Issue link: https://read.dmtmag.com/i/684297
JUNE 2016 25 THE JOURNAL EASY TO USE • NO MESS • PERMANENT • High-tech, super-aggressive adhesive • User-friendly product with easy-to-remove liner • Permanent and easy way to mend holes, cuts, and tears • Manufactured Home/RV repairs, vapor barriers, tarp repairs, etc. PREMIUM BOTTOMBOARD TAPES SIZES PART NO. 2" - 18" ROLLS 2" X 180' FM-200T 2" X 108' FM-2108T *4" X 180' *FM-400T 4" X 108' FM-4108T *6" X 180' *FM-600T 6" X 108' FM-6108T 8" X 180' FM-800T 18" X 180' FM-1800 28" ROLLS *28" X 25' *FM-2825 28" X 50' FM-2850 28" X 100' FM-2800 ALSO AVAILABLE! DO-IT-YOURSELF KITS FM-2845 ZIPPERED ACCESS 18" X 18" TRAP-FLAP FM-1818 4" X 72" ZIP-STRIP FM-0472 6" X 72" ZIP-STRIP FM-0672 CUSTOM SIZES AVAILABLE! *DENOTES MOST POPULAR SIZES Look for the logo on the core of every roll of tape! THANK YOU FOR STICKING WITH FLEX-MEND! Visit FLEXMEND.COM for your nearest distributor, or for distribution opportunities, please call: 1.800.462.1775 F F No. 12 on Get It Quick Page No. 11 on Get It Quick Page industry-dominant lenders. In the wake of those meetings, the "new" DTS implementation rule is- sued by FHFA in December 2015 continued the blanket chattel exclusion from DTS and, with it, the pseudo-monopoly that uniquely benefits those industry-dominant lenders (and their corporate parents). As a result of all this, the vast majority of ac- tual and potential manufactured homebuyers are caught in a toxic "Catch-22," forced into unnec- essarily higher-rate loans (or excluded from FHA Title I loans) in part because the industry-domi- nant lenders, based on their own self-interest as beneficiaries of a government-maintained pseudo- monopoly – will not provide the type of critical performance information needed to fully-imple- ment both programs. At the same time, those lenders have not been shy about using industry re- sources in an effort to legitimize and protect higher-cost interest rates via legislation to amend restrictions in the Dodd-Frank law. Which brings us back to the April 2016 FHFA meeting. Following the revelation of the 2015 MHI-FHFA closed-door meetings by MHARR (based on verbal confirmation by FHFA) and de- mands for the public disclosure of all documents, notes, transcripts and other documents from those meetings, together with indications of possible legal consequences, the DTS meeting was rapidly- arranged by FHFA. And, in the meeting it did appear that FHFA could be reconsidering its op- position to DTS chattel in some form (particularly since its only "evidence" on the performance of manufactured housing chattel loans bears no re- lation, whatsoever, to current-day reality). But even the appearance of some possible movement by FHFA was more than offset by the position of the industry-dominant lenders. Since it's obvious that public opposition to DTS chattel is not viable, and that any sort of private opposition could ultimately become public record with strongly-adverse consequences, the indus- try-dominant lenders voiced nominal support for DTS chattel at the meeting, but also called for tight lender qualification criteria (i.e., restric- tions) as part of any such program to ensure that program lenders had "skin in the game." Obviously, some qualification rules for lenders to participate in any DTS chattel program will be needed to safeguard the integrity and legitimacy of the program. But those rules cannot be so re- strictive that they choke-off development of the type of genuine and vigorous competition in the HUD Code chattel market that DTS was designed to achieve. Which is why this call for "skin in the game" is all too familiar. The GNMA 10-10 "skin in the game" rule has perpetuated a pseudo-mo- nopoly in that program that has brought loan vol- ume to negligible levels. Thus, the invocation of "skin in the game" at the DTS meeting sent up a wave of red flags, as GNMA-type restrictions on a DTS chattel program would likewise maintain the existing pseudo-monopoly in that market, which uniquely benefits the industry-dominant lenders at the expense of consumers and the broader industry. In MHARR's view, the industry and con- sumers must demand a full explanation from FHFA as to why it appears to be working with pri- vate lenders to maintain a dysfunctional chattel market that places lower and moderate-income Americans in a "Catch -22" that forces them into higher-cost loans while excluding them from pro- grams such as DTS that Congress created specifi- cally to help them. Mark Weiss 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 pro- ducers of federally-regulated manufactured housing. Mark can be reached at 202-783-4087. T J

