MHARR Past Chairman Stresses Urgent Need For Full DTS Implementation
Washington, D.C., November 20, 2019– The Manufactured Housing Association for Regulatory Reform (MHARR), in remarks delivered at the most recent Duty to Serve “Listening Session,” conducted by the Federal Housing Finance Agency (FHFA) in St. Louis, Missouri, has again called for significant, concrete action by Fannie Mae, Freddie Mac and FHFA to finally implement the statutory “Duty to Serve Underserved Markets” (DTS) in a market-significant manner. This is particularly the case with respect to the nearly 80% of the mainstream HUD Code manufactured housing market financed through personal property (chattel) loans. The DTS directive, enacted by Congress more than a decade ago as part of the Housing and Economic Recovery Act of 2008 (HERA) in order to reverse and remedy decades of discrimination by the Government Sponsored Enterprises (GSEs) against otherwise qualified manufactured homebuyers, has gone entirely unfulfilled and unimplemented by the two GSEs with respect to the vast bulk of mainstream manufactured home purchases financed through personal property loans.
In verbal and written comments (see copy attached) presented to FHFA and GSE officials at the November 18, 2019 “Listening Session,” convened to solicit public input on the development and content of the second set of DTS “implementation” plans to be submitted by Fannie and Freddie for the period 2021-2023, MHARR Past Chairman Edward J. Hussey, Jr. strongly criticized the failure of the GSEs and FHFA to implement DTS at allwith respect to the personal property loans which serve the vast majority of mainstream manufactured homebuyers, while simultaneously acting to divert what minimal DTS activity there was during the 2018-2020 period to more costly non-mainstrea mmanufactured homes under Fannie Mae’s “MH Advantage” program and Freddie Mac’s parallel “ChoiceHome” program. Given these crucial failures, in defiance of Congress’ mandate, the GSEs’ diversion of DTS outside of the mainstream of HUD Code manufactured housing, and the GSEs’ dismal track record with respect to truly affordable HUD Code manufactured housing, Mr. Hussey reiterated the need for accountability reflected in MHARR’s call for a congressional investigation to examine and address the emasculation of DTS as it pertains to the manufactured housing market.
In addition, in response to questions from Fannie Mae and Freddie Mac representatives regarding discriminatory local zoning mandates which either exclude or severely restrict the placement of manufactured homes, Mr. Hussey stressed the importance of the enhanced preemption provision of the Manufactured Housing Improvement Act of 2000, and the need for HUD to aggressively assert that preemption in to order protect consumers and the availability of affordable manufactured housing in all regions and areas of the United States.
As the FHFA “listening sessions” regarding the upcoming 2021-2023 DTS implementation plans continue, MHARR expects to present additional comments addressing the urgent need to significantly expand existing elements of the GSEs’ initial plans in order to fully serve the mainstream HUD Code manufactured housing market in a market-significant manner, as MHARR has consistently urged since DTS was first enacted in 2008.
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., November 20, 2019– The Manufactured Housing Association for Regulatory Reform (MHARR), in remarks delivered at the most recent Duty to Serve “Listening Session,” conducted by the Federal Housing Finance Agency (FHFA) in St. Louis, Missouri, has again called for significant, concrete action by Fannie Mae, Freddie Mac and FHFA to finally implement the statutory “Duty to Serve Underserved Markets” (DTS) in a market-significant manner. This is particularly the case with respect to the nearly 80% of the mainstream HUD Code manufactured housing market financed through personal property (chattel) loans. The DTS directive, enacted by Congress more than a decade ago as part of the Housing and Economic Recovery Act of 2008 (HERA) in order to reverse and remedy decades of discrimination by the Government Sponsored Enterprises (GSEs) against otherwise qualified manufactured homebuyers, has gone entirely unfulfilled and unimplemented by the two GSEs with respect to the vast bulk of mainstream manufactured home purchases financed through personal property loans.
In verbal and written comments (see copy attached) presented to FHFA and GSE officials at the November 18, 2019 “Listening Session,” convened to solicit public input on the development and content of the second set of DTS “implementation” plans to be submitted by Fannie and Freddie for the period 2021-2023, MHARR Past Chairman Edward J. Hussey, Jr. strongly criticized the failure of the GSEs and FHFA to implement DTS at allwith respect to the personal property loans which serve the vast majority of mainstream manufactured homebuyers, while simultaneously acting to divert what minimal DTS activity there was during the 2018-2020 period to more costly non-mainstrea mmanufactured homes under Fannie Mae’s “MH Advantage” program and Freddie Mac’s parallel “ChoiceHome” program. Given these crucial failures, in defiance of Congress’ mandate, the GSEs’ diversion of DTS outside of the mainstream of HUD Code manufactured housing, and the GSEs’ dismal track record with respect to truly affordable HUD Code manufactured housing, Mr. Hussey reiterated the need for accountability reflected in MHARR’s call for a congressional investigation to examine and address the emasculation of DTS as it pertains to the manufactured housing market.
In addition, in response to questions from Fannie Mae and Freddie Mac representatives regarding discriminatory local zoning mandates which either exclude or severely restrict the placement of manufactured homes, Mr. Hussey stressed the importance of the enhanced preemption provision of the Manufactured Housing Improvement Act of 2000, and the need for HUD to aggressively assert that preemption in to order protect consumers and the availability of affordable manufactured housing in all regions and areas of the United States.
As the FHFA “listening sessions” regarding the upcoming 2021-2023 DTS implementation plans continue, MHARR expects to present additional comments addressing the urgent need to significantly expand existing elements of the GSEs’ initial plans in order to fully serve the mainstream HUD Code manufactured housing market in a market-significant manner, as MHARR has consistently urged since DTS was first enacted in 2008.
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.
