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Double-Digit 2023 Manufactured Home Production Slide Continues, per National Manufactured Housing Association-More Facts

"Double-Digit 2023 Manufactured Home Production Slide Continues" says the Manufactured Housing Association for Regulatory Reform (MHARR), citing IBTS data collected for HUD.

"Double-Digit 2023 Manufactured Home Production Slide Continues" says the Manufactured Housing Association for Regulatory Reform (MHARR), citing IBTS data collected for HUD.

ManufacturedHousingAssocRegulatoryReformMHARRJuly2023ManufacturedHousingProductionShipmentsTop10StatesJuly2023

ManufacturedHousingAssocRegulatoryReformMHARRJuly2023ManufacturedHousingProductionShipmentsTop10StatesJuly2023

The solution to the affordable housing crisis is hiding in plain sight. Federal, state, or local officials, and advocates could call on enforcement of an existing federal law. The Manufactured Housing Improvement Act of 2000 and its "enhanced preemption"

The solution to the affordable housing crisis is hiding in plain sight. Federal, state, or local officials, and advocates could call on enforcement of an existing federal law. The Manufactured Housing Improvement Act of 2000 and its "enhanced preemption"

Manufactured Housing Association Regulatory Reform provides updates on July 2023 and Year to Date Manufactured Housing Production-Shipment Data per IBTS for HUD

HUD must strengthen preemption enforcement...and provide...transparent guidelines for compliance. Further, HUD must respond promptly and definitively whenever localities violate" enhanced preemption."”
— William "Bill" Boor, CEO Cavco Industries MHI Vice Chairman
WASHINGTON, D.C., UNITED STATES, September 6, 2023/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 declined again in July 2023. Just-released statistics indicate that HUD Code manufacturers produced 6,134 new homes in July 2023, a 23.8% decline from the 8,050 new HUD Code homes produced in July 2022. Cumulative production for 2023 is now 50,022 homes, a 28.2% decrease from the 69,709 homes produced over the same period during 2022.

A further analysis of the official industry statistics shows that the top ten shipment states from January 2023 — with monthly, cumulative, current year (2023) and prior year (2022) shipments per category as indicated — are as follows (see shipment graphic at side).

The statistics for July 2023 produce one change from last month, moving Kentucky into 10th place.

As the official statistics demonstrate, production is not improving to any significant degree and the industry will ultimately have to confront and make hard decisions, particularly within the post-production sector where the most significant problems (i.e., exclusionary zoning and a lack of fully-competitive consumer financing) continue to persist.

"IBTS is HUD's contractor for gathering manufactured housing production and shipment data," states ManufacturedHomeProNews.com. Per their website, the Institute for Building Technology and Safety (IBTS) states that the "Institute for Building Technology and Safety (IBTS)" is the "Department of Housing and Urban Development's monitoring contractor under the Federal Manufactured Housing Program" and "has been the sole source of this data since 1976."

MHARR said that "despite the fact that Fannie Mae and Freddie Mac continue to flout Congress and the law with respect to the vast bulk of the HUD Code market, the Manufactured Housing Institute (MHI), representing the industry’s post-production sector," in recent remarks to a DTS “Listening Session,” “commended” Fannie Mae and Freddie Mac for their “efforts” regarding DTS.

Federal Housing Finance Agency (FHFA) is the primary federal regulator of Fannie Mae and Freddie Mac.

Per a document downloaded from the FHFA website on the topic of Fannie Mae's and Freddie Mac's "Duty to Serve" (DTS) manufactured housing, the FHFA said the following.

"FHFA oversees the Enterprises to ensure that they operate in a safe and sound manner and that they serve as a reliable source of liquidity for the housing finance market. Since 2008, FHFA has also served as conservator of the Enterprises."

"For the manufactured housing market, the final rule provides that, subject to FHFA approval, an Enterprise may propose a pilot to support financing of personal property, or “chattel,” loans on manufactured homes to help meet its Duty to Serve obligations."

"Eighty percent of new manufactured homes placed in 2015 were titled as chattel. Thirty four percent of these were located in manufactured housing communities, and 66 percent were located on privately-owned land."

In an interview with MHLivingNews, MHARR's President and CEO, Mark Weiss (J.D.), said that it was a "major problem" that the GSEs were 'given a pass' by MHI in remarks made by Lesli Gooch, Ph.D., CEO of the Manufactured Housing Institute (MHI). Those remarks by Gooch are heard in the video by the FHFA posted below. A document with Gooch's remarks as submitted to the FHFA are found on the MHProNews website at this link here. MHI has reportedly not responded to inquiries on the topic.

Cavco Industries CEO William "Bill" Boor said in remarks made to Congress and found at this link here said the following.

"Rather than artificially making it more difficult for us to produce quality, affordable housing we believe there are things that Congress and federal agencies can do to facilitate the availability of manufactured housing."

"Across the country, there are countless state and local zoning, planning, and development restrictions that either severely limit or outright prohibit the placement of a manufactured home," said Boor who elaborated to Congress as follows.

"There are actions that HUD can take to improve the availability of manufactured housing in jurisdictions across the country. HUD has the statutory authority to prevent local jurisdictions from excluding manufactured homes through the “Manufactured Housing Improvement Act of 2000,” which specifically states that when HUD construction and safety standards are in effect, a locality does not have authority to establish different standards. The statute explicitly states that this preemption should be “broadly and liberally construed” to avoid disparate local requirements. HUD has the authority and duty to pursue more vigorous enforcement of this provision, which clearly establishes federal supremacy for manufactured housing construction.

Due to lax enforcement of preemption by HUD, many localities use requirements that deviate from the HUD Code to accomplish an underlying objective of zoning out manufactured housing (or making it prohibitively expensive). To address this, HUD must strengthen preemption enforcement and must provide clearer, more transparent guidelines for compliance. Further, HUD must respond promptly and definitively whenever localities violate this provision. While HUD has pursued individual cases where local jurisdictions have introduced construction and safety standards that are not consistent with the HUD Code or have imposed zoning and planning requirements that exclude HUD-compliant manufactured homes, HUD must take on a much greater role in this effort. HUD has a statutory mandate to do so."

The Manufactured Housing Improvement Act (MHIA) clause cited by Boor is known as "enhanced preemption" because the original federal manufactured home standards that went into effect on June 15, 1976 also had federal preemption.

Emailed MHI remarks dated 7.14.2023 that are found at the link said: "Several Members of Congress added words of support for the industry. Representative Norman (SC-5) commented that manufactured housing is, “The most affordable housing market that there is,” and encouraged his fellow Representatives to visit a manufactured home building facility.

“If you go into a manufactured housing plant, they are doing an amazing job that site-built builders cannot do,” Norman said, and called manufactured homes, “The most affordable – the most promising housing in the country.”

More data linked below.

https://manufacturedhousingassociationregulatoryreform.org/category/manufactured-home-shipments/

https://manufacturedhousingassociationregulatoryreform.org/about-manufactured-housing-association-for-regulatory-reform-mharr-washington-d-c/

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

https://manufacturedhousingassociationregulatoryreform.org/category/mharr-issues-and-perspectives/

https://manufacturedhousingassociationregulatoryreform.org/mhpronews-qa-with-danny-ghorbani/duty-to-serve-mh/

Mark Weiss, J.D.
Manufactured Housing Association for Regulatory Reform
+1 202-783-4087
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Bill Boor and other remarks to House Hearing on Environmental, Social and Governance, including remarks on manufactured housing zoning and finance barriers.

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