MHARR’s comprehensive comments — which oppose the DTS implementation plans as currently constituted due to their failure to provide for the securitization and secondary market support of manufactured housing chattel loans in market-significant numbers on an expedited or even timely basis – tie together the reasons and relevant history behind the GSEs decades-long track record of discrimination against manufactured housing and their continual resistance to providing specialized programs for the support of manufactured housing loans. This includes, particularly, the chattel loans used by lower and moderate-income American families to purchase the industry’s most affordable homes.
MHARR’s comments (copy attached), are a must-read for anyone curious to know why these two-faced organizations – chartered by Congress to promote homeownership for credit-worthy low, lower and moderate-income Americans – have virtually ignored manufactured housing, while refusing to provide any type of meaningful support for the lower and moderate-income American families who rely upon HUD Code homes the most. Ironically, whether by accident or design, this inaction by Fannie Mae and Freddie Mac has forced lower and moderate-income American families, who desperately need HUD Code chattel financing, to utilize higher-cost financing currently available in high-volume only from the industry’s two established portfolio lenders … which begs the question as to why these government-sponsored entities – and their federal regulator – would allow such discriminatory policies and outcomes to continue.
As MHARR’s comments indicate, the GSEs total failure to commit to providing any type of actual support for manufactured housing loans – which constitute 80% of manufactured home placements – other than possible token purchases by Fannie Mae, in numbers that would not be market-relevant, is unacceptable, and should be similarly unacceptable to consumers currently paying needlessly high interest rates for HUD Code home loans.
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.