STAND & BE COUNTED! Your one time opportunity to influence HUD!
Blog # 450; Copyright @ 11 June 2017; at community-investor.com/blog
Perspective: ‘Land lease communities’, previously manufactured home communities, & ‘mobile home parks’, comprise the real estate component of manufactured housing.’
This blog posting is the sole national advocate voice, official ombudsman, historian, research report, & online communication media, for all North American LLCommunities
To input this blog &/or affiliate with Community Owners (7 Part) Business Alliance, a.k.a. COBA7, use Official MHIndustry HOTINE: (877) MFD-HSNG or 633-4764
COBA7 Motto = ‘U Support Us & We Serve U! Goal of its’ print/online media = to
‘Not only inform & opine, but transform & improve MHBusiness model performance!
INTRODUCTION: We’re living& working in exciting times! This blog posting underscores that claim. Part I encourages YOU to make your concerns, about regulatory overreach, directly to HUD; Part II = How the manufactured housing industry continues to slowly recover, enduring ups & downs in monthly new home shipments; Part III = Another side of MHAction; & Part IV = Preparing for MHAlive! the Think Tank session, 7 August, at the RV/MH Hall of Fame in Elkhart, IN.
OK; Time Has Come For YOU to Make OUR Case!
Both national advocates for manufactured housing, the Manufactured Housing Institute (‘MHI’) and Manufactured Housing Association for Regulatory Reform (‘MHARR’), as well as Community Owners (7 Part) Business Alliance (‘COBA7), by dint (‘power or force’) of this blog posting, encourage YOU to comment directly (per MHARR), or indirectly (via MHI), & Soon Comment on’ Reducing the Federal Regulatory Burden’ on our industry and realty asset class!
What’s this all about? Simple. In recent correspondence to members and interested parties, MHARR & MHI, parrot HUD’s request for input to its’ newly formed Regulatory Reform Task Force relative to the following six categories needing attention and change:
• Result in the elimination of jobs
• Inhibit job creation
• Are outdated, unnecessary, or ineffective
• Impose costs that exceed benefits
• Create a serious inconsistency, or otherwise interfere with regulatory reform initiatives and policies
• Rely, in whole or in part, on data, information, or methods not publicly available, or are insufficiently transparent to meet he standard for reproducibility.
Are YOU ready and prepared to comment? There is a coming deadline!
In MHI’s case you will need to get in direct contact with the institute’s Government Affairs Department via (703) 229-6208 to request they sign YOU onto their prepared letter to HUD. Whether they do so, or not, ask for a copy of their ‘talking points’ pertaining to the above six topics, forwarded to you as YOU draft your own letter.
In MHARR’s case, they approach this important and timely matter in a slightly different fashion. While the aforementioned six bullet points are apt guidance, MHARR rightly addresses the following eight key points:
1. expanded in-plant regulation
2. on-site construction
3. Subpart I
4. federalization of installation
5. HUD’s 2010 interpretive Rule that restricted the role of the MHCC
6. the formaldehyde health notice
7. appointed non-career administrator
8. new/competitive monitoring contract
And if you’d like guidance as to how to incorporate these eight points into your correspondence, reach out to MHAR via (202) 783-4087
Furthermore, MHARR provides the following postal mailing address for your correspondence and commentary, recommending YOU use Fed-X to get it in front of the right people in Washington, DC.
Office of General Counsel
U.S. Department of Housing & Urban Development
Room # 10276
451 7th Street, S.W.
Washington, D.C. 20410-0500
OK, you’ve been provided the tools with which to speak out in behalf of the manufactured housing industry & land lease community real estate asset class. NOW, the question is, ‘Will YOU do it?’ I certainly plan to do so!
DEADLINE! Your concerns, either via MHI’s form letter, or one you draft and send yourself, MUST arrive at HUD no later than Wednesday, 14 June 2017. So, there really isn’t much time left for us to make our views known.
COBA7 presents Official MHShipment ‘#s & $s’ Report for April 2017
Institute for Building Technology & Safety (‘IBTS’) – HUD’s contractor for collecting ‘MHShipment Data’ reports 7,184 new HUD-Code homes shipped during the month of April 2017. Same total is also reported by HUD, MHARR & COBA7. Any other reported total is fallacious – unless fully explained and justified by the reporting source.
A couple ‘takeaways’ from this valuable COBA7 monthly report:
• While 7,184 new HUD-Code homes shipped during April compares favorably (total is ‘up’) with April 2016, this monthly total is the lowest of any monthly shipment total since the first of the year, including January, February & March.
• Using Dr. Stephen C. Cook’s ‘production value’, the 7,184 new HUD-Code homes shipped are valued at approximately $30,481,717. And, considering YTD total of homes shipped is 30,568 – their collective value pencils out to be $131,827,550+/-
• COBA7’s Top Ten HUD-Code home shipment states varies from other reports (which report cumulative totals as being: TX, FL, LA, AL, MI, SC, CA, NC, MS, & GA, in declining order of shipment volume. And together, these ten states shipped 62 percent of all new HUD-Code homes shipped during April 2017.
Editorial Note to Readers. COBA7 is carefully preparing a detailed expose’, describing perennial statistical reporting errors perpetrated and perpetuated by one or more national advocacy entities claiming to represent the manufactured housing industry. The point to this ‘alert’? If one is going to make fallacious and or misleading reporting claims, be prepared to support same with accurate data and disclosed methodology on every front. To do anything less, sullies not only that entity’s reputation, but the public image of the entire industry and related realty asset class, in the minds of federal and state legislators and regulators. Hopefully, corrective actions will be taken soon, and said expose’ will become unnecessary. GFA
‘MHAction’ Ride$ On The Back$ of Land Lease Community Homeowner/site lessees
Last week 55 of us sat in on a national conference call hosted by MHAction. It was an interesting experience, as this blog briefly reported in posting #459. Since then, we’ve come across the following informative and ‘telling’ info about MHAction.org.
According to Press Release Rocket, dated 5/3/2017,
“…MHAction is a non-profit based in Washington, D.C., part of the larger Center for Community Change. Although its website provides no details – not even a street address – a little cyber-sleuthing will uncover their Form 990 report (that all 501C-3s must file, and can be found at www.Guidestar.com). I shows the Executive Director Deepak Bhargava receives about $257,263 per year. At $24 per annum in dues, that means the first 10,719 mobile home park members just about fund his compensation. And the next four employees make a total of $1,004,904 – so it takes around another 41,871 mobile home park residents to send in their $24 to cover those folks. So, if you are among the first 52,290 members of MHAction.org, you’ve done a wonderful thing; you just covered the salary of five people who are living it up while you’re sitting in your trailer. But you better tell all your friends and neighbors to send in their dues quickly, as the Center for Community Change’s total payroll is more than $9 million. It’s going to take 375,000 members to cover that tab! I wonder if those who join MHAction.org are aware of how their money is being used?”
What this writer doesn’t tell us, but was disclosed during said conference call, is that an undisclosed portion of MHAction’s operating costs are covered by grants, etc., from other not for profit organizations.
MHAlive! the MHIndustry & LLCommunity ‘Think Tank’ to Meet at RV/MH Hall of Fame, Morning of 7 August 2017
OK, it’s time for YOU to start thinking about whether you want to be part of this rare business experience, i.e. sharing your thoughts and concerns about issues, trends, and threats to our business models. This MHAlive! Think Tank experience is the second of three , maybe four, opportunities for YOU to Input the Manufactured Housing Industry during 2017! The first occurred last month in Chicago, IL. Next one after the RV/MH Hall of Fame (Elkhart, IN) session will be during the 26th International Networking Roundtable, 6-8 September, in Indianapolis, IN. A fourth occasion may well occur at the rapidly growing SECO Symposium in mid-October in Atlanta, GA.
Now, here’s ‘the rub’. We already have 10 interested parties committed to participating in the 7 August MHAlive! Think Tank experience. We likely will keep the session to around 20-25 participants, to ensure participation by everyone present. If YOU are serious about attending, phone the Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764, or via email: email@example.com And, if you’re going to be in Elkhart, IN., that day, plan to remain for the RV/MH Hall of Fame Induction Banquet that evening! A record attendance is already expected (more than 700 RV & MH industry pioneers & leaders), i.e. ‘Anyone who’s anyone in the RV & MH business types will be present that evening!)
A little background. MHAlive! Think Tank isn’t the first time MHIndustry & LLCommunity aficionados have met to ID and parse issues, trends, and threats to our business models. The Urban Land Institute (‘ULI’) in year 2004, under the leadership of Randy Rowe, of Hometown & Green Courte Partners fame, launched the Manufactured Housing Communities Council (‘MHCC’), in some minds, a quasi (almost) Think Tank. Well, this experience continued for 11 years, until 2015, when ULI disbanded MHCC for lack of interest and active participation. In reality, however, the declining participation had as much, if not more, to do with the high cost of membership, travel, and meetings.
In any event, at this point in time, the MHAlive! Think Tank is a voluntary and no registration fee event. If there’s any charge at all, it’ll be to offset meeting room space, depending on seating requirements at the time, on 7 August, and billed to attendees later.
So, if YOU have the Best Interests of the manufactured housing industry and land lease community real estate asset class at heart, YOU should be at the RV/MH Hall of Fame all day, 7 August 2017. For more info about the Hall of Fame Banquet that evening, phone (574)293-2344. And remember this, of the ten RV/MH pioneers and leaders being inducted that evening, four of them are well known to LLCommunity folk: Michael Sullivan, CPM, of Newport Pacific in CA; Spencer Roane, MHM, of Pentagon Properties in GA; Christine Lindsey of UMH Properties in TN; and, RV guru David Gorin of VA. How can YOU not want to be present at 21565 Executive Parkway, Elkhart, IN., on 8/7/2017? Carolyn and I certainly plan to be present, not only to host MHAlive!, the Think Tank, but to fete Michael, Spencer, Christine, David, and six other honor deserving colleagues!
George Allen , CPM & MHM