In January 2025, with the start of President Donald Trump’s second term fast approaching, MHARR published an Issues and Perspectives (IP) article entitled “Trump 2.0 – The Industry’s Second Chance.” Noting that President Trump first came into office in January 2017 with a domestic policy agenda focused on cutting unnecessary, costly and burdensome federal regulation – particularly on small businesses — the IP detailed the broader industry’s near-total failure to capitalize on that agenda during the four years of President Trump initial term (despite aggressive initiatives by MHARR), in order to ease federal regulatory burdens on manufactured housing producers as well as the post-production sector of the industry and consumers. The IP then recounted various “performative” actions by the Manufactured Housing Institute (MHI) which failed to achieve significant substantive results.
More importantly, though, the article stressed the continuing, urgent need for reform of the HUD program during President Trump’s second term and, most particularly, the crucial need for targeted, effective, broader industry action to address and eliminate the three principal regulatory bottlenecks which have suppressed the industry’s growth and expansion during the 21st Century, specifically:
- Widespread discriminatory zoning exclusion of HUD-regulated manufactured homes;
- Lack of Fannie Mae/Freddie Mac support for manufactured home personal property loans pursuant to the statutory “Duty to Serve” (DTS) mandate; and
- Impending draconian and discriminatory manufactured home “energy conservation” standards.
Accordingly, the January 2025 IP concluded that:
“[T]he start of a second Trump presidential term provides the industry with a remarkable second chance. A second chance to clear away unnecessary and debilitating [energy] regulation. A second chance to eliminate (or significantly reduce) the discriminatory and exclusionary zoning edicts that have wrongly restricted [the] availability [of manufactured housing], and a second chance to demand – and push through to fruition – much-needed federal secondary market and securitization support for the vast bulk of manufactured home consumer chattel loans in accordance with DTS.”
So, with the midway point of President Trump’s second term only a few months away, and the November 2026 midterm elections threatening the possibility of a significant upheaval in the balance of political power in Washington, D.C., where does the industry stand on these three key priorities? And what, if anything, has been accomplished, for the industry as a whole (as contrasted with its largest corporate conglomerates), by – as MHI routinely presents itself – “the only national trade association that represents every segment of the factory-built housing industry?” The short answer, unfortunately, is:
- Not much that could not have been accomplished 40 years ago (before MHI – at that time — withdrew its support, see, below); and
- virtually nothing on the three principal bottlenecks suppressing industry production.
This despite more than a million dollars in reported political contributions paid by MHI’s Political Action Committee (i.e., not including direct political contributions by MHI-connected individuals) between 2023 and 2026 according to public records.
For almost all of President Trump’s second term, to date, MHI’s main focus and main priority – from a public-facing perspective – seems to have been the enactment of legislation ultimately designated the “21st Century ROAD to Housing Act” (ROAD Act). That law, enacted on July 11, 2026 without President Trump’s signature, had two principal “takeaways” for manufactured housing. First, the Act finally repealed the 1974 federal requirement that manufactured homes be built on a “permanent chassis.” Second, the Act — sort of – transferred (or, more accurately, restored) primary jurisdiction over manufactured home “energy” standards to HUD (although it did not, per se, repeal section 413 of the Energy Independence and Security Act of 2007 – EISA — which directed the U.S. Department of Energy to establish manufactured housing energy conservation standards).
MHI, naturally, has touted the ROAD Act as a “major win” for the industry. But the significance of that alleged victory – or whether it is a “victory” at all – is, at a minimum, open to debate and has been the subject of ample misleading commentary. On the issue of optional/removable chassis, the concept of amending the 1974 law to delete the “permanent chassis” mandate was first broached some 40 years ago. Although agreement had been reached on that matter between MHARR, MHI and relevant members of Congress, MHI withdrew its support at a crucial juncture and that amendment – as well as other changes to the 1974 federal manufactured housing law — ultimately failed. So, while the “permanent chassis” change is positive – and was supported by MHARR – it is not a new concept, and its ultimate impact on the industry and consumers will take years to determine, even after the molasses-like HUD regulatory process brings forth the necessary standards and regulations, which itself, will likely take years.
Beyond the singular optional chassis provision, however, the ROAD Act fails to address or rectify in any meaningful way, the principal bottlenecks that have stymied industry production. First, the ROAD Act has no mandatory provision(s) to prevent the zoning exclusion of HUD Code homes. While MHARR submitted a proposed amendment that would have strengthened the existing enhanced federal preemption of the Manufactured Housing Improvement Act of 2000 (2000 Reform Law) to expressly reach such discriminatory and exclusionary mandates, that amendment was not publicly supported by MHI. Second, the ROAD Act does not address the failure of the Government Sponsored Enterprises (GSEs) to provide secondary market or securitization support for the manufactured home consumer chattel loans which constitute nearly 80% of the entire market. Again, while MHARR submitted a proposed amendment to remedy this failure, that amendment was not publicly supported by MHI. And third, while the ROAD Act purports to make HUD the primary regulatory authority for manufactured housing energy conservation standards, the language utilized in the law does not strip the U.S. Department of Energy (DOE) of its regulatory authority under EISA and also contains other weaknesses that could (and likely will) be exploited by future administrations to again try to saddle the industry and its consumers with draconian, unnecessary, discriminatory and excessively-costly energy standards.
Worse yet, on energy regulation, the ROAD Act affirmatively requires new HUD manufactured housing “energy” standards, with continuing updates “not less frequently than once every three years” thereafter. In imposing this mandate, the ROAD Act itself contains no safeguards or guardrails to ensure that any (and all) such standards are both objectively necessary – and more importantly – specifically cost-justified. And, just to illustrate the immediate danger of this baseless mandate, the HUD-manipulated Manufactured Housing Consensus Committee (MHCC) — just days after this directive was enacted – recommended new HUD manufactured housing “energy” standards based on proposals developed by the Committee in 2022, under the gun of the then-looming draconian DOE energy standards, with: (1) absolutely no reconsideration of their merit — or lack thereof; and (2) no specific consideration of the likely current-day cost or market (i.e., consumer) impacts of those now four-year-old recommendations, in direct violation of the 2000 Reform Law. (See, MHARR July 27, 2026 Report – “MHI / ROAD Act Snatch Defeat from Jaws of Victory Regarding Manufactured Housing Energy Standards”).
The ROAD Act, then, essentially leaves intact – without any significant remedy – the three regulatory bottlenecks with the greatest negative impacts on the industry, its production levels, the placement, financing, sales and marketing of manufactured homes, and the overall availability of affordable, mainstream manufactured homes for Americans.
Meanwhile, as MHARR recently communicated to HUD Secretary Scott Turner, the HUD manufactured housing program – under its current leadership — has been steadily regressing back to the abuses, mismanagement and discrimination against smaller industry businesses that characterized the program prior to President Trump’s first term and during the Biden Administration. As MHARR extensively detailed in that August 12, 2026 communication, these abuses primarily fall into four areas of paramount concern:
- “Corrupt manipulation of the Manufactured Housing Consensus Committee (MHCC) and its processes as established by the [Manufactured Housing Improvement Act of 2000];
- The imposition of (or pending imposition of) needless additional and further regulatory mandates that disproportionately impact and harm smaller industry businesses and consumers;
- Continued operation with the same personnel, same regulatory “contractor,” same regulatory excesses, same anti-small business agenda, perspective and biases, and same lack of transparency (g., failure to respond to multiple time-sensitive Freedom of Information Act requests – for years …) as it did prior to the Trump Administration; and
- Failing to take any action, whatsoever, to fully and properly implement remaining reform provisions of the 2000 Reform Law including, most importantly, the implementation of its enhanced federal preemption authority to invalidate discriminatory state and local zoning mandates which exclude HUD-regulated manufactured housing.”
(Emphasis added). MHARR’s communication subsequently details each of these areas with specific documents, facts and evidence.
Ultimately, beyond calling for specific concrete action by HUD Secretary Turner to address and correct each of these (steadily worsening) key program failures – with particular emphasis on urgent action to federally preempt cases of discriminatory zoning exclusion of HUD-regulated manufactured homes — MHARR’s August 12, 2026 communication and supporting document package calls on the Secretary to “either … correc[t] or elevat[e] [the HUD manufactured housing program] to a position under [the Secretary’s] direct supervision, with an appointed Deputy Assistant Secretary.” (Emphasis added).
Based on this key takeaway and fundamental request to Secretary Turner, MHARR was gratified to learn – on August 24, 2026, some 12 days after MHARR’s communication to Secretary Turner – that the Secretary has appointed Mr. Christopher Patterson, a HUD veteran from the first Trump Administration, to serve as Deputy Assistant Secretary of the HUD Office of Manufactured Housing Programs (OMHP). As MHARR noted contemporaneously with this appointment, while the jury will be out on Mr. Patterson until he begins to actively take control of the HUD program, and MHARR, will, therefore, withhold judgment on him and his appointment, the designation and selection of new leadership for the federal program so close in time to MHARR’s highly-critical communication detailing its extreme mismanagement, is encouraging and potentially significant.
As MHARR’s August 12, 2026 communication makes clear, however, the federal manufactured housing program at HUD has regressed significantly since the end of the first Trump Administration in January 2021. The industry – and most particularly its post-production sector (including, among other things, retailers, communities, consumer financing providers, insurers and developers) – cannot afford performative displays by MHI during the remaining 2+ years of the Trump Administration. Instead, the entire industry must address and finally correct the principal regulatory bottlenecks that continue to threaten its prosperity, its consumers and its very existence going forward.
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MHARR is a Washington, D.C.-based national trade association representing the views and interests of independent producers of federally-regulated manufactured housing.
“MHARR-Issues and Perspectives” is available for re-publication in full (i.e., without alteration or substantive modification) without further permission and with proper attribution to MHARR.
