MHARR Comments Merit Careful Review, Support and Adoption
Washington, D.C., October 22, 2019 – The Manufactured Housing Association for Regulatory Reform (MHARR) has submitted detailed comments ( copies attached) to the Manufactured Housing Consensus Committee (MHCC) in support of the Association’s proposals for the reform or elimination of ten abusive and/or excessive regulations or pseudo-regulations that have impaired the production of affordable HUD Code manufactured homes and have saddled American consumers and the industry with needless regulatory compliance costs for decades.
MHARR’s comments, which are a “must-read” for all businesses, individuals and consumers with an interest in federally-regulated manufactured housing, accurately, factually and methodically address and unravel specific abuses and excesses by both program regulators and contractors in imposing illegitimate and baseless mandates which have reduced the production and availability of affordable manufactured housing in direct violation of federal manufactured housing law.
Further, MHARR’s comments expose persistent patterns of conduct by those same parties to repeatedly force such dictates on industry members without either prior MHCC review or notice and comment rulemaking as affirmatively, expressly and specifically required by Congress in the Manufactured Housing Improvement Act of 2000 and more recently in Trump Administration Executive Orders.
In Washington, D.C., MHARR President and CEO Mark Weiss stated: “For nearly forty years, MHARR has pointed out how HUD Code manufacturers, retailers, communities and consumers have been victimized by excessive and unnecessary regulations and related compliance costs, which needlessly drive-up prices for HUD Code manufactured homes and needlessly exclude lower and moderate-income Americans from the HUD Code market and from all of the benefits of homeownership. Congress sought to remedy these abuses through the central program reforms incorporated in the Manufactured Housing Improvement Act of 2000, including: (1) proper, lawful, consensus-based rulemaking; (2) an appointed program administrator; and (3) fully-competitive program contracting.” Weiss continued: “Now, thanks to President Trump, Secretary Carson and Assistant HUD Secretary Brian Montgomery, the portions of the 2000 reform law designed to remedy regulatory abuses, ensure consensus-based rulemaking and restore the legitimacy of the rulemaking process are finally being addressed, and MHARR’s proposals in this area should be carefully reviewed, fully-supported and adopted by the full MHCC.”
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.
Washington, D.C., October 22, 2019 – The Manufactured Housing Association for Regulatory Reform (MHARR) has submitted detailed comments ( copies attached) to the Manufactured Housing Consensus Committee (MHCC) in support of the Association’s proposals for the reform or elimination of ten abusive and/or excessive regulations or pseudo-regulations that have impaired the production of affordable HUD Code manufactured homes and have saddled American consumers and the industry with needless regulatory compliance costs for decades.
MHARR’s comments, which are a “must-read” for all businesses, individuals and consumers with an interest in federally-regulated manufactured housing, accurately, factually and methodically address and unravel specific abuses and excesses by both program regulators and contractors in imposing illegitimate and baseless mandates which have reduced the production and availability of affordable manufactured housing in direct violation of federal manufactured housing law.
Further, MHARR’s comments expose persistent patterns of conduct by those same parties to repeatedly force such dictates on industry members without either prior MHCC review or notice and comment rulemaking as affirmatively, expressly and specifically required by Congress in the Manufactured Housing Improvement Act of 2000 and more recently in Trump Administration Executive Orders.
In Washington, D.C., MHARR President and CEO Mark Weiss stated: “For nearly forty years, MHARR has pointed out how HUD Code manufacturers, retailers, communities and consumers have been victimized by excessive and unnecessary regulations and related compliance costs, which needlessly drive-up prices for HUD Code manufactured homes and needlessly exclude lower and moderate-income Americans from the HUD Code market and from all of the benefits of homeownership. Congress sought to remedy these abuses through the central program reforms incorporated in the Manufactured Housing Improvement Act of 2000, including: (1) proper, lawful, consensus-based rulemaking; (2) an appointed program administrator; and (3) fully-competitive program contracting.” Weiss continued: “Now, thanks to President Trump, Secretary Carson and Assistant HUD Secretary Brian Montgomery, the portions of the 2000 reform law designed to remedy regulatory abuses, ensure consensus-based rulemaking and restore the legitimacy of the rulemaking process are finally being addressed, and MHARR’s proposals in this area should be carefully reviewed, fully-supported and adopted by the full MHCC.”
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.
