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AUGUST 2014 11 THE JOURNAL Just A Click Away Great News!!! Now you can get the leading magazine for the Manufactured & Modular Housing Industries online! www.journalmfdhousing.com June 2013 The Magazine For Manufactured & Modular Housing Professionals THE OURNAL J omes P A R A D E of H 2 0 1 3 July 2013 The Magazine For Manufactured & Modular Housing Professionals THE OURNAL J MHARR Executives And GAO Officials Meet Exclusive to THE JOURNAL MHARR Executives And GAO Officials Meet October 2013 The Magazine For Manufactured & Modular Housing Professionals THE OURNAL J (( RD ANNIVERSARY "Thank You" to all of our readers and advertisers for 33 great years! September 2013 The Magazine For Manufactured & Modular Housing Professionals THE OURNAL J FINANCIAL 2013 Focus Focus FINANCIAL • 21st Mortgage Corp. • Beech Street Capital • CIS Home Loans • CU Factory Built Lending • Monroe & Giordano LLC • Security Mortgage Group LLC • Tremont Realty Capital • U.S. Bank MH Finance • Wells Fargo Call 1-706-655-2333 About Advertising Opportunities form Subpart I, ultimately became the basis for MHCC Subpart I reform recommendations that were adopted, in large measure, in a final rule issued by HUD on October 1, 2013. Unfortunately, though, with no appointed non-career program administrator in place at that time, the resulting leadership vacuum was filled – as it has been so many times in the past -- by the program's contract enforcers (and others). Thus, while the final Subpart I rule adopted most of the MHCC's recommenda- tions, it included a major unilateral change – a requirement for IPIA reviews of manufacturer Subpart I paperwork on "at least monthly" basis. And the initial results are unacceptable, particularly to smaller industry manufacturers that – like all small businesses -- are always dis- proportionately impacted by excessive regula- tion. Consequently, while the final Subpart I rule takes a step forward in adopting reforms first developed and proposed by MHARR over a decade ago, it takes two steps backwards in mandating additional, virtually non-stop, ex- tremely costly, paperwork reviews. So now, even with a new program administrator in place, trying to cope with and address, as quickly as possible, years-worth of accumulated regulatory issues, HUD finds itself with a "hot potato" tossed into its lap, facing multiple in- terpretations and "rump meetings" as PIAs, the program contractor and even some manufactur- ers scramble to put their own "spin" on the new Subpart I. And yet – again -- none of this does any- thing to help protect consumers. It simply ex- tends and expands a costly and unnecessary system that is a throwback to the industry's "trailer" origins and has no place in a regulatory system for permanent homes. Simply put, the industry (and particularly manufacturers – and even more particularly smaller manufacturers) trying to recover from its worst-ever decline and just starting to see a hint of daylight, cannot take this anymore. With the industry today making its best homes ever and with virtually airtight protection for consumers including dis- pute resolution and installation regulation under the 2000 reform law, it is high time that Sub- part I be rethought, re-evaluated and prefer- ably repealed altogether. Consequently, MHARR has been conducting an intensive analysis of this matter and will prepare a Subpart I repeal proposal and White Paper that will be presented to the MHARR Board of Directors at its Fall meeting for consideration. In MHARR's view, Subpart I does nothing for consumers and as a throwback to the indus- try's long-gone "trailer" past, is not appropriate in a housing law. Danny D. Ghorbani is President & CEO of the Manufactured Housing Association for Regulatory Reform. MHARR is a Washington, DC-based na- tional trade association representing the views and interests of independent producers of federally-reg- ulated manufactured housing. Danny can be reached at 202-783-4087. Got News? Send your company press releases to: news@journalmfdhousing.com T J