HUD’s Contretemps; &, Official WHITE PAPER

COBA7® via Blog # 311 @ 24 August 2014 Copyright 2014

Perspective. ‘Land-lease-lifestyle communities, a.k.a. manufactured home communities and ‘mobile home parks’, comprise the real estate component of manufactured housing.’

This blog posting ‘is a national advocacy voice, ombudsman press*, statistical research reporter, & online communications resource for all LLLCommunities in North America!’

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.

*ombudsman press. ‘Manufactured housing’s ronin, fielding inquiries, complaints, etc.’

Introduction to this week’s COBA7® blog posting at website:


Your Responses to ‘Consequences, Good & Bad, of LLLCommunity Consolidation’. Here’re a few responses to last week’s ‘tell all, true story’ regarding pros & cons of LLLCommunity consolidation during the past four decades. Did I miss anything?


HUD’s Contretemps (‘an embarrassing occurrence’) Hobbles Affordable Housing! The Good News is, ‘all of a sudden’ everyone in MH wants on this bandwagon, even an online commentary heretofore critical of MHARR, still not crediting them in any way!


Official WHITE PAPER is ‘in the mail’ to 23rd Networking Roundtable registrants. Mailed 100 copies the first week! It’s chock full of interesting & useful information.



Responses to ‘Consequences, Good & Bad,
of LLLCommunity Consolidation’

“Very powerful George, Nice work.” MH executive

“As usual, I enjoyed flogging your blog this morning. The information on LLLCommunity consolidation was really interesting.” State MHAssociation executive

“As usual, you did a good job of calling our attention to trends that may well shape the future of the (MH) industry:

• Larger (LLLCommunity) operators ducking paying national & state association dues

• National advocacy association paying little attention to anyone but a few of the larger (LLLCommunity) operators

• More and more manufactured homes being bought and rented or sold by smaller (LLLCommunity) operators using creative financing, encouraged by hungry, out-of-the-box-thinking lenders

How long before this combination of trends creates a ‘new & perfect storm’, resulting in smaller (LLLCommunity) operators instructing HUD-Code home manufacturers to relay dues paid on homes these smaller operators buy, to entities who better represent their business interests?” This from veteran MHIndustry entrepreneur businessman

As a related aside; the Official WHITE PAPER being distributed to Networking Roundtable registrants, points out more than once, how land-lease-lifestyle community owners/operators are now oft and openly referred to as the ‘new breed of MHRetailer & lender’. The writer of the previous paragraph commentary has not seen or read said WHITE PAPER. So, an interesting confirmation of the latest paradigm shift within the manufactured housing industry and its’ LLLCommunity real estate asset class! GFA

And this from yet another manufactured housing entrepreneur businessman: “The dearth of chattel financing is changing the manufactured home community (‘LLLCommunity’) business model – especially that of the larger, multistate owners/operators. Renting homes on-site has, once again, become commonplace. ‘Park owned homes’ are no longer the bane of (real estate-secured) mortgage lending. Chattel finance default-related costs are now transformed into rental turnover and rehab costs. Property owners/operators no longer have the luxury of raising lot rent without considering the effect on house payments or unit rent. And finally, creative home acquisition financing is providing interesting new (funding) opportunities, especially for the smaller owners/operators of manufactured home communities (‘LLLCommunities’).”

If you missed reading last week’s blog posting, scroll back a week into the blog archives at the ( website and read of other ‘insider’ Lessons Learned. And hey; this is what two National Public Forums, the morning of 9/11, at the Networking Roundtable, are about: What’s happening in the manufactured housing & LLLCommunity arenas, & What can be done to shape our Free Enterprise futures?


HUD’s Contretemps
(‘an embarrassing occurrence’)

WHO recently penned (8/15/2014), and WHERE did they publish, this Challenge Goal for HUD-Code manufactured housing in the U.S. today?

“…ensure the bottom-line cost of manufactured housing is not needlessly increased by make-work regulation that has no place in this unique affordable housing program.”

The possible answers are: MHI in its’ WEEK IN REVIEW online message to members; a Jim Visser editorial in The Journal; a HUD communiqué; MHARR’s ‘Sobering Wake-up Call for HUD-Code (Home) Manufacturers…’; in the Allen Letter professional journal; Ken Rishel’s Manufactured Housing Chattel Finance online newsletter; or, a COBA7® memorandum to affiliates?

The ideal answer: This statement could and should be apropos for ‘all the above’, beginning with Department of Housing & Urban Development’s manufactured housing program administrator! However, that’s NOT where this Challenge Goal originated.

The answer: That statement was the final sentence in a 14 August 2014 memorandum from the Manufactured Housing Association for Regulatory Reform’s ‘Sobering Wake-up Call for HUD Code Manufacturers on Expansion of Unnecessary and Costly Regulation’.

If YOU haven’t read this three page summary of what appears to be, in this industry observer’s opinion, increasing (voluntary cum mandatory) abuse of the inherent affordable nature of our type factory-built housing, YOU should make it a point to do so! How? Phone (202) 783-4087 and request a copy of the 14 August 2014 memorandum.

Gist of what you’ll read?

1) How HUD is complicating and increasing regulatory compliance costs of programs (e.g. Subpart I) that should be sunsetting, considering “…consumer complaints and referrals to dispute resolution are – and have been – at minimal levels, and the industry is building its’ best homes?”

2) How HUD, to date, has not engaged in an (industry) costs/(homebuyer) benefits study and analysis re: “…massive expansion of in-plant regulation…” – and how it affects, again, the inherent affordable nature of this type factory-built housing!

3) A recitation of 1990s MHIndustry ‘history’ precipitating the Manufactured Housing Improvement Act of 2000, and how today’s missteps by the MHIndustry & HUD alike, mirror the truth of the sage observation: “Those who fail to learn the lessons of history are bound to repeat them!”

4) And finally, of the increase in HUD certification label fee from $39 to $100, a 156% increase in effect by mid-September. It has been simply amazing, to me, there’s not been more of a ‘hue & cry’ from HUD-Code home manufacturers over this matter.

Has anyone else spoken out or written about these timely, salient and troubling matters?

MHI’s WEEK IN REVIEW online message to members, in a passage labeled ‘HUD Issues Final Rule to Increase Label Fees’ plows much of the same ground on this particular topic, pointing out that “HUD said it will consider reducing the label fee if there is an unpredicted increase in production.” Fat chance of that happening until ‘easy to access’ chattel capital returns, if ever, to the HUD-Code home manufacturing scene.

The online message also alerts members that “HUD plans to seek contractual support to assist in the administration of the installation standards program in states that have not established approved programs” & “…the dispute resolution program in states that have not established approved dispute resolution programs.” Here’s yet another bromide that certainly applies: “If it ain’t broke, don’t fix it!” So HUD, leave the states alone!

One also wonders, after reading WEEK IN REVIEW, why there’s been NO brouhaha, from MHI’s manufacturer members, about the aforementioned lack of an (industry) costs/(homebuyers) benefits study and analysis by HUD? Perhaps it’s easier for the Big-3C HUD-Code home manufacturers to absorb increased production (inspection & labeling) costs, associated with enhanced regulatory oversight, rather than resist them. Hmm. Is there a history lesson here, say circa 1985? Yes there is….

SO, why is all this labeled as a HUD Contretemps, or ‘an embarrassing occurrence’?

Simple. One would logically think the federal agency known for its’ manifold housing programs, providing shelter to disadvantaged and lower income citizens, at taxpayer expense, would be the government’s leading proponent of ‘affordable housing’! Yet, just the opposite appears to be true, as HUD pushes for the enhancement of unnecessary and costly regulatory measures at a time when, as MHARR so aptly states: “…consumer complaints and referrals to dispute resolution are – and have been – at minimal levels, and the (manufactured housing) industry is building its’ best homes.” One doesn’t get anymore ‘contretemp’ (embarrassed), than when caught between two such opposing views!

‘HUD’, if you’re listening; start PROMOTING manufactured housing, as America’s homegrown type ‘affordable’ factory-built housing, and STOP HOBBLING it with more regulatory oversight and increased production costs!

Know WHERE to effectively ‘draw that much needed line in the sand’? At and during the 23rd International Networking Roundtable, 10-12 September 2014, in Peachtree City, GA. WHY? Because there’ll be more than 200 land-lease-lifestyle community (A.k.a. manufactured home community) owners/operators, along with HUD-Code home manufacturers and lenders, present to hear and carry such a timely, dual thrust message back to the rest of the manufactured housing industry!

For more information, phone the Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764.


Official WHITE PAPER is ‘in the mail’

It’s 18 pages in length, 8 ½” X 11” in size, and sports a Kelly green plastic cover. The title? ‘Past, Present & Future of Manufactured Housing & Land-lease-lifestyle Communities in a WHITE PAPER…’an authoritative report giving information on an issue’.’ If you’ve registered for the upcoming (10-12 September 2014) 23rd annual International Networking Roundtable, then one is in the mail to you. Only exception is where there’re multiple registrants from the same company. One copy has been sent now, and additional copies will be distributed the morning of 9/11, before we commence the two National Public Forums – for which the WHITE PAPER was penned in the first place.

WHITE PAPER content? Here’s a recitation of the first page of this CONFIDENTIAL document. But first, know this: There’s more information about manufactured housing and land-lease-lifestyle communities in this document than in any other previously published reference. It alone is worth the price of attending the networking roundtable! Now…

Setting the stage. Here are recent, unsolicited passages characterizing contemporary attitudes and opinions relative to manufactured housing and land-lease-lifestyle communities (A.k.a. manufactured home communities)

Bob Vahsholtz writing in DURELING CURVES, about manufactured housing:

“In the near term (post 2014), our best cost advantage lies with handsome singles, small enough to keep the monthly cost of our homes to the consumer well below the stick competition’s apartments.” P.98
“The MH industry needs to think outside the square (box).” P. 109

A veteran LLLCommunity portfolio owner/s view of home manufacturers:

“HUD-Code (home) manufacturers have identified, at mid 2014, two very distinct buyers of their product: ‘Big Box = Big Bucks units’ and ‘lower-priced’ (Community Series) homes.” SR

Point? ?Depending on who one talks to in the MHBusiness; many believe, LLLCommunities need ‘handsome, small (affordable) singlesection homes’ to fill vacant rental homesites; and, home manufacturers, given their choice of models exhibited at regional home shows, prefer ‘big money’ shipping ‘big boxes’ (multisection homes) for placement on scattered building sites conveyed fee simple, and into subdivision.

Let’s preview what follows from here:

Part I summarizes past and present manufactured housing & LLLCommunities via a dozen descriptive categories apiece.

Part II imagines the ‘future’ of both business models, in light of past performance, contemporary issues & trends, and probable ‘future ‘prospects.

All of which begs this question: Just what will our individual (business) and collective (industry/realty asset class) ‘futures’ be like, looking to year 2015 and beyond? ‘Answers to that question’ is the anticipated outcome of the two National public Forums scheduled the morning of 9/11/2014! Be there & Be ready!


There you have it, the introduction to this fact-filled Official WHITE PAPER describing the manufactured housing industry and land-lease-lifestyle community realty asset class, Past, Present, & yes, Future.

Might as well put our industry’s two national advocacy bodies ‘on notice’ here, as to how they might/should look to the future, once the results of said National Public Forums are published. What follows is from page # 15:


Where to go from here? There’re likely several alternatives, but here’s…

One suggestion. MHARR, MHI & COBA7® to jointly announce, plan & host, a National Strategic Planning Session at an easily accessible, reasonably-priced meeting facility, using a capable, experienced, motivated facilitator, to lead a two day brainstorming and planning caucus.


And at this point no fewer than three historic examples of past Strategic Planning Sessions, within the MHIndustry/LLLCommunity asset class, are recalled, citing the leadership, proceedings, and wisdom – respectively – of now retired MHI Chairman Barry McCabe, the first National State of the Asset Class caucus, and Randy Rowe.

The Official WHITE PAPER concludes with this suggestion to MHARR, MHI, & COBA7®. That “They Call for a National Strategic Planning Session by the end of 2014 or early during year 2015!”

Want a copy of this Official WHITE PAPER? Then plan on attending the 23rd International Networking Roundtable next month! At present, there are no plans to distribute this document, for sale or for free, beyond this audience. To register, use the program brochure at or phone the Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764 and request it. Again, the 18 page, Official WHITE PAPER is FREE to Networking Roundtable registrants, presenters, and guests.


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