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NOVEMBER 2015 13 THE JOURNAL the securitization of all manufactured home loans in the event that GSE reform legislation winding- up Fannie Mae and Freddie Mac was, in fact, en- acted by Congress, MHARR's approach was castigated by one such lender, who publicly stated in July 2013: "… [I]t is a total waste of time to talk about DTS until Congress reaches a consen- sus on the GSEs. *** I think it is a million to one shot that FHFA and either of the GSEs agree to finance chattel manufactured homes while the larger issues remain unresolved." Ironically, at nearly the same time, former congressman Melvin Watt was nominated to re- place Edward DeMarco as FHFA Director – a move that MHARR fully and publicly supported, again in the face of criticism from the same indus- try sources -- based on prior experience with Mr. Watt as a leading proponent of the Manufactured Housing Improvement Act 2000. When subse- quently confirmed by the Senate in January 2014, MHARR welcomed Mr. Watts' selection, stat- ing: "[W]hile some in the industry were highly critical, MHARR was an early and enthusiastic supporter of Rep. Watts' nomination to head FHFA, an agency that, under its former leader- ship had developed and proposed a DTS imple- mentation rule that totally excluded manufactured home chattel loans and ever since has ignored DTS, without ever issuing any final implementa- tion rule. *** This change in leadership at FHFA could … produce a corresponding change in di- rection at the agency that may provide an oppor- tunity to administratively revive DTS as originally envisioned by Congress (i.e., including chattel loans)." Events (advanced by specific MHARR activi- ties) quickly proved this expectation to be cor- rect, as shortly after Director Watts' arrival, FHFA -- in a May 2014 report -- announced that DTS would be reconsidered by the agency. This commitment to re-open and revive DTS was further amplified at a July 2014 meeting between MHARR and FHFA officials, where MHARR, after reiterating the absolute necessity of includ- ing chattel loans under DTS, was advised that FHFA was working on a revised DTS rule and that Director Watt was asking all stakeholders to "wait" and withhold any further activity. Thus, at that point, through persistent MHARR efforts, the stage was set for a final DTS rule to implement DTS as envisioned by Con- gress. Since that time, however, FHFA has en- gaged in closed-door discussions on DTS with the Manufactured Housing Institute, certain lenders, and an ostensible "consumer" group that does not represent actual manufactured home owners. Al- though FHFA officials at a September 15, 2015 meeting denied "negotiating" with these parties on the content of a new DTS implementation rule, the officials refused to address any aspect of the discussions that did occur. Nor would they indi- cate whether a new proposed DTS implementa- tion rule – promised by the end of October 2015 – would include the GSE secondary market for manufactured housing chattel loans envisioned by Congress. Given the previous hostility of certain large in- dustry lenders (and their supporters) toward DTS and their public dismissal of DTS while pursuing Dodd-Frank reforms that would eliminate sanc- tions on current higher-interest non-securitized manufactured housing loans, any such closed- door discussions are – and should be – cause for significant concern. While MHARR will con- tinue to fight for the full securitization of chattel loans as part of DTS, if chattel loans are ulti- mately excluded again from any final FHFA rule – or significantly restricted, or, worse yet, left in limbo for the GSEs to decide themselves – it will be because the industry allowed DTS to be de- railed. In MHARR's view, DTS, and particularly the securitization of manufactured home chattel loans, are far too important to be left to special interests a nd back-room "discussions." Mark Weiss is President & CEO of the Manufac- tured Housing Association for Regulatory Reform. MHARR is a Washington, DC-based national trade association representing the views and interests of in- dependent producers of federally-regulated manufac- tured housing. Mark can be reached at 202-783-4087. T J The Choice is Yours Now you can receive your JOURNAL delivered directly to your computer each month or you can still receive the printed version. The choice is yours. Contact our office, give us your e-mail address and it will be delivered directly to you FREE. By signing up for the e-mail delivery of your magazine you will receive your issue quicker than by mail. The online version is exactly the same as the printed version. Call or e-mail your request to: 706-655-2333 or news@journalmfdhousing.com August 2014 The Magazine For Manufactured & Modular Housing Professionals THE OURNAL J SCOTT STROUD SCOTT STROUD It's All About The Lifestyle ED HICKS ED HICKS "Old Persons" and Pride in MH Next Month F i n a n c i a l F o c u s Ed i t i o n September 2014 The Magazine For Manufactured & Modular Housing Professionals THE OURNAL J RV/MH Hall of Fame Inducts Class of 2014 \ 6 inancial ocu$ F F 2014 \ 15 Congratulations Tom Kern, Founder & CEO of Style Crest Products July 2014 The Magazine For Manufactured & Modular Housing Professionals THE OURNAL J GEORGE PORTER GEORGE PORTER Fit for the Purpose Intended FRANK ROLFE FRANK ROLFE New Face of Affordable Housing