Washington, D.C., May 6, 2020 – The Manufactured Housing Association for Regulatory Reform (MHARR) reports that the U.S. Senate Committee on Banking, Housing and Urban Affairs held a hearing on May 5, 2020 on the pending nomination of Ms. Dana Wade to become HUD Assistant Secretary for Housing/Federal Housing Commissioner. Ms. Wade was nominated by President Trump to fill the position being vacated by Brian Montgomery, who has been tapped to become the Deputy Secretary of HUD. If confirmed by the full Senate, this will be Ms. Wade’s second stint at HUD under the Trump Administration, having previously served as White House liaison at the agency, and in other leadership capacities.

During her prior tenure at HUD, Ms. Wade — at the specific urging of MHARR (which had a pre-determined plan of regulatory reform action based on the election of President Trump,  approved by the MHARR Board of Directors at its March 2016 Annual Meeting and met with her shortly after she arrived at the Department) and in full accordance with President Trump’s regulatory reform policies — moved quickly and decisively with a series of actions designed to improve the management and operation of the federal manufactured housing program, and make it more responsive to the concerns of the industry’s small businesses and consumers.

These actions began with the re-assignment of former manufactured housing program career administrator Pamela Danner, who had devastated the program during her brief four-year tenure, and continued with the initiation of a “top-to-bottom” review of all HUD manufactured housing standards and regulations, steps to include manufactured housing in a range of government housing programs, and action to avoid the designation of a permanent new career manufactured housing program administrator, contrary to the federal law directive, among other things.

Unfortunately, however, since Ms. Wade’s departure from HUD, progress on these and other related initiatives to fully reform the HUD Office of Manufactured Housing Programs (OMHP) have effectively ground to a halt, with substantially less than a year now remaining in President Trump’s first term — and time rapidly running-out.

Thus, contrary to the express directive of the 2000 reform law — and with no objection whatsoever from the Manufactured Housing Institute (MHI) – a new career OMHP administrator was named in 2019. Meanwhile, not a single OMHP standard or regulation has yet been withdrawn or modified as a result of the “top-to-bottom” regulatory review initiated pursuant to President Trump’s Executive Orders 13771 (“Reducing Regulation and Controlling Regulatory Costs”) and 13777 (“Enforcing the Regulatory Reform agenda”). Nor have any of the numerous sub-regulatory “guidance” documents unlawfully issued by OMHP without prior Manufactured Housing Consensus Committee (MHCC) review and rulemaking (including a complete de facto revision of Subpart I) been withdrawn pursuant to Trump Administration Executive Orders 13891 (“Promoting the Rule of Law through Improved Agency Guidance Documents”) and 13892 (“Promoting the Rule of Law through Transparency and Fairness in Civil Administrative Enforcement and Adjudication”).

Perhaps even more significantly, former OMHP administrator William Matchneer’s unlawful 2010 “Interpretive Rule,” reading section 604(b)(6) (requiring MHCC review and rulemaking for any change to HUD policies, practices or procedures affecting the OMHP standards, enforcement and monitoring) out of the 2000 reform law remains in place. Meanwhile, MHI actively opposed an MHARR proposal to withdraw this baseless edict – which illegally invalidates one of the most crucial protections of the 2000 reform law for industry manufacturers — when it came before the MHCC for consideration.

With the OMHP regulatory reform process either stalled or being needlessly slowed through entrenched regulators and contractors – and with MHI allied on multiple matters with outside groups and interests that historically have been industry competitors and detractors – Ms. Wade’s return to HUD may represent the best opportunity that industry members (and particularly its smaller businesses) will have to realize actual, on the ground benefits, from President Trump’s regulatory reform policies. Accordingly, MHARR has vigorously supported her nomination and will continue to closely monitor the pending Senate confirmation process, and work closely with Ms. Wade once she arrives at HUD.

In Washington, D.C., MHARR President and CEO, Mark Weiss, stated: “Dana Wade, during her earlier tenure at HUD, had an enormous impact in rapidly moving the HUD program toward compliance – in key areas – with the Manufactured Housing Improvement Act of 2000.”  He continued, “Her absence, however, has seen a steady and unfortunate erosion in that progress that can and must be reversed when she returns as the top HUD appointee with authority over the federal manufactured housing program.”##

The Manufactured Housing Association for Regulatory Reform is a Washington, D.C.-based national trade association representing the views and interests of independent producers of federally-regulated manufactured housing.

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: MHARR@MHARRPUBLICATIONS.COM
Website: manufacturedhousingassociation.org