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

August 3, 2022

Read MHARR report

Filed under: Uncategorized — George Allen @ 1:17 pm

Blog Posting # 699. Copyright @ 27 July 2022. EducateMHC

Perspective. ‘Land lease communities, previously manufactured home communities, and earlier, ‘mobile home parks’, comprise the real estate component of manufactured housing! EducateMHC is the online national advocate, realty asset class historian, trend spotter, education resource, textbook supplier for land lease communities throughout North America!To input this blog and or connect with EducateMHC, telephone (317) 881-3815,email and or visit

INTRODUCTION: What follows is a ramble (or as they say in Australia, a ‘walkabout’) beginning with the months long ‘PUT UP or SHUT UP’ challenge per establishment of a national post-production trade advocate; then transitions into a loose review of the recently released (i.e. 7/26/2022) MHARR White Paper which touches on the same subject. And if we’re ‘lucky’, the ramble will end with a succinct statement as to why production and sale of new HUD-Code manufactured homes continues to lag at 300,000 & 500,000 levels of 50 and 24 years ago.

OK, here goes. The Manufactured Housing Association for Regulatory Reform (‘MHARR’) recently released a 16 pages White Paper titled, ‘The Exploitation of Federal Housing Finance & Mortgage Funding Assistance Programs and Potential Solutions’, presumably authored by Mark Weiss (his name does not appear anywhere within said document). To obtain a copy, phone MHARR via (202) 783-4075.

After reading the White Paper through, from start to finish, I thought: “This is almost a PUT UP response to the aforementioned PUT UP or SHUT UP challenge. Why ‘almost’? Because the timely topic of birthing a new national post-production trade entity while presented and justified, NO mention is made of meeting to organize and move forward with this idea!

So the industry challenge stands: PUT UP or SHUT UP! on or before 15 August 2022, at the RV/MH Hall of Fame in Elkhart, IN. Which will it wind up being?

Let’s begin with the purpose of this White Paper report. “…to expose and explain the disconnect and disparity between claims (and the exploitation of such claims) on the one hand, and actual results on the other, which continues to deprive manufactured housing and its largely moderate and lower-income consumers of all the benefits that could – and rightly should – be derived from such federal housing, finance and mortgage assistance programs.” P.3 Yes, I know, this is about as clear as mud; but the report does, in the final analysis, expose and explain, from MHARR’s perspective, what’s holding manufactured housing back from success.

In my opinion, the White Paper does not ‘hit its’ stride’ until almost halfway through, on page 6, where the writer identifies Federal Program Implementation Failures. And while he does a yeoman’s job doing so throughout the text, the absence of footnotes and end notes makes it difficult to follow his line of thought, e.g. “…specific integration of federal manufactured housing into all such programs….” What programs?

The author’s summary of “…negative impacts…concerning the U.S. Department of Energy’s (‘DOE’) proposed (and now final) manufactured housing energy standards.” P.7 was particularly informative and thought-provoking. You should make it a point to read this ASAP!

The two most compelling parts of this White Paper, for this reader, were as follows:



It is without exaggeration that I state: Every businessman and woman in manufactured housing, and owning land lease communities, should read those two parts of the White Paper. I’m not commenting on their content, as I far prefer you to read and do so – directly to MHI & MHARR.

My epiphany.*1 During the reading of pages #7 thru 11 it hit me as to ‘why’ our industry and unique income-producing property type, have so darn much difficulty getting local and federal legislators and regulators to ‘play ball’, so to speak, with us. Now, nothing new here, just – for me anyway – an epiphany after working 40+ years in this ‘double dual industry’.*2

So here goes. Everyone, it seems, knows HUD-Code manufactured housing is, by far, the most affordable of all housing types in the U.S. today, priced at half – or less, than average cost of new site-built homes. But, at the same time, we are the only housing producer, to date, that routinely fights installation regulations, to properly and (Gasp!) permanently, attach our product to underlying realty. It’s like we want the cake (market popularity) and eat it too (but with shortcuts). No one knows how many, but a large number of new homes, for example, especially those sited within land lease communities, are installed at ground level with not even a nod to ‘best practice’ procedures, like Frost Free Foundations. No wonder banks don’t want to finance our housing product. And this is just the tip of the ongoing discriminatory, exclusionary state and local zoning laws albatross we bear.*3

Next there’s the confusing and complicated world of consumer finance. This White Paper does an excellent job, in my opinion, spelling out where the skeletons lie, e.g. “…unavailability of market-competitive consumer financing for such homes, as a result of failure and refusal of federal mortgage giants, Fannie Mae & Freddie Mac, to support manufactured housing personal property loans (comprising nearly 80% of the entire HUD-Code market….”P.9. And there’s this gem again, quoted from a Consumer Financial Protection Bureau (‘CFPB’) report: “…the ‘top five’ lenders in manufactured housing market made nearly 75% of all chattel loans, and an estimated 50 percent of MH chattel loan applications were denied, while ‘only 7 percent of site-built applications (are) denied”.” Doesn’t anyone else see what is being described here?

Back to my epiphany. As an industry, we continue to ‘cornfuse’ potential lenders who do not fully understand manufactured housing – and how the very same new home, on one hand going onto a scattered building site owned fee simple can qualify for a conventional real estate mortgage. And at the same time, its’ ‘twin’, so to speak, going into a land lease community (a.k.a. manufactured home community) on a rental homesite, is eligible only for a chattel or personal property loan (a.k.a. ‘home only loan’) featuring higher interest rates and shorter loan terms. Solution to this perennial dilemma? Well, at least we’re talking about it here today. What’s your solution? Mine?

As a longtime, but now former, land lease community owner/operator, I’d have been willing, given the opportunity, to finance new HUD-Code home on-site with conventional real estate mortgages (not chattel or personal property loans) if required to do the following:

• Agree to long term rental homesite leases, extending beyond the mortgage term limit.

• Keep my rental homesite rent rate in sync with other forms of multifamily rental communities (e.g. conventional apartments) in the same local housing market. How’s this done? Read end note # 4.

A particularly interesting part of this White Paper had to do with identification of those within and outside our industry, who benefit from Discriminatory & Exclusionary State & Local Zoning Laws, and Discriminatory & Exclusionary Consumer Finance Regulations. Here goes: “…extra-industry beneficiaries (include) on-site homebuilders, the real estate industry, the rental housing industry, and other types of homebuilders, site-built lenders….”; “…intra-industry beneficiaries (include) a small number of vertically-integrated industry-dominant producers…captive finance companies owned by those manufacturers, and large, corporate manufactured housing communities.” P.12 *5 Once again, it’d be so helpful to have these identities footnoted, so as not to continue the confusion that exists about such important matters.

Solutions to our industry’s challenges? This White Paper identifies two:

• “Creation of an independent national post-production manufactured housing Association.”P.14 But no definitive steps (i.e. meeting planning) taken to do so soon.

• “Legal challenges and congressional hearings to establish accountability for implementation of enabling laws.”p.14

This blog posting does not cover the subject White Paper in detail. For example, it does not explore what’s termed, the “Misuse of Public Relations to Make Baseless Claims of Success and to Cover Failures.” P. 7. Just one more reason for you to obtain a copy of the White Paper for perusal and inspiration.

As usual, your reaction to, and opinions regarding, this blog posting are welcome via And tell you what; if concerned enough about the aforementioned industry matters and desirous to discuss them, I’ll be pleased to meet with you personally, or in a group, at the RV/MH Hall of Fame library on 15 August 2022. Just let me know your wishes ASAP.

End Notes.

1. Epiphany. “a sudden, intuitive perception of or insight into reality, or the essential meaning of something.” Random House Webster’s Dictionary.

2. Double Dual Industry. A term I’ve long used to demonstrate how, as an industry and realty asset class, we’re really four types of business models rolled into one: housing manufacturing & marketing/sales – and – land lease community homesite leasing and housing sales/finance.

3. Reference made here to Silas Marner and the albatross hung about his neck in the epic poem: The Rime of the Ancient Mariner, by Samuel Taylor Coleridge, 1797.

4. Use the traditional 1:3 Rule; where land lease community rental homesite rate is roughly one third the monthly rent for a 3BR2B apartment or townhouse, e.g. Apartment rent = $1200/month, divided by 3 = $400/month rate per rental homesite. Note: Important to treat utility charges (e.g. water, sewer, electric) in similar fashion.

5. Vertically-integrated industry-dominant producers? Guessing here, but maybe the Big 3-C firms? And large corporate manufactured housing communities? Guessing again, but maybe some of the largest property portfolio owners/operators? This is why it’d be so helpful to have End Notes or footnotes throughout this White Paper.

George Allen, CPM, MHM

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