Blog Posting # 831; Copyright 14 February 2025. EducateMHC
Know this! HUD-Code manufactured housing (‘MH’) is federally-regulated, performance-based, affordable-attainable, factory-built housing (a.k.a. offsite construction). Land lease communities (a.k.a. manufactured home communities & ‘mobile home parks’) comprise the commercial real estate (‘CRE’) component of MH; and, with variations of housing finance (e.g. chattel or ‘home only’ loans & real estate-secured mortgages), describe the post-production segment of MH.
EducateMHC is the official MH historian, trade term & trend tracker, as well as perennial information source. Contact EducateMHC via (317)881-3815, email: gfa7156@aol.com, and www.educatemhc.com, to purchase Community Management in the Manufactured Housing Industry (A copy of which belongs in every land lease community nationwide), & SWAN SONG –History of land lease communities & official record of annual MH production totals since 1955.
And my autobiography, From SmittyAlpha6! to MHMaven, describes personal combat adventures in Vietnam as a USMC lieutenant, a 45 year entrepreneur business career in MH & community ownership, as well as freelance consulting and authoring of 30 nonfiction texts.
George Allen is the sole emeritus member of the Manufactured Housing Institute (‘MH’), a founding member of MHI’s National Communities Council (‘NCC’) division, an RV/MH Hall of Fame enshrinee, as well as Allen Legacy columnist and editor at large for MHInsider magazine.
MH Inside Information No One Else Will Tell You!
You likely know manufactured housing is represented by two different national trade entities, the Manufactured Housing Association for Regulatory Reform (‘MHARR’) & Manufactured Housing Institute (‘MHI’). But did you know, during its’ long (70 years) history, the latter advocate has cycled through nearly a dozen salaried leaders; while the former body, founded in 1985 as an offshoot of MHI, has had only two, its’ present CEO, and founder Danny Ghorbani, who’s now retired and is an RV/MH Hall of Fame enshrinee.
But there’s more to know, and much ‘came out’ during the first week in February in a Press Release from MHARR. Its’ title? ‘MHARR Initiates Action with Trump Administration On Major Industry Bottlenecks.’ An interesting but humdrum title. What made this lengthy communique intriguing, were several unsubstantiated premises and position statements. Here we go…
First, “Manufactured housing must be – and must remain – federally-regulated pursuant to uniform standards, uniform enforcement and robust federal preemption which result in cost savings that are passed to homebuyers.” Now, for newbies to the MH business model, this statement is emblematic of the proverbial phrase: ‘When life gives you lemons, make them into lemonade!’ Meaning here, when the federal government foisted a regulatory lemon (i.e. the HUD-Code) on the manufactured housing industry in 1976, over time, MH businessmen and women turned that lemon into marketing lemonade, using its’ uniform standards and federal preemption to sell more homes! But is that still the case today?*2 So, ‘Why must we continue to be federally-regulated?’ Some, if not many, say: ‘Federal regulation appears to be doing little, today, to sell more manufactured homes!’ Perhaps being able to openly market as offsite housing – housing built within factories, might be more attractive to potential home-buyers, especially those not wanting a steel chassis under their new home.
Second. “It is beyond dispute that today’s federally-regulated manufactured homes are the industry’s best homes ever, offering high quality and inherent affordability….” Once again, the question begs answering: What’s driving our housing market? Federal regulation or the quality and inherent affordability of our product? Frankly; neither. It’s the paucity and lack of access to personal property or chattel (a.k.a. ‘home only’ loans) financing for new manufactured homes going directly into land lease communities and sited on vacant rental homesites.
Third. “The industry largely wasted its opportunity during the first Trump Administration to remove the three principal bottlenecks that have impaired the industry’s growth and expansion while simultaneously harming homebuyers.” What were those bottlenecks?
- “Forcing HUD to fully implement the enhanced federal preemption of the 2000 Reform Law to end the discriminatory zoning exclusion of HUD-Regulated manufactured housing from entire communities.”
- “Forcing Fannie Mae and Freddie Mac to serve the dominant manufactured housing personal property consumer financing market in accordance with Duty To Serve (‘DTS’)…” This sentence makes no sense as penned; perhaps rewrite in part:’ Forcing (the GSEs) to dominate the manufactured housing personal property consumer financing market….’
- ‘Eliminating DOE’s draconian, destructive and discriminatory manufactured housing ‘energy conservation’ standards.” No argument here.
The Press Release goes on to criticize MHI for spending the years 2016-2020 “…pursuing speeches, exhibitions, displays and other public relations stunts that ultimately did nothing substantive to change the diminished status quo for (SIC) the industry…a wild goose chase of wasted opportunities.” Dealing with Washington bureaucrats and regulators has to be a constant education process, given attrition, elections, and more. There’s really no way of telling how much good the MHI-hosted ‘Homes on the Mall’ did for our industry, but it needed to be done.
In another premise, the writer decries ‘ceding market share to other types of construction.’ Just what is manufactured housing’s ‘market share’ in today’s overall housing market? Frankly, no one really knows! Why? Because manufactured housing, modular, panelized & Park Model RVs are not included in the U.S. Census Bureau’s monthly total of residential single-family, site-built housing starts (because most MHs are not permanently sited on scattered building sites conveyed fee simple, and no one tracks the other types of offsite construction). It is this writer’s contention that the total housing market starts in the U.S. should include residential single-family, site-built housing, HUD-Code manufactured housing, modular & panelized (i.e. pre-fab) housing, as well as Park Model RVs. Until that happens we will not be able to accurately calculate what percentage of the national housing market truly belongs to HUD-Code manufactured homes.*3
The most outspoken recommendation in this Press Release has to do with the contractor used by HUD to supervise the manufactured housing program. Here goes: “….MHARR…calls for strong HUD action to remedy endemic (*1) mismanagement of the HUD manufactured housing program, including its unprecedented, destructive and inexcusable dependence on an entrenched ‘monitoring’ contractor which has held a de facto sole-source contract for 50 years without any of the legal safeguards normally required for non-competitive federal contracts.” Whew! Aside from wordiness, this commentary does raise this strong and valid point: Why no change in monitoring contractors, where manufactured housing is concerned, over 50 years?
Another bugaboo appears to be “…last-minute (a.k.a. ‘midnight’) Biden Administration appointments to the statutory Manufactured Housing Consensus Committee (‘MHCC’).These appointments, announced four days before the inauguration of President Trump, continue HUD’s tactic – since at least the Obama Administration – of undermining the independence of the MHCC by manipulating MHCC membership…” e.g. refusing representation for smaller, independent producers of manufactured housing. It’d be interesting to learn the names of these last minute appointees, to ascertain ability to perform, experience in MH, and political persuasion. MHCC has, in my opinion, long been a political quagmire. For example, I’ve tried since 1980 (i.e. 45 years!) to be named to this august body, and its’ predecessor the Manufactured Housing Advisory Council (‘MHAC’), all to no avail.
There’s more, to be sure. But I wanted to give you a hefty taste of what goes on ‘behind the scenes’ where the regulation of HUD-Code manufactured housing is concerned. Once again, if you have information or opinions on these matters and are willing to communicate them to me, please do so via gfa7156@aol.com
End Notes.
- endemic. ‘peculiar to a location or a people’
- 1976 = 246,120+/- new HUD-Code homes produces, compared to 2024 with but 103,314 new homes produced and shipped (per IBTS data)
- Given 1,588,404 ‘total U.S. housing starts’ in 2024 (including onsite & offsite housing types), divided by 103,314 new HUD-Code homes produced during 2024, estimated national market share for manufactured housing is 6.5% (i.e. .065)
Official Historical Record Available to You for Free!
As some of you already know, I recently updated the ‘Official Historical Record of HUD-Code Manufactured Housing Production’, the seminal document featured in the industry text, SWAN SONG. Now this official record extends from 1955 through year 2024 (i.e. 69 years). Here’s how the first and final data entries read:
1955 = 111,900 new mobile homes produced & shipped
2024 = 103,314 new HUD-Code manufactured homes produced & shipped
Boy, at first glance it does not appear we’ve made any production progress during the past seven decades, but that’s not the whole story. To learn more, request a FREE electronic copy of this document via gfa7156@aol.com Between the 69 annual performance entries and 27 historical footnotes, you’ll read quite the story! GFA
George Allen