The Reporter 2023
January - February Issue
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“You get to decide where your time goes.
You can either spend it moving forward,
or you can spend it putting out fires.
You decide... and if you don’t decide,
others will decide for you.”
-- Tony Morgan --
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On behalf of your Association Board of Directors, THA is very excited to announce our new, state-of-the-art, consumer-facing website launched on Tuesday, February 21st!
This new website will allow Tennessee residents to shop for a home, learn more about manufactured and modular homes, view floorplans, get price quotes, explore communities, and find lenders. Consumers can even take 3-Dimensional tours of new homes! This is an interactive site, so member listings need to contain a few details!
As a THA member, you have a free site listing allowing consumers to directly access your business. What a fantastic member benefit! However, to provide the best consumer experience, retailer listing profiles should display the makes and models of new homes offered, and communities should have full descriptions with amenities. In order for you to best utilize this new site, it is imperative that you verify your listing and provide all necessary changes. Our vendor will directly receive your requests for changes or additions (see buttons below).
In all events, ensure any leads are going to an email address that is checked daily. Please take a minute to click the appropriate button below and provide/update your free member listing. If your business is not listed, we did not have enough current information to complete your listing. Non-member companies will not be allowed to list on this website for consumer searches.
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Disclaimer! As with any new venture there will be a learning process! Launching a new site will come with tweaks and corrections! Be our eyes and ears! Check your listings and utilize the direct vendor access buttons below, for changes/additions/updates.
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Remember! This is THA’s consumer-facing website. Our existing association website remains active as your continued resource for industry news, legislative announcements, educational offerings, and general business information.
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Use these links to make changes or additions to your listing. |
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Proposed Tennessee Investments |
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When Governor Lee delivered his State of the State address recently, he detailed his proposed budget for FY2023-2024. The budget proposal totals $55.6 billion, which is a decrease from last year’s overall budget due to the ending of federal pandemic stimulus aid. However, state sales tax revenues increased by 11% over last year, allowing for a $3.1 billion increase in state spending. The Governor’s proposed initiatives include (but not limited to):
- $3.3 billion to the Transportation Modernization Fund for investments in roadway and infrastructure improvements to alleviate urban congestion
- $288.3 million for a one-time sales tax holiday on groceries from August through October
- $370 million to be used for new parks and completion of existing trails
- $125 million for teacher pay raises
- $193.5 million budget increase for the Department of Children’s Services
Other highlights from the Governor’s agenda can be found here. The budget overview can be found here and a presentation can be found here. You can also replay the event on YouTube, here. |
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Tennessee Works Act (Proposal) |
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During legislative session hearings last week, Department of Revenue Commissioner David Gerregano presented the details of Governor Lee’s Tennessee Works Act proposal. Both the presentation (a short 9 slide document) and the filed legislation are linked below.
Significantly, the legislation implements a mandatory Single Sales Factor, which will be phased in over three years. The legislation also proposes nearly $70 million in franchise and excise tax reductions.
Part of the presentation visuals show examples of how TN based businesses currently pay a higher amount of taxes, than out-of-state entities who attribute a percentage of their business to TN sales.
Feel free to pass this along to your legal or financial lawyers (or advisors), for their review.
This is a PROPOSED item and will no doubt be thoroughly debated on the floor.
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MH Discussed at Congressional Hearing |
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During the first Senate Banking Committee hearing of the 118th Congress, titled “The State of Housing 2023,” Ranking Member Tim Scott (GA) praised manufactured housing stating “the theory that modular or manufactured homes are less quality and not as safe is consistently proven not true.” He stated that both “manufactured and modular housing shows great promise in constructing decent, safe, quality housing that low-income families can afford.” Asking the witnesses to share their thoughts about this affordable homeownership option, Lance George, Director of Research and Information at the Housing Assistance Council, stated that manufactured housing is an “extremely important source of housing in rural communities but is often maligned and overlooked.” He furthered recognized that “the quality, safety, size, and amenities of these homes are indistinguishable from stick-built homes.”
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HUD Launches New Tool to Navigate Reasonable
Accommodations Requests for Assistance Animals
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HUD has launched its Assistance Animals and Fair Housing – Navigating Reasonable Accommodations Interactive Tool. The tool allows users to click through a series of questions that guide users through HUD’s January 2020 Fair Housing and Equal Opportunity Notice 2020-01. In that Notice, HUD set forth guidance on housing providers’ obligations under the Fair Housing Act to provide reasonable accommodations to housing consumers with disabilities who require the use of an assistance animal. Now, housing providers and consumers alike may use the tool to ensure compliance with the Fair Housing Act’s requirements related to reasonable accommodations for assistance animals. Some of the information that can be obtained from the tool includes the following:
- The definition of an assistance animal,
- The rules and polices that are enforceable against assistance animals versus pets,
- Circumstances in which the Fair Housing Act requires a provider to accommodate a reasonable request,
- The extent of a housing providers’ ability to make document or information requests to consumers, including best practices for this “interactive process,” and
- The scope of information consumers must provide in response to a provider’s request for information or documents.
For those interested in accessing the tool, click here.
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Fannie Mae Promotes Manufactured Housing through Video Series Spotlighting Lenders
Fannie Mae has released a series of videos that focus on lenders who are originating manufactured home loans using its mortgage products. One of these videos features the work that Land Home Financial Services is doing with developers to bring MH Advantage® eligible homes to subdivisions in California. In the video, Land Home Financial’s President and CEO, Brad Waite, who serves on MHI’s Financial Services Division Board of Governors, speaks about the work that Land Home Financial has done to support the development of communities using manufactured homes that qualify for the MH Advantage program, which MHI has trademarked as CrossMod® homes. These homes are built with features that make them indistinguishable from site-built homes. Click here to view the Fannie Mae video series.
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Manufactured Housing Shipments Increase 6.7% to 112,865 homes in 2022
A recently released Economic Report includes both shipment and production tallies for December as well as annual totals for 2022.
Cumulative shipments for 2022 totaled 112,865 homes compared with 105,775 homes for 2021, a net increase of 6.7%.
In December 2022, 6,411 new manufactured homes were shipped, a decrease of 1,587 homes or 19.8% compared to November 2022, and a decrease of 1,619 homes or 20.2% compared to December 2021. Compared with the same month last year, shipments of both single- section and multi-section homes were down, by 15% and 24.1%, respectively. As of 2022, manufactured housing accounted for roughly 11.2% of new single-family starts, up from 9.4% in 2021.
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Industry Legal Action - Last Option Available |
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On February 14th, the Manufactured Housing Institute (MHI) and the Texas Manufactured Housing Association took legal action to delay implementation of the Department of Energy’s (DOE) “Energy Conservation Standards for Manufactured Housing,” which are scheduled to take effect on May 31.
For several years, MHI has been pursuing a multipronged strategy to stop implementation of the DOE standards until the standards are properly incorporated into the HUD Code. Progress has been made with HUD and lawmakers, and we are continuing to work with DOE and HUD to find a workable and affordable solution. However, with the looming deadline and continued lack of clarity from DOE, MHI decided legal action was the only option available.
DOE set an arbitrary and unrealistic 1-year deadline and the proposed requirements are not ready for implementation on May 31. DOE failed to consult with HUD, and the standards do not align with the HUD code, contain inaccurate cost estimates, do not take current manufactured home construction methods into consideration, and fail to address testing, inspection and certification.
In addition to yesterday’s legal action, MHI is dedicated to:
- Continuing to work with regulatory agencies to delay implementation of the DOE standard until there is alignment between DOE and HUD regulations.
- Ensuring HUD’s Manufactured Housing Consensus Committee’s (MHCC) proposed changes to incorporate the DOE standards into the HUD code are finalized.
- Supporting legislation to guarantee HUD is the primary regulator for all construction standards for manufactured housing.
In an effort to ensure a consistent industry message, we ask that you please refrain from making comments to reporters on this matter and instead refer any media inquiries to Molly Boyle. Molly’s email is molly.boyle@fpmgi.com and her phone # is 202-777-3668.
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ICYMI - White House Announces New Actions
to Protect Renters
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The White House has announced new actions to protect renters and promote rental affordability, including a new Blueprint for a Renters Bill of Rights. The Blueprint lays out a set of principles to drive action by the federal government, state and local partners, and the private sector to strengthen tenant protections and encourage rental affordability. Click here to learn more.
As part of the Blueprint, the Administration has laid out five principles it plans to address: access to safe, quality, accessible, and affordable housing; clear and fair leases; enforcement of renter rights and protection from unlawful discrimination and exclusion; the right to organize without obstruction or harassment from landlords; and eviction prevention, diversion, and relief. To achieve these principles, the Administration is taking the following actions:
- The Federal Housing Finance Agency (FHFA) will launch a public process to examine proposed renter protections and anti-rent gouging measures for new federally-backed mortgages.
- The Administration will hold quarterly meetings with renters and advocates to continue the conversation on renter protections, and will launch a Resident-Centered Housing Challenge, a call to action to housing providers and other stakeholders to commit to renter protections.
- The Federal Trade Commission (FTC) and Consumer Financial Protection Bureau (CFPB) will collect information to identify unfair practices that prevent tenants from accessing or staying in housing, informing each agency’s enforcement actions. This is the first time the FTC has acted on renter protections.
- The CFPB will issue guidance and coordinate with the FTC on enforcement to ensure accurate credit reporting.
- HUD will publish a notice of proposed rulemaking to implement the 30-day-notice requirement enacted by Congress through the Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020.
While manufactured housing is not specifically referenced in the Blueprint, our national organization, MHI, and its housing coalition partners have been consistently calling on the Administration to refrain from implementing new or expanded federal obligations for private rental housing providers and instead focus on leveraging federal resources to bolster new housing supply, improve access to existing housing benefits for those renters in need and provide additional funding for federal housing support.
In numerous letters and meetings, the coalition has stated that housing providers and renters are governed by layers of statutes, case law, regulations, and private contractual agreements – all providing for specific protections and responsibilities. This includes extensive renter protections in building code, landlord and tenant, fair housing, eviction, consumer reporting and debt collection laws. MHI and its coalition partners argue that layering additional federal regulation on an already overly regulated industry will only further exacerbate housing affordability challenges, making it increasingly difficult for renters to navigate.
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HUD Releases its
Affirmatively Furthering Fair Housing Rule
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HUD Releases its Affirmatively Furthering Fair Housing Rule
HUD has now published its long-awaited Affirmatively Furthering Fair Housing (AFFH) rule (all 284 pages!). The rule essentially re-establishes more detailed compliance requirements under the Fair Housing Act that were implemented during the Obama Administration, then suspended and replaced by different requirements during the Trump Administration.
If adopted, the proposed rule would provide a permanent framework to replace a 2021 Biden Administration action interim final rule repealing the Trump Administration’s provisions and restoring certain portions of the Obama Administration’s provisions. HUD released a Fact Sheet on the proposed rule and a Quick Reference Guide.
The proposed rule would require program participants, including states, local governments, and public housing authorities that administer HUD programs, to submit an equity plan every five years, as well as annual progress evaluations showing how they are complying with Fair Housing requirements.
The industry has generally supported strong AFFH requirements in order to encourage localities to conduct local zoning and other actions in a manner that does not discriminate against the siting of manufactured homes in the local community.
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Travelers can access road and travel conditions online at TNSmartWay Traffic or by dialing 511 (or 877.244.0065 outside Tennessee) from a cellular or landline phone.
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Fannie Mae and Freddie Mac Announce Changes to GSE Pricing
The Federal Housing Finance Agency (FHFA) made two significant announcements about GSE pricing. First, FHFA announced a comprehensive pricing grid for upfront fees for Fannie Mae and Freddie Mac loans purchased after May 1st. The changes produced more granularity in pricing, generally reducing fees for low-and moderate-income borrowers with higher debt to income (DTI) ratios and higher loan to value (LTV) ratios, while raising them for higher income borrowers with more conservative underwriting ratios. This continues a trend FHFA has pursued over the last year of moving away from risk-based pricing (higher fees for higher risk) towards the opposite direction of more favorable treatment for loans to underserved and first-time home buyers. The pricing is shown here in a pricing matrix for Fannie Mae and a Fact Sheet for Freddie Mac.
Also, FHFA Director Thompson released a statement announcing a reduction in the upfront fee for commingled Fannie Mae or Freddie Mac securities to 9.375 basis points, effective April 1, 2023. This reduction came in response to industry comments critical of higher fees for situations in which Fannie Mae securitizes Freddie Mac loans and vice versa, which commenters argued would discourage further development of a Unified Mortgage-Backed Securities (UMBS) market for Fannie and Freddie mortgage loans.
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FHA Extends Flexibility for Appraising CrossMod® Homes
The Federal Housing Administration (FHA) extended appraisal flexibility for CrossMod® manufactured homes, under which an appraiser “may include site-built homes” when there are not sufficient CrossMod® comparables available.
FHA stipulated that the appraiser “must provide detailed justification to support the Appraiser’s selection of comparable properties and the adjustments for dissimilarities to the subject properties.” This extends changes FHA made to CrossMod® appraisals in December 2020 through FHA Mortgagee letter 2020-48, which expired at the end of 2022, but are reinstated through this incorporation into the HUD Handbook.
The industry continues to advocate for further changes to the FHA appraisal requirements to require that appraisers "shall" use site-built homes when there are not sufficient CrossMod® comparable properties, with appropriate adjustments.
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Program Requirements for Zero Energy Ready Home Tax Credit Released |
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The Department of Energy released its Zero Energy Ready Home (ZERH) program requirements necessary for manufacturers to receive a $5,000 tax credit under the Inflation Reduction Act of 2022’s amendments to Internal Revenue Code Section 45L. To manufacture homes recognized as meeting ZERH requirements, a manufacturer must register as a ZERH Manufactured Home Plant Partner and complete a certification process through a Quality Assurance Provider recognized by the Department of Energy or Environmental Protection Agency. To meet the ZERH requirements, a new manufactured home must meet Energy Star Version 3 requirements and additional requirements which can be found by clicking here.
The additional requirements are broken into three categories:
- Mandatory Efficiency Requirements – prescriptive- or performance-based requisite features for envelope and glazing (based on Climate Zone), thermostat and ductwork, and marriage line seal and duct installation.
- Additional Efficiency Requirements – a series of optional features with point values that must combine to meet total values that are increased from the values in Energy Star Version 3.
- Mandatory Technical Requirements – prescriptive factory construction methods that must be documented and verified through DAPIAs and IPIAs.
The ZERH program is a pilot program, so the requirements were issued without the opportunity for review or public comment. The Department of Energy states that it will devote substantial resources to studying manufactured home methods, innovations, and techniques and will engage in a public comment process beginning in 2023 for future versions of the ZERH program. The ZERH program is in addition to the current 45L New Energy Efficient Home Tax Credit for manufactured homes which is still available for manufacturers. For homes completed by December 31, 2022, the existing 45L tax credit is retroactively extended in its current form (a $2,000 credit). For homes completed after December 31, 2022, but before December 31, 2032, the 45L tax credit has been modified and will apply to manufactured homes that meet the qualifications of Energy Star Version 3 (a $2,500 credit).
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Treasury Issues FAQs to Consumers about Energy Efficiency Home Improvement Tax Credits
The Department of Treasury and the Internal Revenue Service (IRS), in coordination with the Department of Energy, have released FAQs to help families, homeowners, and renters lower energy costs by using new and expanded tax credits, secured under the Inflation Reduction Act, to invest in energy efficiency upgrades to homes.
The FAQs provide detailed information on how families can access several tax credits for making energy efficiency upgrades to their homes over the next ten years. These FAQs are part of the Administration’s ongoing efforts to educate the public about how they can benefit from the investments in the Inflation Reduction Act.
Click here to view the FAQs and click here for more information about other incentives for the private sector, non-profit organizations, homeowners, and communities.
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Industry Appeals to the Associated Press to Properly Define “Manufactured Housing”
To support factual news reporting on manufactured housing, the Manufactured Housing Institute (MHI) requested state associations join them in requesting the Associated Press (AP) include the terms manufactured homes, modular homes, off-site built homes, CrossMod® homes, mobile homes, and trailers in the AP Stylebook.
The AP Stylebook is the gold standard reference for journalists and editors, providing impartial, consistent guidelines that lead to uniformity and common understanding in news stories.
Journalists refer to the AP Stylebook for guidance on using the correct language and terms when writing news stories, but the guide does not include any language related to manufactured housing.
Inclusion of the correct terminology is one step the industry is undertaking as we work to change the negative portrayal of manufactured housing in the media.
THA provided a submission to the AP on this issue.
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News articles from around the country! |
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There's a push to change zoning laws to create more affordable housing, NPR
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$25M in federal funds headed to mobile home parks across Vermont, WPTV
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Mobile home park request rebuffed, The Brunswick News
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New zoning changes seek to protect residents of mobile homes, Fox 11/41
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City drains housing reserve to help residents buy mobile home park, Missoula Current
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Rep. Barry Moore leads Alabama delegation protesting energy mandates, The Messenger
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Tax incentives for mobile home park owners who sell to nonprofits proposed in Virginia Senate, Cardinal News
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Lawmakers not aware of bills regarding lot rents, Yahoo! News
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Unaffordable Housing: Mobile home residents fear losing their homes, pleading 'I can't start all over again', Spectrum News 1
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Not all Santa Rosa mobile home residents are benefiting from new rent control law, The Press Democrat
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Riverdale mobile home park tenants offered money to help with move, Standard-Examiner
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Commissioners vote to allow mobile home expansion near 100-year-old farm, Yahoo News
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The Shockingly Affordable Home This Couple Risked Buying – Should You Get One, Too?, Realtor.com
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How manufactured housing communities are grappling with flood risk, VTDigger
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THA Annual Meeting!
August 21 - 23, 2023
Make your plans now!
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Gaylord Opryland and Resort & Convention Center
2800 Opryland Drive
Nashville, TN 37214
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Annually, we encourage our members to support Tennessee's legislative efforts, by contributing to the Political Action Committee campaign. Click on the Donate Button above, to download a contribution form. You may also review the PAC webpage, for more information!
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Tennessee MH Education Available Everyday! |
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Pick your course. Pay online. Access Online.
Print your certificate of completion right from your dashboard!
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Discounts are available for THA member companies!
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