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As we embark upon 2024, MHI would like to celebrate some of the manufactured home industry’s advocacy highlights from 2023 that we will build upon in the year ahead.

 

Elevating Manufactured Housing within Congress and the Administration

HUD elevated the Office of Manufactured Housing Programs (OMHP) to an independent office reporting directly to the Assistant Secretary for Housing and Federal Housing Commissioner.

During the “MHI on the Hill” event, MHI members met with dozens of members of Congress and Administration officials from across the federal government and HUD Secretary Marcia L. Fudge visited a home exhibited by Cavco and UMH Communities. As a result of MHI on the Hill, MHI elevated the profile of manufactured housing and made progress on all four of MHI’s legislative “asks”:

  • HUD should be the regulator for all manufactured housing construction standards;
  • FHA should do more to support manufactured housing financing;
  • Federal Policies Should Support Development of New and Preservation of Existing Land-Lease Communities; and
  • Congress Should Remove Permanent Chassis Requirement.

MHI Chairman and President and Chief Executive Officer, Cavco Industries, Inc. Bill Boor testified in a Housing and Insurance Subcommittee Hearing entitled, “How Mandates Like ESG Distort Markets and Drive Up Costs for Insurance and Housing.”

Additionally, HUD announced expanded Community Development Block Grant (CDBG) eligibility for manufactured homes.

Zoning Wins for the Inclusion of Manufactured Housing

MHI is working to help state associations and member companies overcome zoning hurdles, such as when the Tipton (Indiana) Planning Commission proposed an ordinance that prohibited “mobile homes” as accessory dwelling units (ADUs). MHI supported the Indiana Manufactured Housing Association-Recreation Vehicle Indiana Council in communicating with the city council. The Tipton Planning Commission amended the proposed ordinance to include manufactured home ADUs because of the letter.

Combatting Legislation That Is Harmful to Communities

MHI supports state associations battling legislation detrimental to manufactured home communities. MHI helped the Connecticut Manufactured Housing Association successfully lobby for a change to their right of first refusal law to create a carve-out that would allow the sale of a property to be through portfolio sales, stock transfers and other means.

MHI continues to make progress with policymakers to do the following to help manufactured home communities:

  • Ensure federal affordable housing policies encourage capital investment into land-lease communities to build, update and preserve land-lease communities, through initiatives such as creating more flexible investment incentives under the Opportunity Zone statute.
  • Ensure HUD programs allow all eligible community owners to obtain grants and financing to preserve and revitalize manufactured housing communities, including through the newly created Preservation and Reinvestment Initiative for Community Enhancement (PRICE) grant program.
  • Ensure Fannie Mae and Freddie Mac expand their commitment to financing manufactured housing communities.

Energy Efficiency Standards for Manufactured Housing

A major priority for MHI in 2023 was to stop the June implementation of the Department of Energy’s (DOE) rule about energy efficiency standards for manufactured housing and instead, ensure that HUD stays the primary regulator for manufactured home construction standards. Through advocacy on Capitol Hill and with the Administration, and by filing federal litigation, in May the DOE announced that it would delay the implementation date as it worked through a process for compliance and enforcement of its standard.

MHI continues to advocate to ensure HUD is our primary regulator and the House Energy and Commerce Committee passed the “Affordable HOMES Act” (H.R. 6421) to repeal Section 413 of the law that gives DOE authority over manufactured home construction code and would ensure that the DOE’s final rule has no force or effect.

The House Financial Services Committee’s Housing Subcommittee, which oversees HUD, held a legislative hearing on H.R. 3327, a bipartisan bill introduced by Representatives Kustoff (R-TN) and Sewell (D-AL), that clarifies and reaffirms the longstanding role of HUD as the sole regulator of federal manufactured housing construction standards. Rep. Norman (SC-5) observed that the DOE standards were developed by bureaucrats without the proper understanding of factory-built housing or the potential impact on housing affordability. The House of Representatives subsequently passed an amendment by Rep. Norman prohibiting DOE funds from being used to implement the manufactured housing rule during House consideration of the DOE spending bill for Fiscal Year 2024. No member spoke in opposition to the amendment, and it was one of only a few amendments passed by a voice vote.

MHI will build upon this momentum to once and for all fix the process of setting building standards for the construction of manufactured homes, ensuring that our primary regulator is HUD as it has been for 50 years.

Federal Financing Programs and Regulations

During a session at MHI’s National Communities Council Fall Leadership Forum, Assistant Secretary for Housing and Federal Housing Commissioner of HUD Julia Gordon announced updated appraisal requirements for the valuation of manufactured homes certified under Fannie Mae’s MH Advantage™ and Freddie Mac’s CHOICEHome® programs. FHA’s updated policy for the valuation of manufactured homes certified under the Fannie Mae and Freddie Mac programs, also known as CrossMods®, requires appraisers to use the most appropriate site-built-home comparable sales when there are less than two comparable sales of these certified manufactured homes available. These updates align FHA appraisal requirements with those of Fannie Mae and Freddie Mac and will improve the valuation of these homes for borrowers seeking FHA-insured mortgages.

The Federal Housing Administration (FHA) published its annual report to Congress describing the work of its Single Family mortgage insurance programs in FY 2023 and the performance of the FHA Mutual Mortgage Insurance Fund (MMI Fund) which supports that work. In FY 2023, the percentage of FHA endorsements for mortgages used to finance manufactured homes (4.33%) nearly doubled the rate for the rest of the market (2.39%). The report also noted that FHA supports manufactured housing titled as personal property through its Title I Manufactured Home Loan Program and will soon propose changes to that product to encourage its use.

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