Issue link: https://read.dmtmag.com/i/67690
cial policy initiative. As a result, this joint ef- fort offered senior HUD leadership a golden – in fact, unparalleled -- opportunity to "work with" the industry through its two national associations on three vitally important issues that could have been readily accommodated, thereby showing good faith toward industry members and the powerful, free-market, affordable housing solu- tions they offer, which have been all but ex- cluded fromnational housing policy and national housing programs under the Department's juris- diction. So what happened? Well, Secretary Galante conceded in an October 2011 follow-up confer- ence call that although the Title I securitization requirements are based largely on "perception" rather than hard data, the relevant performance information for such loans was not "organized" or maintained by HUD/FHA in a way that would be of any help in changing those require- ments or developing, at least for now, an ana- lytical model based on fact rather than outdated prejudices. On an appointed non-career ad- ministrator, the answer was made clear at the face-to-face meeting – "no" – even though the 2000 law makes the appointment of such an ad- ministrator a non-discretionary "responsibility" of the Secretary (along with conducting inspec- tions and monitoring). And on the simplest, easiest, least complicated request of the three – the restoration of collective national industry representation on theMHCC -- the industry got its answer, without even so much as a courtesy communication, when word dribbled out of HUD in April 2012 (with no public announce- ment) that the only new appointee to the MHCC would be a new member in the "user" category. Somuch forHUD's golden opportunity to co- operate and what passes for "conventional wis- dom." If anyone still needed it, this telling episode (along with many other examples) is proof that "go-along-to-get along" -- as con- trasted with MHARR's policy of close scrutiny, insistence on full and proper compliance with the law, transparency and accountability to both the Administration and Congress – simply does not work, but is instead used by regulators against the industry to get their own way, to the detri- ment of the industry's small businesses and con- sumers (and the benefit of only its largest conglomerates). What is needed instead, is a candid reassess- ment of this failed industry policy and recognition that the better approach – for the entire indus- try – would be for the industry's two national or- ganizations to act on the basis of the fundamental philosophy of holding all of the industry's regu- lators strictly accountable on all issues, includ- ing the Title VI federal program on production matters, and both public and private financing. The bottom line is that, as a great political philosopher once said, "there is such a difference between the way we really live and the way we ought to live that the man who neglects the real to study the ideal will learn how to accomplish his ruin, not his salvation." In MHARR's view, as a comprehensively regulated industry, for the industry to once again grow and thrive, it needs to "get real" about the way it deals with its federal regulators in the na- tion's capital. TJ Danny D. Ghorbani is President of the Manufac- tured Housing Association for Regulatory Reform. MHARR is aWashington, DC-based national trade association representing the views and interests of producers of federally-regulated manufactured hous- ing. Danny can be reached at 202-783-4087. We just wanted to say thank you For the sixth consecutive year, Wells Fargo has been voted Community Lender of the Year by the members of the Manufactured Housing Institute. We've provided more than $5.5 billion in financing for manufactured home communities since 2000. The members of MHI recognize us as the most dependable and experienced lender in the industry. We know you will agree. Call us today. Tony Petosa Trevor Brotman Nick Bertino Creighton Weber wellsfargo.com/mhc No. 9 on Get It Quick Page JUNE 2012 19 THE JOURNAL