direct the Government Sponsored Enterprises (GSEs) (e., Fannie Mae and Freddie Mac) to securitize both real estate and personal property (i.e., chattel) manufactured home consumer loans. MHARR became involved in this finance-related, post-production matter because the lack of an effective, independent, national post-production representative for the industry’s post-production sector had allowed the GSEs to avoid the manufactured housing market almost entirely, in direct violation of their Charter obligations to help promote homeownership for all Americans, including lower and moderate-income families.  More than a decade after the enactment of DTS, its implementation remains a continuing issue, with MHARR aggressively seeking market-significant implementation of its personal property financing element, affecting nearly 80% of the manufactured housing market.
  • Led the industry in changing the leadership of the U.S. Department of Housing and Urban Development’s (HUD) manufactured housing program following the election of President Trump and promoting full and legitimate accountability of the program to senior HUD leadership. This was reported by the Washington Post.
  • Led and continues to lead the effort to implement major reforms to the HUD manufactured housing program contracting process, which has, over the past forty (40)-plus years, resulted in the selection of the same program monitoring contractor(albeit under differing corporate names) without full and fair competition, as required by law.
  • Led and continues to lead the industry in developing and promoting proposed standards for multi-family manufactured housingapproved by the MHCC and recommended to HUD.
  • Led the industry in ensuring the creation of a firewall between specifications for manufactured homes purchased for emergency use by the Federal Emergency Management Agency(FEMA) and general, consumer market homes, thus ensuring the continued affordability and price stability of HUD Code manufactured homes.

 

  • Led the industry in ensuring the creation of a firewall between accessibility standardsfor manufactured homes purchased for emergency use by FEMA and general, consumer market homes, thus ensuring the continued affordability and price stability of HUD Code manufactured homes, while simultaneously promoting full compliance with the Americans with Disabilities Act and related federal accessibility laws.

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[1]The MHCC, established by the Manufactured Housing Improvement Act of 2000, is the centerpiece manufactured housing program reform mandated by that law. Designed to ensure the consensus development and interpretation of both standards and enforcement regulations, as well as adherence to notice and comment rulemaking and all other procedural safeguards, the MHCC is comprised of three groups of individuals – users, producers, and general interest – appointed by the HUD Secretary.