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August 2013

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factured home loans under a reformed federal guarantee. And, in fact, there are aspects of the pending Senate bill where support for manufactured home chattel loans could readily be included, such as the proposed Market Access Fund, which would authorize and provide support for new types of activities such as grants, loans, credit enhancement and other forms of credit support for "sustainable homeownership and affordable rental programs. . . for the benefit of families whose income does not exceed 120 percent of the area median income." On this point, there is one technical concern to which the industry and consumers should pay attention. Various GSE reform proposals refer either directly or implicitly to the possibility of the loan originator taking all or a major portion of the risk sharing. Thus, as the concept of GSE risk sharing develops, it is important that there be broadly available sources of such a third party guarantee for manufactured homes. It is important that the essential private risk sharing role not be limited to just one -- or a handful -- of loan originators with deep enough pockets to provide the private sector guarantee, thus effectively freezing in place the current unacceptable status quo in the manufactured housing market, which has held-down industry production at historically low levels for years. Very simply, a balkanized market in which mortgage financing is not broadly available is not good for competition, not good for the industry, or manufactured housing consumers. Above all, it is important that the manufactured housing industry and its allies not get caught in the weeds, not to become obsessed with the parlor game of how, when and where Congressional GSE reform will take place. The most important communication that the industry can make to Congress and the FHFA is to make clear how important manufactured housing is to the nation's housing markets and particularly to moderate and lower-income families, first-time homebuyers and seniors for whom this may be the only way to own a home. These stakeholders are a powerful constituency and, if organized, cannot be easily ignored by Congress. If the case is made for why GSE reform needs to take place in a way that maintains and expands personal property, real estate and hybrid loans for manufactured homes, Congress will find a way to make sure this happens in any legislation that is ultimately adopted. And, if Congress makes it clear that it wants to see a vigorous role for this sector, the private sector will respond in its risk sharing role, since we know these loans, properly priced, can be profitable. It is not clear how long congressional GSE reform will take. But the debate has begun in No. 9 on Get It Quick Page earnest and the industry cannot afford to sit on the sidelines. Proposals solidify into legislation, and congressional committees start taking action on such legislation, which then becomes difficult to change. One thing, however, is clear, and that is in the wake of the 2000 reform law, the industry's homes have come of age and today's manufactured homes and manufactured home consumers are entitled to the same type of nondiscriminatory treatment afforded all other homebuyers. Ultimately, moreover, the focus of the industry and consumers of affordable housing should not and must not be locked into one single financing issue at the expense of others that are equally important. In MHARR's view, the manufactured housing industry and consumers of affordable housing need to ensure that broad, expansive and competitive sources of all types of manufactured home financing are allowed and facilitated as GSE reform moves forward. T J Danny D. Ghorbani is President & CEO of the Manufactured Housing Association for Regulatory Reform. MHARR is a Washington, DC-based national trade association representing the views and interests of independent producers of federally-regulated manufactured housing. Danny can be reached at 202-783-4087. AUGUST 2013 13 THE JOURNAL

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