November 20, 2020
Messages from THA
"The day you complete any project is only the beginning of a lifetime of opportunity to serve your customer." - Glen W. Canter (1948)
It is not happy people
who are thankful,
it is thankful people
who are happy!
The THA Board of Directors and staff wish you a Happy Thanksgiving! May we all be thankful for what we have!
The offices of the Association will be closed next Thursday and Friday (November 26th and 27th), in observance of Thanksgiving.
!!! Educational Deadlines !!!
Retailer/Installer Licensing
If you need an initial licensing educational class to pursue a new license or a certification, or if you need to complete your continuing education for 2020 renewals, online modules/videos are still available. However, please take note of the following yearend deadlines:

  • THA will cease to process online 2020 class registrations on 11/24/2020.

  • Initial Licensing: You must successfully complete your curriculum and have an exam date scheduled for completion, prior to 12/11/2020. (The Tennessee State exam given by a contracted 3rd party testing company, will not schedule testing appointments after 12/11/2020.)

  • Continuing Education: You must successfully complete your curriculum by 12/11/2020.

  • The State of Tennessee, Commerce & Insurance, will accept license applications or renewal packages through 12/18/2020. The last two weeks of December are set aside for processing, recording and reporting.

  • No educational registrations will be processed after November 24th.
  • THA 2020 course curriculum and testing links will be removed by the end of the business day on December 11th.
  • All testing with the 3rd party must be completed by December 11th.
  • The regulatory department must receive your initial license or renewal package by December 18th.

2021 educational schedules are not yet available, and the State of Tennessee will determine the delivery method of these classes (i.e. either in-person reduced class sizes, or online delivery of education).

(See class links for registration and processing, further below under the RESOURCES SECTION.)

Tennessee Modular Homes Rule Making Hearing
Held November 19, 2020
A Modular rulemaking hearing was held yesterday morning, on November 19, 2020, with a final 2-week comment period to follow, which will end on close of business day, December 3, 2020.

The Modular Rule revision has been in process for the last year, and many have already commented.

However, the State encourages any others who may be interested in the final redline draft of proposed changes to provide comments, whether they be positive or negative. Comments to these rules ensure the Legislature has viable feedback from interested parties to better understand whether the content of the proposed rules meets industry trends and standards.
The State also welcomes any questions you may have about the proposed rules. Note that questions are not a portion of the public record, but comments are included in the official record. Feel free to email Director Hightower directly with questions or comments.

FHFA 2021 Multifamily Loan Purchase Caps Include Tenant Pad Lease Protections for Manufactured Housing Communities to Qualify as Affordable Housing
The Federal Housing Finance Agency (FHFA), which regulates Fannie Mae and Freddie Mac (the Enterprises), announced Tuesday its 2021 multifamily loan purchase caps, including a requirement that loans to manufactured housing communities must have tenant pad lease protections to qualify under the affordable housing component of the caps. To ensure a strong focus on affordable housing and traditionally underserved markets, the 2021 caps require at least fifty percent of the Enterprises’ multifamily loan business must be mission-driven, affordable housing. To be counted as mission-driven, affordable housing, manufactured housing communities must either be resident/government/nonprofit-owned or must have tenant pad lease protections as outlined in the Duty to Serve (DTS) regulation.
Volume caps for Fannie Mae and Freddie Mac have been set at $70 billion for each Enterprise with respect to their purchase of multifamily loans in calendar year 2021. This is a modest proportionate reduction compared to the prior year cap, which was $100 million during the longer five-quarter period running from 4th quarter 2019 through 4th quarter 2020. Unlike several years ago, there are no exclusions from this hard volume cap for multifamily GSE loans.

HUD Increases Minimum Per Section Compensation
from $2.50 to $14, for Participating States
The Department of Housing and Urban Development recently published a final rule in the Federal Register which will take effect on December 14th. This rule increases payments to states participating as State Administrative Agencies in the HUD’s manufactured housing program.

Participating and compliant State Administrative Agencies in 33 states, which carry out manufactured housing oversight programs, will see the minimum per home section federal payment increase from $2.50 to $14.

The minimum $9 payment per placement of a home to participating agencies will remain.
Subcommittee Reviews Proposals to Update the HUD Code
The MHCC has begun a series of Subcommittee meetings to review proposed changes for the 2020-2021 HUD Code development cycle.

Kicking things off, the MHCC’s Structure and Design Subcommittee met last week to review Log Items that were assigned to the group. During its day-long meeting, the MHCC’s Structure and Design Subcommittee held vigorous discussions about proposals to amend the HUD Code, including revising the snow roof load map, bathroom privacy locks, carbon monoxide detectors, and placement of data plates.

Prior to the meeting, the Manufactured Housing Institute (MHI) and members of its Technical Activities Committee, carefully reviewed each proposed change and provided a detailed recommendation for how the Subcommittee should respond. MHI was a strong presence throughout the Subcommittee meeting reiterating its concerns and providing guidance.

At the end of the day, the Subcommittee had reviewed all nine Log Items on its agenda and the group’s recommendations will now go before the MHCC for consideration. 
Have You Conducted Your Annual Queries in the Clearinghouse?
Per § 382.701, employers of CDL drivers must conduct a query in the Clearinghouse at least once per year for each CDL driver they employ, and before hiring a prospective driver. The annual query requirement is tracked on a rolling 12-month basis. Download the Queries and Consent Requests Factsheet to learn more.

Employers of CDL drivers must purchase a query plan to meet this regulatory requirement.

Registered employers may purchase query plans only on the FMCSA Clearinghouse website. Consortia/third-party administrators (C/TPAs) may not purchase query plans on behalf of an employer. A separate query plan must be purchased for each individual company.

Next Steps:

The TN State of Emergency related to the ongoing pandemic, currently extends to December 29, 2020. (Executive Order 67)
Tennessee Governor Lee
Statewide Press Conference

Recorded viewing may be accessed HERE.
During Governor Lee's press conference on Tuesday (11/17/20), surrounding the COVID-19 pandemic, the following updates were provided:

  • Tennessee is on track to set a new record of positive COVID-19 cases, surpassing the record-breaking numbers experienced in October.
  • Pfizer has selected Tennessee as 1 of 4 states to partner with, for their pilot vaccine distribution program. Dr. Lisa Piercey, Commissioner of the Tennessee Department of Health, credited the robust vaccine proposal the department submitted, as a driving factor in Pfizer's decision.
  • Additionally, Dr. Piercey stated the Department of Health continues to place final touches on preparing for vaccine distribution. She indicated the Department will be ready to distribute vaccines as early as December 1st to Tennesseans considered top priority, which includes health care employees and first responders. 
  • The Department of Health has worked with its lab partners to offer a COVID-19 testing day on Monday, November 23rd. Free tests will be available in each of Tennessee's 95 counties, and the Department hopes to return the test results to the patient within 24 hours.

Visit the TN Department of Health and Tennessee's Unified Command Group website for statewide COVID-19 data.

The THA 2020
Political Action Committee (PAC) Campaign

We have received $24,147 towards our $35,000 goal. 68.9%!
Please support the THA-PAC, to allow THA's continuance of educating key lawmakers on the importance of our industry, while also providing general counsel in ways of promoting manufactured homes as a viable option for addressing the affordable housing crisis.
Tennessee accepts corporate, personal and LLC contributions. Your contribution is critical! 
MHI In Action
MHI Submits Recommendations to the MHCC Regulatory Enforcement Subcommittee

MHI has submitted comments in advance of a Manufactured Housing Consensus Committee (MHCC) Regulatory Enforcement Subcommittee meeting.

The MHCC Regulatory Enforcement Subcommittee will be reviewing three proposals focused on updating the HUD Code. Proposals include moving to the most recent editions of the NFPA 1192 Standard on Recreation Vehicles and NFPA 501A Standard for Fires Safety Criteria for Manufactured Home Installations, Sites, and Communities. They also include proposals for repealing various sections of the HUD Code related to the manufactured home installation program in HUD-Administered States. As previously done for the MHCC Structure and Design Subcommittee meeting, MHI and members of its Technical Activities Committee, carefully reviewed each proposed change and provided a detailed recommendation for how the Subcommittee should respond to those items on its agenda.

Election 2020: Housing Policy Outlook Under a Biden Administration

A Biden presidency will result in significant turnover in senior leadership positions at various agencies as “political appointees” leave with the outgoing administration. MHI has developed strong relationships with key career staff members at these agencies, who will remain in place with a new administration, to ensure a smooth transition in consideration of our manufactured housing priorities.
MHI Urges Congress to Include Rental Assistance
for Housing Providers in COVID Relief Package

As deliberations in Congress are ongoing about another COVID relief package, MHI and its coalition of national housing trade groups are continuing to tell Congress that a multi-pronged response is needed to ensure that housing providers will be able to cover their debt, payroll, property taxes and increased operating expenses, while preserving housing stability for millions of Americans. Arguing that the CDC eviction moratorium was issued without rental assistance and sets up an untenable situation for all parties involved, the coalition continues to urge Congress to include in the next COVID relief package the following: utilize alternatives to eviction moratoriums that provide assistance to residents, property owners and managers alike, renew federal unemployment pandemic benefits and create a strong emergency rental assistance program for renters, and expand the Small Business Administration’s (SBA) Paycheck Protection Program (PPP), to include manufactured home communities and all multifamily businesses.

Lend your voice to Congress! See the Action Alert below!
Tell Congress to...
Act on the CDC's Eviction Moratorium
Letters have already been prepared! Just enter your name, address, etc in the form provided at the link below, and press submit!
--YOUR ASK -- Pass Targeted Rental Assistance Funding

So far, more than 1,500 communications have been sent to Congress.
What We Are Asking?
Ask Congress to provide rental assistance funding to stabilize the rental housing sector. 
The halt on evictions imposed by the CDC without funding for rental assistance puts the stability of the rental housing sector in danger.
Congress’ next COVID-19 relief package must include funding for rental assistance to keep residents who have a COVID-related hardship in their homes, and to support housing providers who are already stretched thin providing necessary assistance and services for residents.

Without funding, the very people the halt on evictions aims to help will be harmed by making it impossible for housing providers to meet their financial obligations and continue to provide shelter to their residents. 
Free Webinars
Powered/Sponsored by:
2020 Webinar Series: Embracing Change
Upcoming Free Webinar
Fannie Mae and Freddie Mac
Thursday, December 3, 2020, 2 PM ET

Thursday, December 17, 2020, 2 PM ET - Development
by: Lenny Kopowski and Leo Poggione
January 20 - 22, 2021
For more information, contact Show Coordinator Dennis J. Hill at (770) 587-3350.
Save the Date: March 15 - 18, 2021
IP Casino and Hotel, Biloxi, MS


Come Experience the Mississippi Gulf Coast!

The THA Annual Member's Meeting & 65th Anniversary Celebration has been postponed until June 27 - 29, 2021.
Initial Licensing/Certification Retailer/Installer Education
available online for Tennessee!

DEADLINES APPROACHING! No class registrations will be processed after November 24th and all testing links will be removed by the end of the business day on December 11th.

THA provides the educational access required to apply for or renew a license.
THA DOES NOT process, grant, revoke or suspend licenses. That process resides within the Department of Commerce & Insurance, State Fire Marshal's Office, the Manufactured Housing Division.
Initial Licensing/Certification
Year End Deadlines! You must successfully pass all of the online course modules, as well as the Tennessee State exam given by a contracted 3rd party testing company, by December 11th, 2020, in order to obtain your license.
05 Hour Continuing Education
Year End Deadlines! You must complete the 2020 Continuing Education online course by December 11th, 2020, and have your paperwork submitted to the State by December 18th in order to renew your license.