Responses to Request for Information Pursuant to Eliminating Regulatory Barriers to Affordable Housing

Blog # 568 @ 17January 2020;

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, asset class historian, data researcher, education resource and communication media for all land lease communities in North America!

To input this blog &/or affiliate with EducateMHC, telephone Official MHIndustry HOTLINE: (877)MFD-HSHNG or 633-4764. Also email , & visit

Motto: ‘U Support US & WE Serve U! Goal: promote HUD-Code manufactured housing & land lease communities as U.S. source of affordable attainable housing! Attend an MHM class!

INTRODUCTION: Call this a potpourri of topics today! Part I is your glimpse of packages submitted to the White House council on eliminating regulatory barriers to affordable housing. Part II summarizes what occurred at the semi-public meeting of land lease community owners/operators during the Louisville MHShow. Part III is your hint of a resource possibly to debut during year 2021. And Part IV; well, it’s my need for input from you, relative to a unique career pattern among MHIndustry & LLCommunity executives. Enjoy!


Responses to Request for Information Pursuant to Eliminating Regulatory Barriers to Affordable Housing

At least one real estate, and two manufactured housing-related, national advocacy bodies have prepared and submitted formal replies to the White House Council on Eliminating Regulatory Barriers to Affordable Housing! Copies of packages were received from the Manufactured Housing Association for Regulatory Reform (‘MHARR’), The Real Estate Roundtable*1, and EducateMHC. At this writing we can only assume the Manufactured Housing Institute (‘MHI’) submitted a like formal reply to the White House Council request for input. As an MHI member, I’d have liked to seen and read it along with the three just mentioned.

Frankly, everyone in the HUD-Code manufactured housing business should read the comprehensive response researched, prepared and submitted by MHARR. It is textbook-like in presentation and content, and useful to boot (‘in addition’). To request a copy, phone (202) 783-4087. Talk to Mark Weiss and tell him ‘George Allen sent you!’

Four topics stood out in The Real Estate Roundtable white paper: support for more manufactured housing; YIMBY not NIMBY; need for GSE reform; and rent control as a non-solution. Specifically:

• “Promote strategies to increase production of manufactured housing.” Or, meet dire Need with more Supply! While recommendation described only one of the two (i.e. Freddie Mac’s Choice MH program, but not Fannie Mae’s MHAdvantage) realty-secured DTS (Duty to Serve) programs, it made NO mention of the continuing need for reasonable access to chattel capital by hundreds of owners of land lease communities nationwide, except for the following remark:

• “Deploy GSE reform efforts with a focus to improve liquidity for mortgages serving low and middle income homebuyers, and prioritize middle-income rental housing creation.” Chattel capital should be the focus of the second round of DTS program planning, but will it be?

• “Support ‘Yes in My Backyard” (‘YIMBY’) land-use policies….” – just as is the case with contemporary ‘zoning reform’. But why stop with morphing from NIMBY to YIMBY? Let’s also flip LULU from ‘Locally Unwanted Land Use’ to ‘Locally Useful Land Use!’, and BANANA from ‘Build Absolutely Nothing Anywhere Near Anything’ to ‘Build New Apartments (or Assets) Near Affordable’ housing need areas!

• ‘Rent Control is Not a Long-Term Solution to Address the Housing Crisis” Amen to that.

There was much more contained in The Real Estate Roundtable submission. Perhaps, in time, more of the content will appear publicly.

Then there’s the response submitted by EducateMHC. The distinguishing feature here, unlike the two aforementioned replies, was the point to carefully and clearly define the concept of ‘affordable housing’ in general, then Low Income Housing (‘LIH’) & Very Low Income Housing (‘VLIH’) in particular, followed by the six widely-used measures of said concept:

• Housing Expense Factor or HEF, commonly used in manufactured housing sales environments, using the ‘Ah Ha! & Uh Oh! Form’ for estimating housing price points.
• Housing Opportunity Index or HOI; formerly NAR & NAHB’s ‘Housing Affordability Index
• Housing Wage or HW measure
• Workforce Housing or WFH measure
• Income to Home Value Ratio or IHVR measure
• ‘One, or anyone, who believes they live in affordable housing’, a matter of perspective.

Much of the remainder of this response had to do with citing examples of how HUD-Code manufactured housing, and its’ sister lifestyle, the land lease community, when allowed to do so, outperform traditional, site-built housing time and again.

End Note.

1. “The Roundtable brings together leaders of the nation’s top publicly-held and privately-owned real estate ownership, development, lending and management firms with leaders of the major national real estate trade associations, to jointly address key national policy issues relating to real estate and the overall economy.” From correspondence date 17 January 2020.


LLCommunity Owners Convene During Louisville MHShow

It wasn’t a big meeting, it was not intended to be a big meeting. Rather, an opportunity for interested land lease community owners/operators to convene in a semi-public meeting, to identify and discuss various industry/asset class issues and emerging trends, troubling and otherwise.

What happened? Nearly 20 individuals met for 1 ½ hours late morning on the 16th of January.

• Dr. Leslie Gooch, CEO of MHI, and the institute’s VP of Communication were present and assured everyone of improved communication and advocacy, especially via the National Communities Council (‘NCC’) division.

• Some talk about MHI’s ‘new type’ HUD-Code manufactured home. identified as a CrossMod™, and appropriate for GSE’s realty-secured loan programs (i.e. MHAdvantage & Choice MH), but not for home-only financing needed for in-community placements.

• Passing mention of self-help measures, to influence and pressure acquirers of land lease communities from outside the industry, who have been raising site rental rates flagrantly.

• The most passionate conversations occurred when Spencer Roane, MHM, of Pentagon Properties in Atlanta, GA., called for a National Advertising Campaign – one funded with floor fees from manufacturers, to promote manufactured homes nationally, and land lease communities locally!

No plans were made for a future ‘continuation’ of this meeting. However, it was noted, every time land lease community owners caucused nationally in the past (e.g. 8/31/1993; 2/27/2008, 2/27/2009 & more), significant progress occurred, resolving troubling issues such as need for improved national advocacy; an ‘action plan’ to revive ‘everyone’, following the year 2009 nadir; and, agreement on the need for a Community Series Home design. So, continue to follow the news shared in this weekly blog posting series to be the first to hear of ‘the next time we get together’!

Is It Time?

In 1996, John Wiley & Sons, New York publishers, revolutionized the marketing and acquisition of (then) manufactured home communities, with the release of the first case bound text ever researched and authored on the specialized investment realty property type.

The 500 pages book, How to Find, Buy, Manage & Sell a Manufactured Home Community, when released, sold out within six months, there was so much demand for this information. A second printing sold out in another 12 months, and today the text is out of print – though used copies continue to be sold on, often for a higher price than the $95.00 charged 25 years ago! So, is it time to readdress this timely and strategic topic?

Given there are no quality HOW TO acquire land lease community texts on the market these days – discounting collections of real estate broker ‘war stories’ masquerading as guidance, consideration is indeed being given to preparing a new edition of the 1996 tome.

If YOU believe you have bona fide ability and experience in one or more skill areas, where land lease community marketing and sales is concerned, let me know – in writing via You see, the first edition featured input from more than a dozen individuals with such specialized skills in this area, but most have since retired or left the realty asset class. So, we’re not in the process of beginning to recruit new contributors for this project. Interested?


Allen Legacy column in MHInsider Magazine…

I’m seeking to identify manufactured housing industry executives and land lease community owners who served in the U.S. military during the 1960s & 70s, and served a combat tour of duty in the Republic of Vietnam during that timeframe. If this describes you, or you know someone with this background, please let me know via voicemail: (317) 346-7156. I think this would make an interesting and appropriate Allen Legacy column during the months to come.

George Allen, CPM, MHM

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