February 9, 2018
On The Home Front
A special thanks to Representative Adam Koenig (R) - District 69 for sponsoring KMHI's bill on assistance animals. HB 329 was introduced in the House of Representatives yesterday. This bill summary reads:

AN ACT relating to assistance animals.
    Create a new section of KRS Chapter 383 to allow a person with a disability or disability-related needs to make a reasonable request for an accommodation in housing to maintain an assistance animal; allow a person receiving a request to ask for documentation on the assistance animal; provide penalties for the offense of misrepresentation of an assistance animal.

It had come to KMHI's attention that there was an overreach and abuse with tenants in manufactured home communities using an easy on-line method to obtain an "emotional support" certificate for animals so that they would be allowed in the communities.

Please watch for Calls to Action on this bill and please let your Representative and Senator know that you support this legislation. Thank you.
92,891 New HUD-Code Homes Shipped in 2017 
  7,269 New HUD-Code Homes Shipped in 
December 2017
In December 2017, new manufactured home shipments increased 3.6% to 7,269 homes as compared to the 7,019 homes shipped in December 2016. Total shipments for December 2017 are lower by 1,319 when compared to November 2017. Compared with December 2016, the trend is mixed with shipments of single-section homes down by .4% and multi-section homes up by 9.1%. Total floors shipped in December 2017 increased 5.1% to 10,500 compared to December 2016.

HUD Officially Begins Full Review of its
Manufactured Housing Program
The Department of Housing and Urban Development (HUD) announced a "top-to-bottom review" of its manufactured housing rules. According to the announcement, HUD will consider whether to "adopt, revise, and interpret its manufactured housing rules based upon the public comments it receives and the recommendations of the Manufactured Housing Consensus Committee, a statutory federal advisory committee comprised of producers or retailers of manufactured housing as well as consumers, residents and public officials." 
There will be a 30-day public comment period to "identify existing or planned manufactured housing regulatory actions to assess their actual and potential compliance costs and whether those costs are justified against the backdrop of the nation's shortage of affordable housing." Not only will MHI submit comments - based on all of our prior letters and filings - but we will work to make the process simple for MHI members to submit comments as well.
A more cooperative regulatory environment for manufactured housing has been a top priority for MHI. MHI previously presented Secretary Carson and his senior leadership with a series of recommendations to improve the regulatory climate for manufactured housing at HUD, including providing examples of burdensome regulations and enforcement such as intrusive installation requirements, shifting guidelines on alternative construction, and unnecessary increases in inspections without cause. In addition, MHI sent letters to the U.S. Department of Energy, U.S. Department of Commerce, the Office of Management and Budget, and the Senate Banking Committee expressing these concerns.
MHI also worked with members of Congress to communicate to Secretary Carson about their concerns that HUD's regulation of manufactured housing is contradictory to statute. MHI waged an aggressive grassroots advocacy effort so MHI members could easily contact their Representatives and Senators to ensure they understood the negative impact of these HUD actions on consumers to access affordable manufactured housing in their congressional districts. MHI appreciates all of the Representatives and Senators who raised the importance of HUD changing course on its regulation of manufactured housing with Secretary Carson during congressional hearings and meetings.
In September, the U.S. House of Representatives unanimously passed an amendment offered by Representative Andy Barr (R-KY) to stop HUD's expansion of the regulation of manufactured housing beyond, and often contradictory to, the statute on the following actions: the regulation of garages and carports; frost free foundation requirements; and onerous new requirements for the on-site completion of construction.
As the only trade association officially registered to lobby on behalf of the manufactured housing industry in Washington, MHI will continue to work with the Administration's key housing leaders and Congress to ensure that a more cooperative regulatory environment is achieved so that regulatory initiatives do not increase costs or limit consumer choice for manufactured housing.
If you have any questions, please contact MHI's Government Affairs Department at 703-229-6208 or MHIgov@mfghome.org .
Easing CFPB Regulations to Support
´╗┐Financing for Manufactured Housing
The administration's government-wide regulatory relief efforts are starting at the CFPB, now that Mick Mulvaney has become the Acting Director of the Bureau. Last week, Mulvaney announced the launch of a review of the CFPB's policies and priorities, including a public "call for evidence," to ensure the Bureau is fulfilling "its proper and appropriate functions to best protect consumers." In the coming weeks, a series of formal requests seeking public comment will be published in the Federal Register. Comments will be solicited about CFPB's enforcement, supervision, rulemaking, market monitoring and education activities. MHI plans to submit comments, when appropriate, to these CFPB calls for evidence.
In making the announcement, Acting Director Mulvaney said: "In this New Year, and under new leadership, it is natural for the Bureau to critically examine its policies and practices to ensure they align with the Bureau's statutory mandate. Moving forward, the Bureau will consistently seek out constructive feedback and welcome ideas for improvement."
As the only trade association officially registered to lobby on behalf of the manufactured housing industry in Washington, MHI has been actively engaged with Congress and the Administration to ease federal regulations that limit access to credit for manufactured housing. In senior level meetings with White House officials and with our champions in Congress, MHI has called for reasonable modifications to CFPB's regulations to restore a robust market of manufactured housing financing. 
Moving Toward a Better Regulatory Climate
for Manufactured Housing
Last week, the Senate Banking Committee again advanced the nomination of Brian Montgomery to the full Senate. President Trump nominated Montgomery in September 2017 to serve as the Assistant Secretary for the Department of Housing and lead the Federal Housing Administration (FHA) as its Commissioner. This followed almost five months of speculation that he would be the President's nominee. While the Senate Banking Committee voted to advance his nomination to the Senate last November, since the full Senate did not hold a vote prior to adjourning for the holidays, the Committee had to revote. Montgomery previously served as the FHA Commissioner under President George W. Bush from 2005 to 2009. If confirmed, he will again oversee HUD's regulation of manufactured housing.
Montgomery has historically been an ally for manufactured housing. During his confirmation process, MHI worked with him and members of the Senate Banking Committee to highlight the changes that need to be made in HUD's regulation of manufactured housing. As a result of this outreach, Senator Tim Scott (R-SC), Chairman of the Housing Subcommittee, submitted questions to Montgomery about HUD's regulatory overreach of the manufactured housing industry. He asked Montgomery to state in writing his views about HUD's regulations governing manufactured housing and whether the current framework ensures affordability and access. Referencing President Trump's Executive Order requiring all federal agencies to re-examine their rules and reduce the regulatory burden on the American public, Montgomery stated, "We need to make sure FHA's manufactured housing rules undergo a rigorous cost-benefit analysis to ensure we are balancing important product safety considerations with affordability and access. If confirmed, you have my commitment this will be a priority."

  Final Fannie Mae and Freddie Mac Duty to Serve Plans Are an Improvement from Original Plans
  Specific Plan Commitments Reflect MHI's Continued Advocacy Efforts
On December 18, 2017, the Federal Housing Finance Agency (FHFA) released Fannie Mae and Freddie Mac's (the Enterprises) final 2018-2020 Duty to Serve (DTS) Plans, which became effective on January 1, 2018. Both Plans include common themes such as extensive market outreach, concerns about safety and soundness, and modest increases in liquidity.
The final Plans reflect several years of aggressive advocacy by MHI to educate Fannie Mae, Freddie Mac and FHFA about the fundamentals of the manufactured housing finance market and the critical need for a secondary market for chattel loans. Through detailed comment letters, participation in the Duty to Serve listening sessions and meetings with the FHFA and the Enterprises, MHI has continually called for specific targets for Fannie Mae and Freddie Mac to begin purchasing chattel loans at an early date, along with intermediate steps that are necessary to ultimately purchase and securitize chattel loans on a flow basis. MHI will continue to serve as a resource for FHFA, Fannie Mae and Freddie Mac as they move forward with implementation of their Plans, and will be closely monitoring their compliance with the purchase targets and actions outlined in the Plans. MHI has developed a detailed review of each Plan.
Setting the Record Straight Regarding Duty to Serve
In the article above this one, we reprint an update about the Final Duty to Serve (DTS) Manufactured Housing Plans for Fannie Mae and Freddie Mac. Largely as a result of extensive multi-year efforts by MHI, these Plans now include purchase of thousands of chattel loans in the next few years, for the first time in over a decade.
Unfortunately, some parties are continuing their incendiary rhetoric about the DTS rollout - attacking the integrity of the FHFA Director (the regulator of Fannie Mae and Freddie Mac), falsely claiming that FHFA, Fannie Mae, and Freddie Mac are in violation of the DTS statute, and using inflamed rhetoric about MHI, attacking by name some of our members and impugning MHI's motives with regard to the DTS.
Sadly, the main impact of several years of such attacks on the FHFA Director and Fannie Mae and Freddie Mac (the GSEs) is to undermine the reputation of the manufactured housing industry. These attacks alienate the very parties that will decide how extensively and how quickly Fannie Mae and Freddie Mac enter the chattel loan market. This approach is totally destructive and counterproductive to the objective of creating a secondary market for chattel loans. In contrast, MHI has worked constructively with FHFA and the GSEs to push them to increase their chattel commitments during the development of the DTS Plans - which they have.
Understanding that a strong, unified voice would be helpful in moving a chattel program along more quickly, early in the process MHI reached out to bring together parties interested in chattel lending. However, the very parties that continue to undermine the development of a secondary market for chattel lending because of their outrageous attacks against FHFA and the GSEs refused to join MHI on its effective effort to include chattel lending in the DTS plans. As evidenced by the commitment by both GSEs to enter the chattel space, MHI has succeeded despite those who undermined the effort with their inflammatory tactics.

Kentucky Manufactured Housing Institute | Phone: 502-223-0490 | Fax: 502-223-7305 |
Email: kmhi@kmhi.org | Visit our Website: www.kmhi.org