MHIndustry gets Ombudsman & MHARR an Open Letter! Blog # 294 Copyright 2014 27 April 2014

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

Roles of this blog. ‘It’s the national advocacy voice, ombudsman press*, statistical research reporter, & communications resource for LLLCommunities in North America!’

How to input this blog & affiliate with Community Owners (7 Part) Business Alliance, a.k.a. COBA7, via Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764.

* Ombudsman press. ‘Non-government alliance handling complaints from the public.’

Introduction to this week’s blog posting…Part I. Finally, for the first time in manufactured housing industry history, we have an ombudsman (press) to field inquiries & complaints from homebuying customers, homeowner/rental homesite lessees in land-lease-lifestyle communities, and others! Part II. Just what it says, ‘An Open Letter to the…’ folk at the Manufactured Housing Association for Regulatory Reform. And Part III. Salient responses to one of the ‘Stories Not Posted’, but hinted at in last week’s blog. Whew! Another full plate of news and op/ed for you this week! And if you think this blog fare is ‘informative & compelling’, you should read the Allen Letter professional journal each month – along with Signature Series Resource Documents, or SSRDs, enclosed for affiliates of the Community Owners (7 part) Business Alliance! To subscribe (to the newsletter alone) or affiliate with COBA7, simply phone the Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764 today


Ombudsman for the Manufactured Housing Industry!


An Open Letter to the…

Manufactured Housing Association for Regulatory Reform, or



Responses to ‘A Story Not Posted’ but Described Last Week



Ombudsman for the Manufactured Housing Industry!

Didn’t see this one coming, but probably should have….

“I’ve been in factory-built housing since 1970, & have frequently wondered: ‘Why no national advocacy entity appoints, trains and sponsors an ombudsman to serve our industry’s unique customer/resident mix, the ‘manufactured home owner/rental homesite lessee’?” My opinion is, present day national advocacy bodies view themselves simply as lobbyists, not ‘fixers’ of industry problems, customer complaints and more.

(Hmm. Maybe if we’d had an ombudsman or two on board during the past seven decades, we wouldn’t have suffered the image issues faced over the years through today)

In any event, since the Community Owners (7 Part) Business Alliance was launched mid-December 2013, it’s fielded several inquiries and complaints from home owners/rental homesite lessees, land-lease-lifestyle community (A.k.a. manufactured home community owners/operators, and just last week, one from an MH/RV product vendor, who asked:

“Are park model RVs specifically excluded or exempted from the HUD Code?”

COBA7’s answer, with assistance from a manufactured housing state association executive, involved sending this inquirer a copy of current HUD language contained in 42 USC 5402(6), addressing the size and configuration requirements of HUD Code ‘manufactured homes’. Inquiry handled!

With that said, this blog posting is “COBA7’s Public Announcement of an ombudsman (press) presence in behalf of our industry’s customers & residents, as well as businessmen & women, nationwide & throughout Canada!”

What’s an ombudsman or ombudsperson? The term is generally associated with ‘a public official…who investigates complaints by private citizens against government agencies or officials’; but also can refer to ‘…a similar person in a corporation or other organization’ and business alliance. Webster.

Introduction of an ombudsman (press) presence falls within the ‘Seventh Part or Function’ embraced by the Community Owners (7 Part) Business Alliance. Specifically, it’s the ‘National Advocacy, when need be…’ function; again, a presence long needed by manufactured housing/land-lease-lifestyle communities, nationwide and in Canada. And since COBA7 is NOT a formal, national or international, not for profit entity per se, but an alliance of businessmen and women from all segments of the manufactured housing industry and LLLCommunity asset class, a variant of ombudsman, or ombudsperson, is in order, to wit: ombudsman (press), i.e. Where industry ‘problems, inquiries & customer complaints’ will play out, if or when need be….

How to access the ombudsman (press)? Simple. Respond via host website: &/or Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764. Also (317) 346-7156, & Ombudsman c/o Box # 47024, Indianapolis, IN. 46247 USA.

How’s research and resolution ‘problems, inquiries 7 customer complaints’ to occur? While details will be worked out as this ombudsman (press) initiative unfolds, the plan is to receive and log same at COBA7, then reach out to allegedly involved parties, offering assistance, and suggesting private resolution of said matters; and where appropriate, conduct further investigation and or research into the matter – as was the case this past week.

If you’re affiliated with COBA7, and would like to volunteer as an ombudsman or ombudsperson, let me know. Just like every other function, of the seven parts of COBA7, we’re actively seeking volunteers to share the increasing workload of 1) writing articles for the Allen Letter professional journal, 2) updating the dozen Signature Series Resource Documents or SSRDs, 3) preparing a new edition of the Land Lease Lifestyle Community Management text, even 4) teaching future Manufactured Housing Manager® or MHM® professional property management training and certification classes. How to volunteer? Phone GFA at (317) 346-7156.

IMPORTANT REMINDER. Mark your calendar to participate in the 23rd annual International Networking Roundtable, 10-12 September 2014, at the DOLCE Conference Center in Peachtree City, GA. Highlights this year? Two historic (Because this hasn’t been done before!) NATIONAL PUBLIC FORUMS, the morning of 11 September, re: ‘Future of manufactured housing as ‘housing’ (Not ‘trailers’!)’, & ‘Future of land-lease-lifestyle communities as ‘lifestyle’ & ‘investments’ (Not ‘trailer parks’ & ‘predatory $ feeding grounds’!). PLUS 20 seminar sessions, eight superb networking venues, and copious deal-making opportunities. But know this: we market this superb educational, networking, and deal-making opportunity only to last year’s attendees, COBA7 affiliates, and the ‘500 portfolio owners/operators’ mailing list. SO, if YOU want an ‘INVITE’, but are not on one of those three data bases, you must let us know via the Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764. Goal? 250+/- this year!

An Open Letter to the…

Manufactured Housing Association for Regulatory Reform, or


The following observations and comments are inspired by an MHARR Press Release dated April 15, 2014, titled: ‘MHARR Advances Its’ Final Push for Complete Implementation of the 2000 Reform Law’

To begin with, every businessman and woman whose career ‘is’ manufactured housing and or land-lease-lifestyle communities, should be very grateful to MHARR for the ‘Washington, DC Watchdog’ services and results they’ve provided, and continue to pursue in our nation’s capitol! It is my opinion; we would not have the HUD-Code manufactured housing industry we enjoy today – despite the new home shipment malaise since the turn of the century – if it wasn’t for the work of this national advocacy body.

But with that said, and again in my opinion, there’s much room for improvement in the agenda, focus, and very nature of their work as lobbyists. Let’s begin with a simple and easy matter. How many reading these words are aware the ‘2000 Reform Law’ referenced in the title of the aforementioned Press Release actually refers to the Manufactured Housing Improvement Act of 2000; and for some of us, abbreviated as MHIA@2000? Why begin an important recitation of a six bullet Action Plan for 2014, by ‘cornfusing’ readers with unclear terminology?

The six bullet points comprising MHARR’s Action Plan going into 2014?

• Implementation of the Full Status & Functionality of the Manufactured Housing Consensus Committee or MHCC. This body hasn’t met for nearly two years!

• Implementation of the New/Revised Subpart I. Here there needs to be more communication among parties within and outside HUD and the MHIndustry

• Implementation of New Energy Standards. Here the issue has to do with communication with the Department of Energy, and not being pre-empted by standards not reviewed for cost effectiveness.

• Implementation of Enhanced Federal Preemption. Past promises of program reviews and re-evaluation have not been kept, but are still needed.

• Implementation of Label Fee Increase. MHARR argued against implementation of ‘an administrative notice-only system’ that would contravene MHIA@2000, and take advantage of home manufacturers.

• Implementation of Proper Status of MH Program at HUD. Here the desire is to move the Title VI $ program from Office of Risk Management, over to the Office of Single Family Housing in accords with MHIA@2000.

When and where have you, blog flogger (reader) had this sort of Washington ‘insider’ information brought to your attention, even in abbreviated fashion like this? Probably rarely or never! And that’s the point. If you ‘make your living’ in this industry and via the LLLCommunity asset class, you owe it to yourself to ‘be informed’. To contact MHARR, phone (202) 783-4087. But don’t expect to ‘join up’, as this national advocacy body accepts only HUD-Code home ‘manufacturers’ as members.

Which brings up the next, somewhat negative aspect of MHARR. There’s a statement early in this Press Release that begs further discussion. It reads:

“the Association’s outreach on consumer financing showing one of the main reasons for continuing discrimination against manufactured homes and homebuyers is the lingering perception of manufactured homes as ‘trailers’ – which the 2000 reform law was designed to end by completing the transition of manufactured homes to legitimate housing – it became evident renewed and intensified MHARR engagement with HUD on completing implementation of the 2000 reform law (i.e. ‘MHIA@2000’) is both warranted and necessary.”

OK, that statement is fine, as far as it goes. The problem, in my opinion, is MHARR does NOT GO FAR ENOUGH! Out of one side of their mouth, so to speak, the association claims to desire to see HUD-Code manufactured housing ‘complete the transition to legitimate housing’ (presumably away from our ‘trailer’ vestigial heritage) – but only relative to their smaller ‘manufacturer’ perspective! And while they tacitly recognize (What they refer to as) post-production segments of the industry, they do little to fully understand, let alone cultivate support from these adrift folk, other than encourage their formation of a new, independent, national post-production advocacy presence in Washington, DC – or elsewhere.

For example, it’s well known most state association executives routinely read MHARR’s VIEWPOINT press. And many LLLCommunity owners/operators, as well as chattel finance lenders, and product/service vendors, regularly peruse The Journal, the Allen Letter professional journal, and Rishel Consulting’s online newsletter, to learn ‘the rest of the (manufactured housing) story’ – according to MHARR. But all that’s not enough. To be a true and effective industry leader takes ‘more than just talk’- and writing, to achieve, maintain, and apply such status!

So, what’s the answer? In my opinion, STOP (What appears to be) WORRYING about what any other national advocacy body might be doing, and focus on MHARR’s agenda (like these six bullet points). Look what that did for you this Fall, where GSE Reform legislation language was concerned! In addition, make it a point to learn more about the nature and needs of the post-production segment of the manufactured housing industry, solicit their support, and become a timely and valuable resource to them – to the point of stepping out and publicly describing the ‘Future of manufactured housing as ‘housing’, NOT ‘trailers’! Press Releases are Not Enough! However, if MHARR continues to run ‘hot & cold’, relative to post-production segments of the manufactured housing industry, it runs the real and serious risk of compromising its’ present day reputation, integrity and value to the industry and realty asset class as a whole!

Think I jest? Here’s what one owner (Not me) of several LLLCommunities has to say about MHARR and its’ manufacturer members:

“Smaller community owners feel a kindred spirit with smaller MH manufacturers. We are both entrepreneurs, often small businessmen and women. We property owners appreciate the personal service and attention we receive from small manufacturers. We also appreciate the flexibility small manufacturers have in designing and building homes. Similarly, we also share grave concerns about dominance by larger manufacturers and LLLCommunity operators, along with their attitude that ‘bigger must be better’. Lastly, we are especially sensitive to government regulations, red tape, and influence over our businesses and our lives.”

And this from yet another Community Owners (7 Part) Business Alliance affiliate (Again, not me!):

“I think he’s (Danny Ghorbani) very effective as a lobbyist for smaller home manufacturers – and to a big extent, the industry as a whole! However, the business model he’s most familiar with is the independent (street) MHRetailer of the past. My concern is, so much of what the industry does today, and even more so tomorrow, is in the hands of manufacturers selling new homes directly to LLLCommunity owners, who in turn sell the homes to the public. He knows very little about this new business model, and what he refers to as the ‘post production segments’ of our industry. Getting involved in the Networking Roundtable and SECO Symposium this Fall would be excellent opportunities for MHARR to learn about these important segments of the industry – especially the many smaller LLCommunities.” (lightly edited. GFA)

Bottom line MHARR?

1) Pursue the above-listed six bullet point agenda with vim and vigor!

2) Stop fretting over ‘opposition within’ (e.g. recent GAO interviews) as well as ‘competition outside’ (e.g. other building trade bodies) manufactured housing circles, and move ahead!

3) Learn all you can about the post production segments of the manufactured housing industry1 And when need be, serve as their unofficial proxy, or ronin voice, inside the capitol beltway until…..

4) In the end, MHARR will be a much more effective industry lobbyist in Washington, DC.

As usual, we solicit your response to this challenging and forward-thinking MOPHEAD*

End Note. * MOPHEAD is a 1980s era abbreviation for ‘manufactured housing opinion/editorial’, and metaphor for ‘a tool used to mop up MHBusiness messes’. MOPHEAD is from the time when I penned monthly columns for The Journal, and now defunct Manufactured Home Merchandiser magazines. Now you know….GFA


Responses to ‘a Story Not Posted’ but Described Last Week

Relative to ‘How Latter Day Mobe Dogs Eat Helpless & Hapless Gophers’ non-story:

“Sliding Occupancy & Higher Rent – Oh What A Great (business) Suicide Route!” NB

“You must know the California land-lease-lifestyle community (A.k.a. manufactured home community) market very well, to pen what you did in your blog. Here’s my take:

• California has (local) rent control

• California has high rental homesite rent rates, even for 40+ year old homes

• California has LLLCommunity owners/operators unwilling to upgrade their property’s image, by not renewing leases on old homes and buying new ones.

• California politicians pander to take away property rights to give to others, e.g. bastion of ‘feel good at others expense place’ in the entire U.S.

• California LLLCommunity owners raised site rents during the ‘Go Go days’ for one reason: they could. In the end, they killed the independent (street) MHRetailer business, and affected homeowner/site lessees in different ways, per rent control.

• California ‘chattel finance’ has a hard time financing resale homes in LLLCommunities. Now that new home market is primed, will LLLCommunities participate?

• California LLLCommunity owners must take control of their property(ies) now, following seven years of idleness.

Interestingly, the non-story cited in last week’s blog posting was NOT describing a LLLCommunity market survey re: California or Florida, but Michigan. Surprised?

And know what else we learned from this unpublished story? Who ‘really reads’ blog postings and who does not. It was so apparent when individuals started phoning and emailing, requesting FREE copies of the unidentified Market Survey. Conscientious LLLCommunity owners/operators want to know (Must know!) if their local housing markets are experiencing, e.g. ‘declining occupancy AND rising rents’, in order to take corrective or self-protective actions before business failure threatens or occurs. Did YOU request your FREE copy?


George Allen, CPM& MHM
Box # 47024, Indpls, IN. 46247
(317) 346-7156

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