George Allen / EducateMHC Blog Mobile Home & Land Lease Community Advocate & Expert

January 28, 2017

It’s All About FHFA Listening Sessions re GSEs & DTS – and more!

Filed under: Uncategorized — George Allen @ 5:34 am

Blog # 431 Copyright @ 29 January 2017;

Perspective. ‘Land lease communities, previously manufactured home communities, & ‘mobile home parks’, comprise the real estate component of manufactured housing.’

This blog posting is the sole national advocate voice, official ombudsman & historian research report & online communication media, for North American LLCommunities!

To input this blog &/or affiliate with Community Owners (7 Pat) Business Alliance, a.k.a. COBA7, use Official MHIndustry HOTLINE: (:877) MFD-HSNG or 633-4764

COBA7 Motto: ‘U Support US & WE Serve U!’ Goal of its’ print/online media = to
‘Not only inform & opine, but transform & improve MHBusiness model performance1’

INTRODUCTION: What a week it was for COBA7! Distributing the 28th annual ALLEN REPORT; writing & publishing the most detailed historical retrospective to date, describing 65 years of manufactured housing chattel capital history; spending a day in Chicago ‘telling it like it is’ at FHFA’s first Listening Session; laying plans for the 26th annual Networking Roundtable this Fall; and, handing out more COBA7 Challenge Coins to affiliates!


Land Lease Community Owners Dominate FHFA Listening Session in Chicago on 25 January 2017

FLASH NEWS. “Of the 20+/- manufactured housing representatives a the first FHFA Listening Session, 13 were allocated time to address the 50+/- person audience. Of those 13 businessmen and women, five were owners of land lease communities – making the real estate asset class the best represented segment of the industry!” Quoted from the February issue of the Allen CONFIDENTIAL! business newsletter.

All three national advocates for manufactured housing were present at this Chicago event: MHARR, MHI, and COBA7.

It’s anticipated a Special Edition of TAC! will be published after the Federal Housing Finance Agency publicizes session proceedings. TAC! has promised to enclose copies of all handout material distributed at the Listening Session, including the Historical Retrospective published last Sunday, as a blog posting, at the website. Have you read it? If not, suggest you go there and do so. 65 years of history!

And finally; COBA7 has already responded to FHFA’s request for public input relative to chattel financing of manufactured homes sited in land lease communities. If you’d like a copy of the eight page FHFA booklet describing parameters for said input, phone the Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764 & request it.

Deadline for input, labeled as ‘Chattel Pilot RFI’ is 17 February 2017 via email, webpage, or USPS. What an incredible opportunity for LLCommunity owners/operators, large & small, nationwide – YOU – to influence our realty asset class’ present day and future financing of new and resale manufactured homes!

No longer should you feel ‘left out’ because a national advocacy entity neglected to inform you of opportunities to share your expertise, knowledge, experience and or opinions about manufactured housing & land lease community matters! COBA7 will keep YOU informed!


Historical Perspective to FHFA’s DTS Rulemaking Challenge to Fannie Mae & Freddie Mac

Here’s what land lease community owners and MH businessmen & women had to say about last week’s blog posting, on this very subject:

“Excellent treatment of the MH financing mistakes. The naïveté’ and greed of Wall Street & MHIindustry – pushed home sales and financing through the stratosphere during the 1990s. MHRetailers, with lenders turning a blind eye, ‘created’ down payments, phantom income, and credit for below-marginal buyers/borrowers all too eager to buy what they clearly couldn’t afford. What was later termed ‘mortgage fraud’ was rampant. We killed the goose that laid the golden egg – THEN along came the S.,A.F.E. & Dodd-Frank Acts.

Thank you Otto Wantuck. I too mistook the ’76 HUD Code as the sole cause of the dramatic downturn in MH production, when the real culprit was apparently the first round of chattel lending abuses 20 years prior to the downturn of the 90s. Hello; another 20 year anniversary isn’t far away – is it any wonder that powers- that-be are reluctant to repeal the S.A.F.E. & Dodd-Frank Acts?

I also went back and read blog # 284, ‘UPSIDE DOWN in a Mobilehome Park’ (2/13/14). Should be a mandatory re-read by everyone in the MHIndustry every five to 10 years!”

And then this input from the Midwest:

“Great history lesson, and a very pointed commentary on the importance of GOOD financing. It will also teach us that ‘price/value’ was another hugely important factor George, and we will see that reflected in increased quality/longevity and stability in land lease community treatment of rent and maintenance issues. We are in line now, for the updraft to find us.”

Finally, this from the left coast:

Nice recap of the history of Chattel. One might wonder if Fannie & Freddie ‘s (anticipated) expansionary policies into chattel lending might have an alternative motive. (Specifically), One would wonder if it is a beginning step in the process for local development for affordable land lease communities. Government could offer affordable housing solutions with GSE approved financing. And end around existing LLCommunity owners who have old communities needing new replacement units and infrastructure improvement. Just an observation….” (lightly edited. GFA)

Makes you stop and think doesn’t it?


Looking for 20 Topics & Speakers for 26th annual Networking Roundtable, 6-8 September 2017.

Wow! Is it that time of year again – already? Guess so. Well, if you have one or more ‘hot topics’ you’d like to see covered at this year’s Networking Roundtable, let us know ASAP via (317) 346-7156. Also, if you’d like to be considered as a primary presenter at this affair, let us know that as well, along with one or more topics about which you’re the ‘duty expert’, so to speak.


January 21, 2017

65 Year Historical Perspective to FHFA’s DTS Rulemaking Challenge to Fannie Mae & Freddie Mac

Filed under: Uncategorized — George Allen @ 12:37 pm

Blog # 430 Copyright @ 22 January 2017;

Perspective. ‘Land-lease communities, previously manufactured home communities, & ‘mobile home parks’, comprise the real estate component of manufactured housing.’

This blog posting is the sole national advocate voice, official ombudsman & historian, research report & online communication media, for North American LLCommunities!

To input this blog &/or affiliate with Community Owners (7 Part) Business Alliance, a.k.a. COBA7, use Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764

COBA7 Motto: ‘U Support US & WE Serve U!’ Goal of its’ print/online media = to “Not only inform & opine, but transform & improve MHBusiness model performance!”


This blog posting was prepared specifically and especially for the Federal Housing Finance Agency Listening Sessions. It is a 65 year look back at manufactured housing finance cycles, plus a challenge to look forward, and collectively decide how to restore reasonable access to chattel capital for financing of new and resale manufactured housing in land lease communities nationwide.

Historical Perspective to FHFA’s Duty to Serve (DTS’) Rulemaking Challenge to Fannie Mae & Freddie Mac

“If you dwell in the past you lose an eye. If you forget the past you lose both eyes.”
An ancient eastern proverb *1

“Use this look back into our 65 year MH$ past, to ensure 20/20 vision going forward!”
George Allen, CPM & MHM

Folk new to manufactured housing and land lease community business models may hold the naive view this industry and realty asset class’ loss of easy access to chattel capital, from independent third party lenders – between the turn of the 21st Century and now – is simply a one time hiatus. Not so. We’ve gone through similar cycles in years past.

(More than a dozen of the following paragraphs, republished two years ago as lead feature in the January 2015 issue of the Allen Letter professional journal, were in turn quoted from the June 2000 issue (pages 45-48) of the defunct Manufactured Home Merchandiser magazine, in an article titled: ‘Looking Back at 50 Years of Manufactured Housing Financing’ by Otto Wantuck, former owner of San Diego-based Amcorp Financial Services.)

Mr. Wontuck’s reason for penning his half century retrospective description of manufactured housing finance cycles? In his words, “…help us do a better job and avoid same ‘pitfalls’ in the future.”

Otto. “The year is 1950. It’s summer in Tulsa, OK., and gasoline is selling for 37 cents a gallon. The young couple (is) from Knobnoster, Mississippi, where they bought a trailer from Sipes Trailer Sales, the local Spartan retailer. They are at the factory to pick up their new home, a beautiful, shiny, silver 8X20 Spartan Mansion aluminum trailer.”

Their Spartan Mansion’s “Sale price, including title and tax = $4,200. Down payment paid to dealer = $840. Balance owing = $3,360. Physical damage insurance for three years = $140. Credit life insurance = $60. Amount financed = $3,560. Finance charge (five percent add-on) = $534. Total note balance = $4,094.”

“The couple will be making 36 payments of $113.74 to pay off the loan. The true interest rate on the loan is 9.2 percent in simple interest. The cost to the lender is about 3.5 percent, resulting in a gross profit, before an administrative cost of almost 60 percent of the finance charges. A very profitable financing operation, indeed.”

Such was the reality of that time period, 65 years ago.

Moving ahead ten years, Otto again: “As of the mid-1960s, banks and savings & loans were unregulated. In their race for deposits, they turned to manufactured housing loans for higher yields. However, they lacked the expertise in originating these consumer installment loans. Entrepreneurs, many coming from manufactured housing finance companies, formed ‘service companies’…becoming the loan arm of thousands of federal and state – insured banks and savings & loans.”

Then came the Crash of the 1970s. “By 1973, annual sales volume (i.e. new ‘mobile home shipments’) reached 580,000 – an all time high never to be seen again. However, there was a flaw in the industry growth. The marriage of service companies, financial institutions, and credit (repossession loss insurance) companies did not incorporate the basic checks and balances needed in the world of lending.”

“Competition for loan volume reached a ‘fever pitch’. Prudent lending practices disappeared in the feeding frenzy for profits by service companies. Banks, and especially S&Ls, were screaming for more loan business, since they needed the higher yields to support their marketing of high yield deposits for their customers in CDs and savings accounts.”

“The credit (repossession loss) insurance companies, at great risk, were generally unaware of their extreme exposure to uncontrolled loss. When they finally realized their mistake, it was too late.”

“The crash came in 1974, as losses skyrocketed. Credit (repossession loss) insurance companies pulled out of the business and annual sales of home plummeted to 338,000 units (shipped).”

“Repossessions were pouring in due to bad credit standards and many lenders withdrew from the business never to return.”

Two positive events occurred during the late 1970s; Otto continuing…

• The FHA & VA offered government-insured mobile home loans, and the Government National Mortgage Association offered a mortgage-backed securities program, that eventually provided “…billions of dollars to fuel the industry’s growth in the 1990s.”

• “A national construction standard known as ANSI 119.1 was imposed on the mobile home industry in 1976. (Now the HUD-Code)…greatly increasing the credibility of the industry with lenders, investors, and the general public.”

Interestingly, the debut of the HUD-Code (federally preemptive national building code) is most often cited as ‘the reason’ for the following 20 years fall-off in new home shipment volume, when ‘blame’ should be shared, at least equally, by chattel capital lenders of the time.

Economic Factors of the 1980s & 1990s

Otto again. “The borrow rates for manufactured home loans were three percent higher and could be attributed to higher costs of servicing and default losses.”

“Loan terms in 1980 were up to 20 years and rose to 30 years by 1995. This resulted in no equity lending on most loans for several years, and down payments dropped from 10 to five percent, a grave error.”

“…in 1998 & 1999, delinquency increased from 3.5 to five percent for most lenders, indicating problems. Default losses, including expenses, rose from 30 percent in the ’80s, to 45 to 50 percent in the late ’90s.”

“Pressure (however) increased among lenders to gain or hold on to market share. Loan credit quality deteriorated as the competition heated up. Eventually, in the late ’90s, many of these lenders withdrew from manufactured housing lending, but the damage was already done.”

Summary observation from Otto Wantuck, writing in mid-2000: “I have seen all of these problems before, but I have never seen all of them occur at the same time!” And to this he added this hopeful note: “The days of great ups and downs
in the lending industry are coming to an end.” Alas, probably more of an ‘end’
than even he realized at the time.

(For an anecdotal look at how these tumultuous financial times affected homebuyer/site
lessees, read ‘Upside Down in a Mobile Home Park!’ A fictional tale describing the real world consequences of 1) borrower qualification compromise, 2) questionable down payments, 3) bogus credit and 4) employment histories, plus 5) free-wheeling adjustable rate mortgages, even 6) ‘free site rent for a year’ in (then) manufactured home communities with rental homesite to fill. For a FREE reprint, phone COBA7’s Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764.)

How did manufactured housing industry leaders, at the time, view these matters? Now retired, Gub Mix, a former association executive for several western states, and founder of the annual MHI Manufactured Housing Congress, opined circa 2000, in his widely read column, ‘From My Soapbox’,

“…manufactured housing industry devotes an extraordinary amount of its’ resources to sell homes to people who really aren’t qualified home buyers. Why? Because they allow us to sell the ‘old mobile home way’. It’s easier than attempting to sell to qualified buyers who require a lot more effort. Manufactured housing may be the only industry in America who ignores the customer’s desires in their marketing practices. Unfortunately for us, potential buyers are much more savvy these days, and appear to be abandoning us in droves.”

OUCH! But it had to be said!

And, the consequences to annual new HUD-Code home shipments nationwide?

• Year 2000 = 250,550 new homes shipped (Down from 372,843 in 1998)

• 2007 = 95,769 (First year since 1961 with fewer than 100,000 homes shipped!)

• 2009 = 48,789 (The nadir of manufactured housing shipments!)

Furthermore, this is what now retired industry chattel finance maven, Marty V. Lavin, esquire, opined about what he termed, the ‘deeply flawed operating model’ of manufactured housing. In his words…

“During the early 2000s, it became evident the new home sales downturn was unlikely to end! Our long term industry operating model was deeply flawed. The huge number of home shipments enjoyed during the 1960s & 70s, had only been possible given unsustainable chattel loan losses absorbed by industry lenders throughout the period. Once the severity of said losses was fully recognized, in he late 1990s, chattel lending tightened and shipments started a rapid decline, dropping to 50,000 homes shipped per year. Today, only a slight shipment recovery seems possible under the continuing flawed operating model. Not until the industry finds a way to market our homes to a much better credit tier of buyer, is growth likely to occur again. And one must believe industry growth is also unlikely to occur absent many needed industry model changes.” (Lightly edited. GFA)

With all that said though, our focus now must turn to what it’s going to take to restore reasonable access to chattel capital when selling and financing new and resale manufactured homes on-site in land lease communities (a.k.a. manufactured home communities) throughout the U.S. And that’s why the Federal Housing Finance Agency is hosting three Listening Sessions throughout the U.S. this Winter, providing opportunities for manufactured housing executives, land lease community owners/operators, and others, to input Fannie Mae & Freddie Mac, as these GSEs engage in rulemaking and program development that’ll restore reasonable access to chattel capital to this unique affordable housing marketplace.

That’s why it’s helpful to have learned, and now understand, what’s brought the HUD-Code manufactured housing industry ‘to its’ knees’ between 1998 (When 372,843 new homes were shipped), and 2009 (When only 49,789 new homes were shipped); and how we experienced 70,544 new homes shipped by year end 2015 – and just might eclipse 80,000+/- new homes during 2016 – if several thousand FEMA homes are added to the total provided by the Institute of Building Technology and Safety (‘IBTS’).

Yet another succinct historical retrospective on this matter was penned, and recently updated, by Dick Ernst, president of FINMARK in Dallas, TX., writing for the Guidebook for Selling & Seller-financing New Manufactured Homes in Land Lease Communities, he observed… *2

“Let’s go back to those ‘go-go days’ of the 1990s, when HUD-Code manufactured
housing was enjoying strong growth year after year, and was the darling of Wall
Street. Large amounts of capital were chasing public (housing manufacturer)
companies’ stock, driving up housing prices, and giving these firms ‘play money’
with which to expand their retail distribution networks. The new buzz within the
industry as ‘vertical integration’.

Retail (chattel) financing was plentiful and financially attractive, because lenders
were paying MHRetailers a premium for their loans and were very aggressive
with their underwriting practices. While some lenders were portfolio lenders (i.e.
keeping chattel loans on their books), the bulk of financing, at the time, came
from active participation in the Asset Backed Securities Market. Lenders were
originating $100w of millions in loans, packaging them, and selling them, while
retaining servicing. Green Tree Financial was the largest ‘player’ at the time, with
more than 30 percent of market share. Other lenders tried to ‘out do’ them, by buying more marginal business, and or paying more for the loans purchased.

The peak of manufactured housing’s gluttony occurred in 1998, when 372,843 HUD-Code homes were shipped to MHRetailers and land lease communities. Marty Lavin (now retired), veteran manufactured housing finance consultant determined as much as one third of the industry’s chattel loans were made to homebuyers having a FICO score of less than 600 points! The soon result was a default frequency of more than 30 percent of loans originated at the time. The industry ended up with a glut of repossessed homes that took three years to absorb and resell.

So, what has happened since then? The asset-backed security business continued to operate, but the cost of doing securitizations became very expensive. Green Tree reorganized under bankruptcy protection, and stopped originating new loans. Clayton Homes, one of the largest scrutinizers in the MHIndustry, ended up selling to Berkshire Hathaway. Ultimately, when the sub prime fiasco hit, the capital markets were shaken to the core and closed down the asset backed security market completely. By 2010, there was no market for manufactured housing.

The MHIndustry and chattel financing look nothing today like they did at the turn of the century. The number of lenders financing ‘home only loans’, or at least the majority of such loans, can be counted on one hand, oft identified as ‘The Big Three’: 21st Mortgage Corporation, CU Factory-built Lending, and Triad Financial Services; plus, Clayton’s in-house arm, Vanderbilt Mortgage and Finance, Inc.” *3

“First came the S.A.F.E. Act (‘Safe And Fair Enforcement’…of mortgage licensure), implemented and enforced on the state level.” *4

“Then the Dodd-Frank Act occurred in 2010, soon birthing the Consumer Finance Protection Bureau (‘CFPB’) , yet another regulatory agency to enforce mortgage lending laws.” *5

Finally, this hands-on perspective from land lease community portfolio owner/operator Spencer Roane, MHM , of Pentagon Properties:

“The business of owning/managing land lease communities has become capital
intensive during the past 10-15 years. Today we are faced with spending $30-40,000 per new manufactured home we purchase for marketing on-site in our properties. Fortunately, there are many sources today, from which to borrow funds at record-low interest rates.

• Private investors (who) will lend money to community owners, oft from self-directed IRA accounts.

• Local banks, like American Commerce Bank, located on the outskirts of Atlanta, will also lend for home acquisition, seeing this as a means to segue into providing refinance, even new property acquisition funding, in the future.

• HUD-Code home manufacturers, like Clayton, Cavco, Champion, and Legacy, have in-house (Vanderbilt @ Clayton Homes) finance programs that encourage/facilitate community owners’ purchases of new HUD-Code homes. Also include 21st Mortgage Corporation’s CASH Program in this $ mix.

• Excess operating funds within land lease communities, via healthy net operating income (‘NOI’) and or refinancing the debt on said property or properties.” *6

Now, with that said, attention needs to focus on what must be incorporated into Fannie Mae & Freddie Mac chattel capital finance programs, relative to manufactured housing, so as to make their loans/mortgages ‘safe for securitization’ & ‘attractive to borrowers’ .going forward.

To some, this FHFA, Fannie Mae & Freddie Mac effort to rise to the challenge of Duty to Serve, might just be this nation’s last, best opportunity to preserve & increase the inventory of, and access to, this decades-proven and continuing ready source of truly affordable housing combination known as manufactured housing in land lease communities!

End Notes.

1. Quoted from the treatise, AFFORDABLE (MANUFACTURED) HOUSING, ‘From Factory to Family; a Bold Look into the Future of housing & Community’, 2015

2. PMN Publishing, 2016. Chapter # 5.

3. For more detail on this subject, along with contact information, read Signature Series Resource Document: ’18th annual National Registry of ALL Lenders’, 2016. Available ‘free’ from COBA7 via Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764.

4. Quoted from Chapter # 5 of Guidebook for Selling & Seller-financing’, 2016

5. Ibid

6. Ibid


George Allen, CPM & MHM, writing for the Community Owners (7 Part) Business Alliance, or COBA7 c/o Box # 47024, Indianapolis, IN. 46247.

January 13, 2017

Community Owners to Input GSEs; MHI & MHARRR = NAHB & BSC?

Filed under: Uncategorized — George Allen @ 7:07 am

Blog # 429 Copyright @ 15 January 2017;

Perspective. ‘Land-lease communities, previously manufactured home communities, & ‘mobile home parks’, comprise the real estate component of manufactured housing.’

This blog posting is the sole national advocate voice, official ombudsman & historian, research report & online communication media for North American LLCommunities!

To input this blog &/or affiliate with Community Owners (7 Part) Business Alliance, a.k.a. COBA7, use Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764

COBA7 Motto: ‘U Support US & WE serve U!’ Goal of its’ print/online media – to “Not only inform & opine, but to transform & improve MHBusiness model performance!”


Part I. Own one or more land-lease communities? This could be your last opportunity to influence Fannie Mae & Freddie Mac, as they finalize DTS-related rules that’ll return access to chattel capital to us, or continue the impasse endured since the turn of the century, 17 years ago! Do not pass up this unique and timely opportunity! And, why is no one else challenging you to input the GSEs? More to the answer than you likely realize…

Part II. Recent Canadian example of ‘national advocacy consolidation’ is worth talking about here in the states! Picking up where Part I leaves off; recall how very little we’ve achieved politically, given ‘national advocacy marginalization’ in our nation’s capitol these past 17 years. Not saying merger with the NAHB’s BSC is ‘the answer’, just that we sorely need a more effective lobbying arrow in our quiver than is the case at present!

Part III. ‘Hey, Gotta Love the MHARR!’ Takes something significant to get us to pen a headline like that – and Mark Weiss did, when crafting a recent Press Release, laying three of the manufactured housing industry’s key 2017 issues out there in one sterling paragraph! Read and reread what he penned! Then, like me, clip and mount it where you’ll see it everyday. Then ask; ‘Why isn’t anyone else communicating like this?’


This offer still stands, to MHI & MHARR: You’re welcome to contribute an op/ed column, regularly or from time to time, for possible publication in the Allen Letter professional journal. With the demise of The Journal, we – as an industry & asset class – have precious few media outlet opportunities to use these days, to ‘get the word out to our businessmen and women peers’ nationwide.
In January’s Allen Letter, COBA7 challenges MHARR & MHI to meet – all three together – to ‘brainstorm’ continuance of the NEW ERA of manufactured housing & land-lease community cooperation into year 2017. Will it happen? Read more here later…

Community Owners Asked Here, to Input GSEs with
Duty to Serve (‘DTS’) Rulemaking Recommendations!

OK, we’ve officially been invited to answer this question: ‘What would you, as a land-lease community owner or operator like to see written into DTS Rulemaking being considered and codified at present, by Freddie Mac & Fannie Mae?’ Read on….

Trust me, the GSEs are not waiting around for you and me to respond. Rumor has it, one manufactured housing national advocacy entity is already advising them on matters having to do with leases, etc.. Have YOU been asked, before NOW, to input what YOU would like to see included? For most of us property owners the answer is NO. Why?

With that said, COBA7, during the week following the Louisville MHShow, and after the FHFA Listening Session in Chicago, on 25 January, will be collecting your responses to this suggestion by FHFA (i.e. GSE’s oversight agency), to input both GSEs’ in formal business correspondence. Already we know there are concerns, among LLCommunity owners, about 1) the nature and terms of potentially requisite ground leases; 2) the possible role of mortgage insurance; 3) role of lender recourse; and, 4) identification of potential investors to buy securitized chattel capital mortgages on manufactured homes in this property type. What else should the GSEs write into their DTS rulemaking?

Look at it this way, ‘What do you think it’ll take to help the GSEs feel secure guaranteeing chattel capital mortgages on their way to being securitized and sold on the financial market?’

This is your last opportunity to directly influence DTS Rulemaking at Fannie Mae & Freddie Mac, via the Community Owners (7 Part) Business Alliance, or COBA7! Send your input, this week, to COBA7 c/o Box # 47024, Indianapolis, IN. 46247, or via

Such an exciting and rare opportunity for us. Don’t delay letting us know your ideas and thoughts on this vita and timely matter! Who’d have thought, three years ago, when Fannie Mae & Freddie Mac first attended the annual Networking Roundtable (in Peachtree City, GA.), we’d be invited to work this closely with them on a project of mutual, strategic, national interest.



Is this the ‘consolidation formula for manufactured housing’ in Canada and the U.S. during year 2017? Wow! Based on responses to last week’s blog posting at, one would certainly think so. Here’s the SURPRISE: All commentators favor the idea! Seriously. I’d have bet ‘dollars to donuts’ U.S. MHIndustry aficionados would balk at following CMHI & MHICanada’s example of joining with CHBA in council fashion. And maybe they will. But for right now, sentiment is 180 degrees different – at least in part, evidenced by these and other remarks:

• “NAHB would be a good move, and I used to advocate it when we were MOD builders. Their codes are consistent, believed, trusted and supported by most communities, particularly in rural markets where, too frequently, there is no code, or the enforcement is minimal….”

• “George. I’ve thought about this a lot over the years. The full scope of the MH industry does not fit with NAHB, unless the (land-lease) community business is left out. The communities have more in common with the Realtors. Unless MH is willing to slice its’ small slice of the housing pie (i.e. 5% of national market share) in half, I don’t see any merger working.”

Good point, that latter observation. And with the rising percentage of new HUD-Code home being shipped directly into land-lease communities nationwide (i.e. 25% in 2009; 40+% in 2015; 75% predicted for year 2020), that slice of the housing pie could well become a deal killer or maker. Hmm. Worth thinking about, don’t you think?

But that ‘thought’ is fraught with at least two significant challenges only now beginning to be addressed by the manufactured housing industry and land-lease community real estate asset class:

• Return of reasonable access (Forget easy access) to chattel capital via ‘any source(s)’, especially the two GSEs identified in Part I of this blog posting. It hasn’t happened yet. Maybe with a new national governance administration…No, at present, the two best alternatives remain independent third party chattel finance firm(s) – one in particular; and increasing popularity of lease-option methodology. (NOTE. On Tuesday, 17 January, of this week, between 1 & 4PM at the Crowne Plaza Hotel in Louisville, KY., Spencer Roane, MHM, will be conducting a three hour workshop on L-O, the practical, seller-finance alternative! Only $95.00/aattendee. Reach out to TODAY, or phone (770) 871-6889, to register and obtain the handout attendees will want to print ahead of the workshop!)

• HUD-Code home manufacturers, while now knowing how to ID & sell new homes to large property portfolio owners/operators, have yet to figure out how to reach all 500+/- of these sole proprietors and firms, nary to mention the 85% of 50,000+/- LLCommunities numbering 100 and fewer rental homesites apiece! (NOTE. On Tuesday, 17 January, of this week, between 9AM & Noon, at the Crowne Plaza Hotel in Louisville, KY., George Allen, CPM & MHM, will share 35 year trade secrets to this end: ‘How to ID LLCommunities & owners nationwide!’ Audience limited to HUD-Code home manufacturers. $95.00/attendee. Phone (317) 346-7156 to register Monday morning only!

Both the above events are being planned and hosted by COBA7. Do you see what’s happening here? No other manufactured housing national advocacy entity is taking steps, such as these, to promote the sale and seller-financing of new HUD-Code homes on-site in land-lease communities. If we don’t as an industry and realty asset class, do just this sort of thing NOW, then we might as well fold our collective futures in with the NAHB’s Building Systems Council and let the chips fall where they may….

Of course the land-lease communities will likely be left out of this esoteric (‘new’) mix. Either LLCommunities will have to entice the NAR, or NAA, to ‘take us in’ – and who knows, maybe they will, if we bring our ‘floor fees (dues)’ with us from manufacturers where we buy new HUD-Code homes. OR, we continue on our own in one or (GASP!) two national groups: 1) MHI’s National Communities Council and its’ few large property portfolio owners/operators; and, 2) COBA7, representing LLCommunities of all sizes, large & small, throughout the U.S. and Canada. What do you think?


Hey, Gotta Love the MHARR!


We sure did, especially that last substantive paragraph. It bears repeating and repeating!

“With this MHARR action having now been initiated in Congress…1) to challenge and enjoin any final DOE rule. MHARR is also moving forward on two other pending regulatory matters -2) the Federal Housing Finance Agency’s ‘Duty to Serve’ final rule, which fails to create an affirmative duty for the securitization of manufactured home chattel loans by the GSE; and 3) HUD’s impending ‘Interpretive Bulletins’ on frost-free and frost-protected shallow foundations, that would substantively and improperly alter existing standards, and is insistently being pursued by the current career manufactured housing program administrator and contractors, as a device to assert total HUD control over installation standards and programs in all 50 states.” (#s added. GFA)

WOW – again! That about ‘says it all’ where major 2017 issues are concerned, relative to manufactured housing. Hmm. Now one must ask; ‘Why am I not hearing more about these three significant issues of import, from other national advocacy bodies?

Me? I’ve cut out that paragraph and taped it to the side of my office PC, as a constant reminder of what’s going on – or should be going on, in the industry and asset class where we do business. Perhaps you should do likewise….

In the meantime; THANKS MHARR for keeping us informed and engaged!


George Allen, CPM & MHM
Box # 47024, Indianapolis, IN. 46247
(317) 346-7156

January 7, 2017

FHFA’s DTS Listening Sessions; MHICanada/CMHI Regroup; & New Expose’s…

Filed under: Uncategorized — George Allen @ 5:26 am

Blog # 428 Copyright 2017 COBA7 @ 8 January 2017;

Perspective: ‘Land-lease communities, previously manufactured home communities, & ‘mobile home parks’, comprise the real estate component of manufactured housing.’

This blog posting is the sole national advocate voice, official ombudsman & historian, research report & online communication media for North American LLCommunities!

To input this blog &/or affiliate with Community Owners (7 Part) Business Alliance, a.k.a. COBA7, use Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764.

COBA7 Motto: ‘U Support US & WE Serve U!’ Goal of its’ print/online media = to ‘Not only inform & opine, but to transform & improve MHBusiness model performance!’


Part I. COBA7 to represent LLCommunities at FHFA’s DTS Listening Session(s)!

Part II. Canadian national advocacy landscape alters as MHICanada & CMHI regroup in council fashion, with CHBA. Maybe a similar path for MHARR & MHI with NAHB?

Part III. Three expose’s in three months? Yes, and likely more to come during 2017!

Part IV. Guess who’s contemplating acquiring The Journal from Jim Visser?


COBA7, as National Advocate for Land-lease Communities, to Attend & Speak, During
‘Duty to Serve Listening Session(s)’

Community Owners (7 Part) Business Alliance, or COBA7, has accepted an invitation from the Federal Housing Finance Agency (‘FHFA’), to attend and comment, at one or more ‘Duty to Serve Listening Sessions’ planned during the next few months.

This is another way COBA7 represents the business interests of land-lease community owners/operators, large & small, from throughout the U.S! During the past few months, COBA7 has participated in public meetings hosted by FHFA, DOE, and other governmental agencies. A report describing the ‘Duty to Serve Listening Session(s)’, in which COBA7 participates, will be published in a future issue of the Allen Letter professional journal.

NOTE. The Allen Letter professional journal and the Allen CONFIDENTIAL! business newsletter are the last two remaining print publications serving the HUD-Code manufactured housing industry and land-lease community realty asset class. If you are not yet reading either or both trade papers, phone the Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764 to affiliate with COBA7 today, at the Option I, II, or III level.

Why is COBA7 affiliation important to YOU? Simply put; in most federal agency meetings attended to date, the only businessperson in the room (i.e. Someone who ‘makes payroll’ week after week) has been there representing COBA7! Seriously. Everyone else in the room is usually an agency bureaucrat, corporate attorney, or association staffer. So, if YOU want continued ‘business representation’, you’ll support COBA7 as your national advocate!


Canadian Manufactured Housing Industry Reorganizes – Suggesting Possible Pattern for U.S.?

This is ‘breaking news’ with details to follow.

MHICanada & CMHI (‘Canadian Manufactured Housing Institute’) have regrouped in council fashion, under the Canadian Home Builders Association (‘CHBA’). This occurring in a fashion similar to the present day Building Systems Council (‘BSC’), operating in council fashion, under the auspices of the National Association of Homebuilders (‘NAHB’), here in the U.S.

Stop and read that paragraph again! Then ponder this present and possible future state of U.S. manufactured housing affairs:

MHI, while not regrouping, does claim via its’ recently revamped website (, to be REPRESENTING THE FACTORY-BUILT HOUSING INDUSTRY. This an attempt to parlay its’ 10% national factory-built housing share (i.e. 5% @ HUD-Code housing & 5% modular housing), by arbitrarily including panelizers’ 50% market share, and production site builders’ 39%, to achieve 100% market coverage? Not a bad strategy, if they can pull it off – convincing panelizers & production site builders to depart NAHB’s BSC and become direct, dues-paying members of the institute. Otherwise, it’s simply, in this industry observer’s opinion, a national advocacy overreach pipedream

Well, since MHI is already thinking ‘outside the box’ relative to national representation, maybe there’s a parallel option – though some might call it heretical*1:

In the spirit of the opening paragraph of Part II, and given similar perennial antipathy*2 between U.S. manufactured housing’s two oldest national advocates, MHARR & MHI; is ‘regrouping together in BSC council fashion’, under NAHB auspices*3 – or some ‘new’ organization, that much of a stretch in today’s world where we ship but 80,000+/- new HUD-Code homes during all of 2016 – compared to 372,843 shipped during 1998? Think about it.

(I have, and that’s why I’ve made this bold suggestion. Now, is it a good idea? I don’t know. On one hand, it’d be Great to have manufactured housing finally viewed as an integral part of the overall national housing scene! However, if ‘counciling together’ with BSC & NAHB occurs at the cost of autonomy (‘independence’…think Federally preemptive building code), then doing so could mark the demise of manufactured housing altogether. What do you think?)

With that said (penned), how much longer are we going to wait, as a divided ‘large vs. small company’ industry, to take – if need be – radical steps, to regain the robust factory-built housing market share of 18 years past? After all, HUD-Code Community Series Homes, when sited within professionally managed land-lease communities, charging market sensitive & homeowner/site lessee ‘fair value proposition’ rental homesite rates, is by far the most competitive type affordable housing/lifestyle combination available anywhere in the U.S. today! And yet, as the ‘Tipping Point’ WHITE PAPER Expose’ clearly pointed out, we’re letting that market advantage slip away!

Furthermore, claiming inflated factory-built national housing market share simply ‘does not make it so’; rather, time is a-passing, if not already past, for us to brainstorm, plan and effect our collective destiny, the sooner the better!

Is anyone at MHI & MHARR really listening? How ’bout proving you are, by uniting and getting this affordable housing/lifestyle ball a-rolling once again!

Land-lease community owners/operators, via COBA7, stand ready to assist!

End Notes:
1. heretical = “one who olds an unorthodox opinion.” Webster dictionary
2. antipathy = ”dislike” Webster dictionary
3. auspices = “favoring influence, protection or patronage” Webster


Watch for Next Expose’ in Allen Letter!

Yes, you read that right. Two months ago it was the widespread distribution of the ‘Tipping Point’ WHITE PAPER Expose’, warning HUD-Code housing producers and land-lease community owners/operators what occurs when:

‘reasonable rental homesite rates & affordable housing values’ are supplanted by ‘higher rental homesite rates & smaller PITI payment’, oft times resulting in

1. Diminished Buying Power for Purchase of New HUD-Code Housing
2. Reduction in Existing Housing Value, &
3. Fewer New Homes Shipped Nationwide

If you did not receive, see, or read this four page expose’, but would like to do so, simply phone COBA7 via (317) 346-7156 and ask for a FREE copy!

Next expose’?

MHI’s website overreach, claiming to be REPRESENTING THE FACTORY-BUILT HOUSING INDUSTRY in toto! Reread Part II of this blog posting for details….also blog postings # 426 & 427 at website. Just left click on blog icon and scroll back thru the archives.

And NOW this one: ‘Freelance Land-lease Community Consultants’, Be Careful Who You Trust & Hire!

This was a challenge dealt with around the turn of the 21st Century, when many portfolio property management (‘PM’) executives lost their jobs. All has been relatively quiet for awhile, but during the past six or so months, there’s been a spate of displeasure directed towards mostly noncredentialied (i.e. ‘not certified’), inexperienced freelance PM consultants, promising much but delivering little.

The Good News is, there’re practical ways to protect oneself from these charlatans. Read the expose’ featured in the February 2017 issue of the Allen Letter professional journal. If not a COBA7 affiliate yet, phone (317) 346-7156 to do so.

George Allen, CPM, MHM
Box # 47024
Indianapolis, IN. 46247

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