Manufactured Housing Association Provides 1-2024 Production Data w/3 Main Bottlenecks Limiting Manufactured Home Sales

New Manufactured Home Production Rises YoY in January 2024 But Still Trails 2022 Manufactured Housing Results. MHARR Issues '3 Primary Bottlenecks' Brief.

WINTER HAVEN, FLORIDA, UNITED STATES, March 5, 2024 /EINPresswire.com/ -- The Manufactured Housing Association for Regulatory Reform (MHARR) reports that according to official statistics compiled on behalf of the U.S. Department of Housing and Urban Development (HUD), HUD Code manufactured housing industry year-over-year production increased in January 2024. Just-released statistics indicate that HUD Code manufacturers produced 7,475 new homes in January 2024, a 7.5% increase from the 6,951 new HUD Code homes produced in January 2023.

A further analysis of the official industry statistics shows that the top ten shipment states from January 2023 — with monthly, cumulative, current reporting year (2024) and prior year (2023) shipments per category as indicated — are: (see graphic at right).

The January 2024 statistics move Tennessee into the 10th spot on the top-ten shipment state list.

Production in January 2024, consequently, shows a year-over-year improvement as compared with January 2023, which had a whopping decrease of 23.6% from January 2022. Hopefully, this improvement will continue going forward in 2024. MHARR will continue to monitor monthly production activity and advise industry members and consumers accordingly.

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. ##

Manufactured Housing Association for Regulatory Reform (MHARR) Continues to Expose Principal Bottlenecks Suppressing Manufactured Housing

March 1, 2024

MHARR CONTINUES TO EXPOSE PRINCIPAL BOTTLENECK SUPPRESSING MANUFACTURED HOUSING

Washington, D.C., March 1, 2024 – The Manufactured Housing Association for Regulatory Reform (MHARR) has published a talking points paper (copy attached) explaining and highlighting the three main bottlenecks that are suppressing the production, marketing and sales of affordable, mainstream manufactured homes. Two of these bottlenecks have worked to thwart the expansion of the HUD Code market for decades, while the third – of more recent origin – has the potential to decimate the historical core of the industry if not stopped and fundamentally altered.

Especially after industry production statistics for 2023 showed a drop in industry production below the 100,000 home benchmark, MHARR has received numerous inquiries and requests from interested organizations and individuals – both within and outside the HUD Code industry – seeking a brief explanation of the main causes and factors that have fueled such a decline for the most affordable segment of the housing industry.

Therefore, the attached points are a brief summarization and explanation of those principal bottlenecks.

Organizations and individuals interested in the manufactured housing industry – and particularly industry state associations – can use this easy-to-read summary to highlight and address these negative and destructive factors.

MHARR will continue to expose — and advance the resolution – of these and other negative factors affecting the industry and its ability to fully meet and exceed the affordable housing needs of American families.

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.

Manufactured Housing Association for Regulatory Reform (MHARR)
1331 Pennsylvania Ave N.W., Suite 512
Washington D.C. 20004
Phone: 202/783-4087
Fax: 202/783-4075
Email: MHARRDG@AOL.COM
Website: www.manufacturedhousingassociation.org

SUMMARY OF THE THREE MAIN BOTTLENECKS SUPPRESSING MANUFACTURED HOUSING PRODUCTION, MARKETING AND SALES

1. Discriminatory and Exclusionary Zoning – Failure to Implement Enhanced Preemption of the 2000 Reform Law– Despite being the nation’s best resource for affordable homeownership, and at a time when manufacturers are building their most modern, energy-efficient homes, HUD-regulated manufactured housing is excluded from many communities and areas by discriminatory and exclusionary zoning mandates. Amendments contained in the Manufactured Housing Improvement Act of (2000 Reform Law) were designed to provide HUD the authority to federally preempt such edicts. In relevant part, 42 U.S.C. 5403(d) was amended to state that federal preemption under the Act was to be “broadly and liberally” construed. It was also amended to state that preemption applies not only to inconsistent state or local construction standards, but also more broadly to any type of state or local “requirement” that impairs the purposes of the Act and HUD superintendence of the industry. HUD, however, continues to fail to acknowledge, utilize and advance this authority to ensure the nationwide availability of manufactured homes that it regulates.

2. Restricted Availability of Competitive Consumer Financing – Failure to Implement the “Duty to Serve”– In the Housing and Economic Recovery Act of 2008, congress recognized that Fannie Mae and Freddie Mac were not adequately or properly serving consumers within three designated markets, including the mainstream HUD Code manufactured housing market. The Act, therefore, contains a “Duty to Serve” (DTS) provision which directs the Enterprises to provide secondary market and securitization support for manufactured home consumer loans. Today, some 15 years later, the GSEs still provide no DTS support whatsoever for the personal property or “chattel” loans that historically comprise 70-80% of all mainstream manufactured home consumer loans. Without such secondary market and securitization support, interest rates on manufactured home chattel loans are higher than would otherwise be the case, with consumers effectively forced into “predatory loans.” Further, the absence of DTS support for such a large portion of the market allows it to be dominated by two Berkshire Hathaway/Clayton Homes-affiliated lenders, Vanderbilt Mortgage and Finance and 21st Mortgage Corporation, to the detriment of both consumers and independent producers.

3. DOE Energy Regulation– Although the HUD Code already contained provisions regarding energy usage and efficiency in manufactured homes, Congress, in the Energy Independence and Security Act of 2007, adopted a provision which effectively transfers regulatory authority over that issue from HUD to the U.S. Department of Energy (DOE). DOE, in defiance of the enabling legislation, has used this authority to adopt draconian energy standards that if/when implemented, would significantly increase the acquisition cost of manufactured housing. These increased costs would exclude literally millions of Americans from the manufactured housing market under metrics developed by NAHB, while providing little if any life-cycle cost benefits. MHARR urged industry litigation against these standards, which is currently pending in federal court. DOE, meanwhile, has delayed the implementation date for the standards which were originally set to become effective on May 31, 2023. MHARR is also working through the HUD Manufactured Housing Consensus Committee (MHCC), established by the 2000 Reform Law, in an effort to quash these standards and force DOE to go back to the drawing board in full compliance with all applicable law. ##

About MHARR | Manufactured Housing Association for Regulatory Reform
The Manufactured Housing Association for Regulatory Reform – MHARR – is a Washington, D.C.-based national trade association representing the views and interests of independent producers of federally-regulated manufactured housing.

https://manufacturedhousingassociationregulatoryreform.org/brief-history-and-objectives-of-the-manufactured-housing-association-for-regulatory-reform-mharr/


Other Recent MHARR News

https://manufacturedhousingassociationregulatoryreform.org/manufactured-housing-consensus-committee-mhcc-votes-to-reject-destructive-proposed-doe-energy-enforcement-rule/

The statutory Manufactured Housing Consensus Committee (MHCC) following a two-day teleconference meeting, voted on February 16, 2024 – as urged by MHARR — to reject the proposed manufactured housing energy standards enforcement rule published by the U.S. Department of Energy (DOE) in the Federal Register on December 26, 2023.

MHARR, in public remarks to the Committee, called upon members to reject the proposed rule, on the ground that the proposed regulations (as well as the DOE manufactured housing energy standards themselves) were not appropriate for manufactured homes, would do little or nothing to benefit consumers, and would result in destructive price increases that would exclude large numbers of lower and moderate-income American families from the manufactured housing market and the American Dream of home ownership.

MHARR also provided Committee members with copies of its January 24, 2024 written comments to DOE on the proposed enforcement regulations, which strenuously objected to the proposed regulations on multiple bases. These comments emphasized that DOE, in a conscious and intentional effort to bypass and subvert legitimate and accurate cost-benefit analysis of the proposed manufactured housing standards – as specifically required by the Energy Independence and Security Act of 2007 and other federal law, – (while rushing to meet court deadlines that it had agreed to) failed to propose or promulgate testing, enforcement and regulatory compliance criteria, and simultaneously failed to consider the cost and cost burden of those criteria in its supposed cost-benefit assessment. Then when it published its December 26, 2023 proposed enforcement regulations, it incredulously maintained – with absolutely no supporting evidence or analysis — that those regulations would have little or no cost impact.

Significantly, the MHCC agreed that DOE’s claims with respect to the regulations and their likely costs were not supported and that the absence of specific compliance benchmarks in the DOE proposed regulations would create confusion and unnecessary cost burdens.

The MHCC’s rejection of the proposed DOE enforcement regulations, by a nearly-unanimous vote (with one abstention), follows its earlier vote to reject (on similar grounds) DOE’s “final” manufactured housing energy standards rule published on May 31, 2022. At that time, the MHCC recommended HUD adoption of less onerous energy criteria based on the unique construction and characteristics of manufactured housing and the specific needs of manufactured housing consumers. According to HUD, these recommended standards (which, again, differ substantially from the DOE “final” standards) are under review by the Office of Management and Budget (OMB) as part of the standard HUD regulatory process..."

Full press release for the above is linked below.

https://manufacturedhousingassociationregulatoryreform.org/manufactured-housing-consensus-committee-mhcc-votes-to-reject-destructive-proposed-doe-energy-enforcement-rule/

Formal MHARR comments on Pending DOE Energy Rule is linked below.

https://manufacturedhousingassociationregulatoryreform.org/manufactured-housing-association-for-regulatory-reform-mharr-comments-call-for-withdrawal-of-destructive-doe-manufactured-housing-energy-enforcement-rule/


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