Manufactured Housing Association ‘Targets’ Fannie Mae and Freddie Mac ‘Failure’ in FHFA Duty to Serve Listening Session

MHARR-nearly 80% of all manufactured home loans are chattel but despite Congressional mandate some 15 years after Duty to Serve (DTS) federal law not enforced.



WASHINGTON, D.C., UNITED STATES, July 22, 2023/ — In a media release to manufactured housing professionals, public officials, and others concerned about affordable housing issues, the Manufactured Housing Association for Regulatory Reform (MHARR) provided comments that their president and chief executive officer (CEO) Mark Weiss, J.D., delivered to the recent Federal Housing Finance Agency (FHFA) “Listening Session” on implementation, or the lack thereof, of the “Duty to Serve” mandate for manufactured housing, underserved, and rural markets.

Manufactured Housing Association for Regulatory Reform (MHARR) ‘Targets’ Fannie Mae and Freddie Mac ‘Failure’ in FHFA Duty to Serve Listening Session

JULY 20, 2023

MHARR, in comments (copy attached) delivered to a Federal Housing Finance Agency (FHFA) “Listening Session” on July 18, 2023, has called for the immediate “market-significant” support of manufactured home personal property or “chattel” loans under the statutory “Duty to Serve Underserved Markets” (DTS) mandate.

While chattel loans represent (and have consistently represented) nearly 80% of all new manufactured homes financed in the United States – and are specifically authorized by law for inclusion within manufactured housing sector DTS compliance programs – not a single manufactured home personal property loan has been supported by Fannie or Freddie under DTS since its enactment 15 years ago.

As MHARR made clear in its comments, this impasse, which leaves the vast bulk of the 

manufactured home financing market completely unserved in violation of the DTS mandate, is unacceptable and cannot continue. That is especially the case with the manufactured housing market having entered a severe downturn, beginning with the third quarter of 2022, which has seen the production of new HUD Code homes plummet year-over-year by a factor of more than 30%.

Consistent with its discussion of this matter with FHFA Director Sandra Thompson at a meeting on June 20, 2023, MHARR stated that the time for further alleged “research” and study by Fannie Mae and Freddie Mac is long past, and that both instead must begin now to provide market-significant support for manufactured home chattel loans, consistent with the explicit directive of Congress in DTS.

Otherwise, MHARR emphasized, if Fannie, Freddie and/or FHFA are unclear on what Congress meant by including chattel loans within the DTS mandate, they should be prepared to take this entire matter back to Congress for clarification that DTS means the entire HUD Code market, as well as a specific, close-in deadline for such market-significant chattel support.

As MHARR made quite clear, the time for delay and obfuscation is over. DTS means what it says, and now is the time for Fannie, Freddie and FHFA itself to live up to the obligations imposed upon them by law.


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