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

July 15, 2017

SWAN SONG, Contretemps, & Honest Disagreement. All for You!

Filed under: Uncategorized — George Allen @ 5:09 am

Blog # 455; Copyright @ 16 July 2017; at

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 all 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.

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to not only inform & opine, but transform & improve MHBusiness performance!

INTRODUCTION: What a heady mix of topics this week! SWAN SONG, Contretemps, & Honest Disagreement. SWAN SONG focuses on past & present; Contretemps & Honest Disagreement on present & future, of manufactured housing and land lease communities. Just wish it could have all been penned in succinct fashion, but given the nature of both foci, this is the best I could do for you. GFA


What’s So Special About Swan Song?

‘George Allen’s History of the Land Lease Communities (1970-2017)
First Official Record of Manufactured Housing Shipments (1955-2017)’

This is a tell-all book about manufactured housing and land lease communities during my 45 year career in factory-built housing and investment properties, and as a professional property manager – accolades, warts, and all!

No fewer than 80 friends and associates, from my decades in this ‘double dual business model’ are identified (Some have died), and credited for specific contributions to the manufactured housing industry, and ‘mobile home parks’ cum manufactured home communities cum land lease communities.*1 A personal goal is to put a gratis copy of Swan Lake in everyone’s hands at the 26th Networking Roundtable, 6-8 September, in Indianapolis, IN. Or mail copies to them afterwards. There are no plans to sell this historic, tantalizing, tell-all tome (‘large book’) on the open market.

Tell-all? Here’s one example. There’s never been, before Swan Song, an ‘Official Record of Manufactured Housing Shipments’ ,circa 1955-2017. Seriously. Oh, there’re lists all right, but have you compared claimed annual shipment volumes side by side, year by year? The totals often differ, depending on ‘whose & which’ national advocate’s list one references. Well, this ‘Official Record of Manufactured Housing Shipments’ debuting in Swan Song, lists annual shipment data with a (+/-) when there’s no verifying monthly data available from HUD’s contracted scorekeeper, the Institute for Building Technology & Safety (IBTS’). And where there is archived monthly shipment data (available only for recent years), the annual total is clearly marked as ‘Verified’. For the record, IBTS does not publish annual HUD-Code housing shipment totals, due to uncertain disposition of DESTINATION PENDING housing units – oft not resolved until years later!

There are additional timely and helpful reprints and unpublished works, about manufactured housing & land lease community topics. Here’s some of what you’ll read and in this landmark text:

• Brian Gallagher’s (COO/CFO @ Santefort Neighborhoods, Chicago, IL.), ‘A Land lease Community, Seller-Finance Success Story’, prepared for the Federal Housing Finance Agency’s (‘FHFA’) Chicago ‘listening session’ in early 2017. Reprinted from the Allen Letter professional journal.

• Spencer Roane’s (Founder & President of Pentagon Properties, Atlanta, GA.), ‘Manufactured Home in a Land Lease Community versus Site-built Home on Deeded Realty’ – a $ comparison featured in Manufactured Housing Review.

• Mary Ann Andersen, ‘One Man’s Vision Realized, the Saddlebrook Farms Story’. This is, without a doubt, one of the most anticipated business model success stories in manufactured housing and land lease community history!

• George Allen’s contributions: ‘An Error to Die For’ (circa 1990); ‘Upside Down in a Mobile Home Park’ (circa 2000); ‘Historical (chattel capital) Perspective, to FHFA’s DTS Rulemaking Challenge to GSEs’ (January 2017); as well as ‘The Florida Communities Story’, shared as a Case Study, in the Guidebook to On-site New Home Sales & Seller-financing (2016); and, ‘The Manufactured Housing Industry Tipping Point’ – a timely, serious warning to the industry and asset class!

If all that doesn’t titillate you to the point of wanting to be present at the upcoming Networking Roundtable, there isn’t much more I can say, to convince you to attend.

Furthermore, we’re ‘pulling out all the stops,’ to host and facilitate the Best educational, interpersonal networking, and realty deal-making opportunity ever planned and facilitated for owners/operators of land lease communities nationwide.

End Notes.

1. Double dual business model’ = HUD-Code manufactured housing production & distribution; land lease community development & management.


MHARR finds FHFA’s Duty to Serve Underserved Markets – Implementation Plan, to be “…wholly deficient and unacceptable with respect to the manufactured housing component of DTS…particularly the chattel financing segment of the manufactured housing consumer lending market….” *1 And, “MHI reinforced its position the Enterprises’ plans must lead to chattel manufactured home loan purchases. MHI argued the plans should include measurable benchmarks, and DTS credit must only come from achieving these benchmarks.” (Lightly edited. GFA)


Others (i.e. non-national advocacy entity academics, as well as businessmen & women, with ‘skin in the MH game’) wax optimistic. Believing GSE’s are ready to work with manufactured housing, on several fronts, to restore reasonable access to chattel capital to land lease community owners/operators routinely selling and seller-financing new and resale manufactured homes on-site. *2

So, how is this a contretemps (‘an embarrassing occurrence’)? As badly as the manufactured housing industry needs reasonable access to chattel capital for home loans, we don’t need continuing disunity and distrust hamstringing the industry in front of federal legislators and regulators! Answer this: ‘Do we continue to ‘go to the mat’ with said regulators and legislators; or, once again, placidly attempt to negotiate our way out of unpleasant situations?’ Here’s a clear example of this counterproductive attitude.

From ‘MHI News & Updates’ dated 12 July 2017:

“Several other organizations noted similar sentiments in their own comment letters. The National Association of REALTORS expressed their support of the Enterprises’ inclusion of a pilot program for chattel loans. The Mortgage Bankers Association stated, given that ‘chattel loans comprise the vast majority of manufactured housing loans, it would be difficult for he Enterprises to fulfill their obligation to serve the manufactured housing market without addressing chattel loans.”

Really? Well then, the defining question is this: ‘Where’s mention of MHARR’s like-focused comment letter to the FHFA? If NAR & MBA support of ‘inclusion of a pilot program for chattel loans’ is worthy of mention; why not the lengthy comments, on the very same subject during the same timeframe, from MHARR – as a sign of industry unity? As long as we, as an industry and realty asset class, suffer counterproductive attitudes like this, among manufactured housing advocacy entities in Washington, DC., we’ll likely continue to suffer unhelpful actions by regulators and legislators!

As to’ honest disagreement’; someone needs to stand up to ‘Support or Debunk’ (lightly edited) statements following; quoted from MHARR’s comment correspondence to the Honorable Mel Watt, Director of the FHFA, dated 10 July 2017:

• MHARR challenges FHFA “…to produce and approve amended plans that…provide for the market-significant securitization and secondary market support of manufactured home chattel loans by the Enterprises on an expedited basis.” (p.2)

• The FHFA 2016 DTS Final Rule and proposed DTS implementation plans flowing from that rule, represent not only a failure to comply with the will and word of Congress, but a failure of leadership as well.” (p.3)

• “The implementation of DTS…established by the FHFA final rule and related Evaluation Guidance fails to mandate any securitization or secondary market support for any type of manufactured housing loan, either real estate or chattel.” p.5)

• “…current ‘portfolio’ manufactured housing lenders have developed a profitable business model (with higher-cost interest rates that would produce even greater returns with the lower rates and significant greater volume that would result from Enterprise support)” p.8

• “…for the Enterprises, that spent years putting people into homes they could not afford – leading to their own collapse – to now balk at helping people buy manufactured homes they can afford (to buy), based on alleged ‘risk’, is absurd, unacceptable and inexcusable.” p.10

• “…manufactured housing consumers will remain, effectively, as captive customers, within a financing market dominated by just one or two lenders, that is less than fully competitive, and that charges them high-cost interest rates, specifically because of the absence of such support by the Enterprises.” p.13

Now, there was one statistic in MHARR’s ‘FHFA DTS’ review, and confirmed in MHI’s like letter, that illustrates growing influence and presence of land lease communities as buyers, sellers, and financiers of HUD-Code manufactured homes:

• “Chattel placements (presumably new homes going into land lease communities), represent an expanding segment of the overall manufactured housing market, having increased from 64% of all placements in 2007 to 80% of all placements in 2014, a 25% increase.” (p.6). For context; recall 2009 = the nadir point of MH shipments @ only 48,789 new HUD-Code homes shipped nationwide; and 2014, where shipment volume increased to 64,331 (verified) new homes.

MHI, in its’ own right, takes the Enterprises to task, in its’ comment letter dated 10 July 2017:

• “…both Plans include a number of ‘soft’ Activities (such as research, conferences, roundtables, and provision of educational materials), and both Plans include Objectives to promote loans to manufactured home communities, which do not increase the availability of manufactured home loans to very low, low, and moderate -income borrowers.”‘ p.1

• “…the Plans do not appear to include efforts to purchase manufactured home loans on a flow basis (i.e. through establishment of underwriting guidelines that allow seller-services to sell all loans that meet such guidelines).” p.2

• “…MHI believes purchasing commercial loans for manufactured housing (sic) communities does not address an ‘underserved market’ need, and therefore the Enterprises should not receive Duty to Serve credit for such loans.” p.3

• “MHI is confident chattel loans can be purchased safely and profitably, with proper underwriting standards and appropriate compensating fees and risk sharing.” From previous paragraph: “…it is now nine years since Congress passed Duty to Serve, and neither of the Enterprises are purchasing such loans.” p.3

• And finally, “…the buildout (sic) of a chattel purchase program on a flow basis necessitates the development of a functioning, cost-effective secondary market for such loans.” p.4

So, where do YOU stand amidst this ‘contretemps &. honest disagreement’ discussion?

It’s simply one more significant and timely reason why you should be in Indianapolis, 6-8 September, when our keynote presenter touts the positive perspective of this complicated matter. To register for the event, use attached brochure of via

End Notes:

1. MHARR = Manufactured Housing Association for Regulatory Reform; FHFA = Federal Housing Finance Agency (oversees GSEs); &, DTS = Duty to Serve

2. GSEs = in this instance, Fannie Mae & Freddie Mac

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