“Shh! Be Quiet.” or No, “Be a MHActivist!”
“Shh! Be Quiet, and it all might go away.”
MHI’s ‘Sprinkler Proposal’ to the MHCC, & the NSAC – III Caucus cum MHInitiative, ‘How to Save Our Industry?!’, likely 27 February 2012.
“Step up & do ‘your part’ as an MHActivist!”
It is not too late to 1) tell HUD know what you think their Research Policies should be, going forward; 2) attend the first National Summit for Independent ‘street’ MHRetailers & in – Landlease Community Home Sales Center Operators; and, 3) participate in the 23rd annual ALLEN REPORT, a.k.a. ‘Who’s Who Among Landlease Community Portfolio Owners/operators Throughout North America!’ And all that’s ‘just for starters….’
But FIRST, important Breaking News!
If you’re a lender or financier, of any sort or to any degree, relative to self – finance methodologies (i.e. ‘buy here – pay here’, ‘captive finance’, maybe even lease – option) of the chattel (personal property) capital variety, you’ll likely want to acquire a copy of the Rishel Consulting Group’s digest of the recently released CFPB Examiner’s Manual. This digest contains material relating only to manufactured housing. As the Consumer Finance Protection Bureau (‘CFPB’) recently opined, ‘Non – depository lenders (i.e. those described in the previous sentence) will conform to the same rules, regulations, and standards that banks and credit unions are currently subject to.’ To order this $500.00 resource, phone Donna Rishel @ (217) 899-9268. Credit card orders only.
OK, now onto the gist of this week’s blog…
Last week’s BEBA (Blast Email Blog Alert) read, in part: ‘Own landlease community (ies)? MUST READ MHARR’s 10/21 Update, & MHI’s 10/21 Week in Review, to learn why MHCC ‘sprinkler proposal’ puts YOU at risk of future liability…’
I’ll admit that’s a sketchy lead – in, but it was worded to spur you to action, i.e. to contact either or both national manufactured housing advocacy bodies, to request and read copies of their respective communiqués, then ponder the consequences of said ‘sprinkler proposal’ on your own. How many of you did so?
In any event, here’re excerpts from one of the subject communiqués and an email exchange I had with a representative from one of the aforementioned bodies late last week, the same day I effected the final edit to last week’s blog posting and composed the aforementioned BEBA:
• From MHARR’s Washington Update. “In a move that could ultimately open the door to an across – the – board federal fire sprinkler mandate, the Manufactured Housing Consensus Committee (‘MHCC’) at its’ October 18 – 20, 2011 meeting, voted to accept and recommend to HUD a Manufactured Housing Institute (‘MHI’) – proposed federal standard that “establishes the requirements for the installation of a fire sprinkler system in a manufactured home.” Interestingly, “The vote in favor of the sprinkler proposal came just one day after the National Fire Protection Association (‘NFPA’) was forced to concede that today’s manufactured homes are as fire – safe, and even safer, than site – built homes.”
• From an email received from MHI’s National Communities Council division VP & Executive Director Lisa Brechtel: “…there is no mandatory requirement to install fire sprinklers in manufactured homes. In fact the proposal explicitly preempts fire sprinklers. …the proposal provides a uniform, voluntary design and construction standard for fire sprinklers should a consumer choose to purchase a home with this option.” Unfortunately, this response clearly ‘misses the point’, where LLCommunity folk are concerned; if not now, likely sometime in the future.
• From an email sent, by this industry observer (and landlease community owner) to MHI and NCC executives: “This new federal statute, and the related publicity, will potentially affect those of us ‘with skin in the game as landlease (nee manufactured home) community owners’. Sure, I don’t see an immediate impact on my property. But now, if I’m prudent – and I think I am, MHI, the NCC and MHCC have collectively, put me in the position of ‘further screening’ every home move – in, whether new or resale, as to whether it has a built – in sprinkler system. And in my case, warning them my otherwise attractive, functional rental property probably can’t support their ‘fire safety system’s need for higher water volume and pressure’; in effect saying, “Would you please sign this waiver, acknowledging the inferiority of my property’s infrastructure design and capability, and accept the increased liability potential to your home, in the event it catches fire while sited here?”
Bottom line? IF the MHCC’s fire sprinkler standard remains unchanged, characterize this serious advocacy misstep to being another unfortunate, self – immolation example of the Law of Unintended Consequences!
POSTSCRIPT. As late as Friday, 26 October 2011, MHI communications continue to ignore the issue of probable consequences of having fire sprinklers in manufactured homes sited in older landlease communities.
MHInitiative®. Gotten used to that new Allenism term yet? By way of review of last week’s blog posting announcement, MHInitiative® is the creative moniker given the evolving scope of two National State of the Asset Class caucuses, first held 2/27/2008 in Tampa, FL., attended only by landlease community owners/operators; and one held 2/27/2009 in Elkhart, IN., attended by a near – equal number of HUD Code home manufacturers and LLCommunity folk. This time around, likely on or about 2/27/2012, and somewhere in the southern Sunbelt, an MHInitiative® is being planned, and will be hosted as a national caucus for ‘anyone in the manufactured housing industry and landlease community asset class who are bona fide business owners and senior executives’ – willing to invest personal and corporate resources (i.e. time and travel expenses) to spend 1 ½ days, or 2 ½ days if necessary, in a brainstorming session focused solely on ‘How to Save Our Industry?!’
Based on heavy reader response to last week’s blog posting debut of the MHInitiative®, along with individuals previously committed to participate, we could hold the MHInitiative® ‘tomorrow’, and count on more than 100 seriously – concerned MHIndustry & LLCommunity businessmen and women MHActivists being present!
Speaking of MHActivism….
Did YOU respond to HUD’s request for Public Comment on HUD’s Research Agenda, described in last week’s blog posting? Well, several of you did! You sent me copies of your correspondence. Thank You for following my ‘lead’ in this effort.
I prepared three separate commentaries; one each on the ‘Homeownership & Finance’ category, with this focus: “It’s Time for HUD to Overtly Promote the very Factory – built Housing type it has Regulated since the mid – 1970s, i.e. HUD Code Manufactured Housing!”. This was my response to ‘Rental Housing’: “Before HUD addresses this timely goal, it should step to the fore and launch a nationwide initiative, seeking consensus among housing providers, lenders and regulators, regarding ‘affordable housing’ & ‘housing affordability’ definition, description, and means of measurement.” And finally, re: ‘Communities’, I opined, “Does HUD even know what a landlease (nee manufactured home) community is? If not, now is the time to learn, as HUD seeks a ready supply of inclusive and sustainable, affordable housing communities, free from discrimination.”
And here’s the Good News for you, loyal blog floggers (readers). The deadline for ‘your submission’ is 4 November 2011. So, as soon as you’re done reading through this posting, sit down and knock out a letter to HUD USER c/o Box # 23268, Washington, DC. 20026-3178. What to say? While it’s certainly ‘up to you’, why not parrot my suggestions, that HUD not only regulate our unique factory – built housing type, but for the first time in 35 years, start to overtly promote it, as our nation’s most affordable type housing; that before HUD talks and writes about ‘affordable housing’, they should know how to define, describe and measure it; and finally, ‘discover’ LLCommunities for the desirable, even affordable lifestyle, they provide!
Do YOU market and sell HUD Code manufactured homes via an independent ‘street’ MHRetail salescenter and or an in – landlease community home sales center? If so, seriously consider participating in the first ever, maybe even historic, National Summit for Independent ‘street’ MHRetailers and in – Landlease Community Home Sales Center Operators. This 2 ½ day event is being held 13 – 15 November 2011, at the Drake Hotel in downtown Chicago. For registration information, contact Bill or Chad Carr @ (800) 336-0339. I hope to see YOU there!
By the way, join me for some informal, no host, interpersonal peer networking, in the coq d’ or lounge (downstairs from the lobby) at the Drake Hotel, between 3 and 5PM Sunday afternoon, 13 November. It doesn’t matter whether you’re attending the aforementioned National Summit or not; if you happen to be in downtown Chicago that day, stop by to socialize and ‘talk shop’ with friends in the MH & LLCommunity business!
Also remember, the first public release of an extensive White Paper, on manufactured housing sales, prepared as a ‘backgrounder’ for participants in this national event, will appear as part of the November 2011 Allen Letter professional journal. To subscribe, phone, (317) 346-7156.
Hey, is it starting to get downright exciting around here, or is it just me?
Research and compilation of the 23rd annual ALLEN REPORT, a.k.a. ‘Who’s Who Among Landlease Community Owners/operators in North America!’ is well underway. We’re now making follow – up phone calls to portfolio ‘players’ listed in the 22nd edition, to ensure they’re ‘not left out’. SO, if YOU and or your firm owns and or fee manages five or more LLCommunities and or a total of 500+ rental homesites (in one or more properties), then YOU qualify for inclusion in this seminal collection of benchmark statistics, description of present day trends, and ‘all you ever wanted to know about our unique income – producing property type’ but didn’t know who to ask!
How to participate? Best NOW, to phone the MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764 or (317) 346-7156 or email: email@example.com What happens? I’ll fax you the standard questionnaire; you complete it ASAP; and fax it back to me via (317) 346-7158. It’s as simple as that! Hope to hear from YOU soon!
George Allen, CPM®Emeritus, MHM®Master
Consultant to the Factory – built Housing Industry &
The Landlease Community Real Estate Asset Class
Box # 47024, Indpls, IN. 46247 (317) 346-7156.