FOR IMMEDIATE RELEASE Contact: MHARR
(202) 783-4087
MHARR COMMENTS CALL FOR FULL DTS/CHATTEL IMPLEMENTATION
Washington, D.C., July 30, 2026 – The Manufactured Housing Association for Regulatory Reform (MHARR) has filed written comments (copy attached) in response to a Federal Housing Finance Agency (FHFA) Notice of Proposed Rulemaking (NPR) regarding potential changes to its regulations concerning the statutory Duty to Serve Underserved Markets (DTS) mandate. MHARR’s comments, while conditionally supporting the proposed modifications, call for the full implementation of the DTS directive within the market-dominant manufactured home consumer chattel lending sector via a new regulatory mandate. The Government Sponsored Enterprises (GSEs) failure to do so for nearly two decades, is one of the principal bottlenecks suppressing the growth and expansion of the mainstream HUD Code manufactured housing industry.
In the NPR, published in the June 24, 2026 Federal Register, FHFA, the federal regulator of mortgage giants Fannie Mae and Freddie Mac, seeks comment on a proposed rule to effectively replace the current DTS regulatory structure – for both products that may be offered and compliance evaluation — that has been in place since 2016, with a less complex structure focused on meeting the statutory DTS directives established by Congress under the Housing and Economic Recovery Act of 2008 (HERA).
Significantly, the NPR preamble simultaneously makes it clear that FHFA expects the Enterprises to finally begin serving the market-dominant manufactured housing chattel consumer lending sector (serving nearly 80% of all new manufactured home buyers), stating:
“It would be particularly timely and appropriate for the Enterprises to focus more attention on chattel lending: today approximately 70 to 80 percent of new manufactured homes are titled as personal property, which makes chattel loans the predominant financing option for manufactured homes. *** Consistent with Executive Order 14394, FHFA expects the Enterprises to develop and implement robust, responsible chattel financing initiatives and will assess them on their progress in expanding liquidity, supporting sustainable credit and enhancing consumer choice in the manufactured housing market.”
(Emphasis added).
Given the nearly two-decade track record of Fannie Mae and Freddie Mac – of totally failing and refusing to provide any securitization or secondary market support for manufactured housing chattel loans under DTS, this FHFA directive, in itself, could have a positive impact. As MHARR stresses in its comments, however, that same track record would indicate that both Enterprises would be just as likely to ignore any such FHFA policy statement regarding manufactured home consumer chattel loan support, and continue to deny any support whatsoever for that market-dominant sector.
Accordingly, MHARR, in its written comments to FHFA, supports the proposed regulatory change on the express condition that FHFA simultaneously adds a provision to its DTS regulations affirmatively requiring that the GSEs serve the manufactured housing chattel consumer lending market under DTS. MHARR thus urges FHFA, in its comments, to include a provision in any final rule adopted pursuant to the NPR, stating, in substance:
“Each Enterprise shall – within 90 days of the publication of this final rule – develop loan products and flexible underwriting guidelines to facilitate a secondary market for consumer loans on manufactured homes for very low-, low-, and moderate-income families. Such loans shall include loans secured by manufactured homes titled as real property and by manufactured homes titled or financed as personal property.”
(Emphasis added). While the exact timeframe specified for the implementation of such programs could be different, it is essential, in MHARR’s view, that any new, final DTS regulations specify a fixed and immediate (or near-immediate) deadline for the implementation of such a program on a market-significant basis. Thus, as MHARR further states in its comments:
“MHARR believes that such express language, with corresponding enforcement provisions, is essential to ensure that the Enterprises fully comply with the directive of … FHFA that they fully serve all segments of the manufactured housing market in a market-significant manner without any further or additional delay.”
(Emphasis in original).
In addition to such proposed changes to the DTS implementation and evaluation regulations, the NPR also requests comment on a possible modification of the regulatory definition of “manufactured home” to include “a broader array of non-site-built homes such as modular homes and other types of factory-built homes that are subject to state or local building codes.” MHARR, in its comments, states that it “strenuously opposes” any such change on two grounds. First, federal law already defines the term “manufactured home” with no reference whatsoever to any such other types of factory-built homes, and a different definition in the FHFA DTS regulations would only promote confusion and chaos. Second, and more importantly, MHARR states:
“[S]uch a change would be an open invitation for further subterfuge, defiance and tacit alteration of the statutory DTS directive by Fannie Mae and Freddie Mac. Again, given the GSEs’ miserable track record in serving the mainstream affordable, federally-regulated manufactured housing market under DTS, they should not be provided with a regulatory “off-ramp” to serve other higher-cost forms of housing while continuing their failure to support mainstream, affordable manufactured homes and the lower and moderate-income Americans who rely on them for affordable homeownership.”
(Emphasis in original).
In Washington, D.C., MHARR President and CEO, Mark Weiss, stated: “It is long past time for FHFA to require Fannie Mae and Freddie Mac to finally begin serving the vast bulk of the manufactured home consumer lending market that is represented by chattel loans. The total failure to serve those loans and those consumers for nearly two decades is a profound disservice to American consumers, effectively forcing them to pay needlessly higher interest rates, while lining the pockets of “portfolio lenders” and their well-heeled patrons. FHFA’s emphasis on the need for robust chattel lending is welcome and appropriate, but must be backed-up with specific, compulsory regulatory requirements.”
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.
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MHARR notes that the featured image was generated by artificial intelligence (AI) powered ChatGPT. This MHARR report was written using industry-expert human intelligence.
