Issue link: https://read.dmtmag.com/i/657319
APRIL 2016 18 THE JOURNAL Wells Fargo Securities is the trade name for the capital markets and investment banking services of Wells Fargo & Company and its subsidiaries, including but not limited to Wells Fargo Securities, LLC, a member of NYSE, FINRA, NFA and SIPC, Wells Fargo Prime Services, LLC, a member of FINRA, NFA and SIPC, and Wells Fargo Bank, N.A. Wells Fargo Securities, LLC and Wells Fargo Prime Services, LLC are distinct entities from aliated banks and thrifts. © Wells Fargo Bank, N.A. All rights reserved. WCS- wellsfargo.com/mhc Our experience and dedication to this unique industry have made us the financing leader nationwide for manufactured home communities for more than years. We'll work with you to help find the best solution for your financing needs. Contact us today. Balance sheet lending | Fannie Mae DUS® Lender Freddie Mac Program Plus® Seller/Servicer | CMBS lending Correspondent lending NOT FDIC-INSURED • NO BANK GUARANTEE • MAY LOSE VALUE Lew Grace • -- • lew.grace@wellsfargo.com | Tony Petosa • -- • tpetosa@wellsfargo.com There for you, now as in the past Manufactured home communities No. 10 on Get It Quick Page HUD to defer enforcement of the rule (starting on March 7, 2016) for 12 months, while the MHCC reviewed its mandates and related costs for possible revisions. Just a few days later, MHARR became the first national industry organization – in a February 2, 2016 communication to HUD – to fully support the MHCC's resolution and reiterate the MHCC's call for a deferral of enforcement of the final rule, stating: "If enforced by HUD in its current state, as was emphasized by the MHCC and other par- ticipants at the Louisville meeting, the September 8, 2015 rule would further depress manufactured housing production -- already at historically low levels – would unnecessarily increase costs borne by consumers, and would cripple an important and expanding HUD Code market. Conse- quently, deferred enforcement, pending neces- sary and fundamental corrections, is clearly warranted. HUD, moreover, to help both the in- dustry and consumers, should allow existing AC approvals and the existing AC system for on-site construction to continue indefinitely pending cor- rection of the September 8, 2015 rule." In light of all this, one last set of questions is warranted. To start, why would the current HUD program Administrator, having been in- formed unanimously by all the program stakehold- ers on the MHCC, and by both national industry organizations that the final on-site rule is ill-con- ceived, unduly costly and harmful for both the in- dustry and consumers, continue to press ahead with its full (and extremely costly) implementa- tion, subject only to a six-month "transition" pe- riod? Could it be because she would prefer to see manufactured housing limited to its current mar- ket and current consumers? Could it be that she is beholden to the revenue-driven contractors that dominate the program? Does she realize that by pressing this fundamentally flawed on-site rule she is helping industry competitors (i.e., site- builders, realtors and the rental housing industry, etc.) to the detriment of the manufactured hous- ing industry (and consumers) she is charged by law with "facilitating" and helping? And – on a related topic -- do MHI members know that their organization's staff at the MHCC meeting thanked – and asked other attendees to "thank" -- HUD and the Administrator after the Committee had voted unanimously for the 12- month deferral and re-consideration of the HUD final rule? Apparently not, because when they fi- nally became aware of this matter – after MHARR's February 2, 2016 communication to HUD – MHI was finally forced by its members to go on record in support of the MHCC's resolution on February 22, 2016…taking three weeks for members to overrule their staff. In MHARR's view, the program Administra- tor's actions regarding this and a host of other matters raise serious questions and confirms, yet again, the wisdom of Congress in mandating the appointment of a non-career administrator for the federal manufactured housing program under the 2000 reform law. Mark Weiss is President & CEO of the Manufactured Housing Association for Regulatory Reform. MHARR is a Washington, DC-based national trade association repre- senting the views and interests of independent producers of federally-regulated manufactured housing. Mark can be reached at 202-783-4087. \ 12 we respect that. Conclusion Evictions are a fact of life. How we all approach them has a huge bearing on our bottom line. We encourage everyone to constantly test new methods and to share those results. As the court environment changes, we all need to stay on top of strategies to keep our costs low and our collection results successful. Frank Rolfe has been a manufactured home community owner for almost two decades, and currently ranks as part of the 6th largest community owner in the United States, with more than 17,000 lots in 22 states in the Great Plains and Midwest. His books and courses on community acquisitions and management are the top-selling ones in the industry. To learn more about Frank's views on the manufactured home community industry visit www.MobileHomeUniversity.com. \ 13 T J T J