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July 2016

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JULY 2016 13 THE JOURNAL R E C E N T C L O S I N G S $34,000,000 Suburban Chicago, non-recourse Bridge Loan with earnout. $11,500,000 Des Moines, Iowa. 4 park portfolio. Regional bank lender RQD\HDUƓ[HGUDWHRIMXVWRYHU. $6,000,000 Cedar Rapids, Iowa was IXQGHGIRU)LYH6HDVRQV0+3 $6,300,0005HQWDO+RPH3RUWIROLR KRPHV\HDUWHUP Drastic New CMBS Market Rules are Coming! Close Your CMBS Loan This Summer! By the end of this year new CMBS rules will curtail your access to new loans and WKHFXUUHQWIDYRUDEOHPDUNHWLQWHUHVWUDWHV:HDUH\RXUƓQDQFHH[SHUWVFRQWDFWXV LPPHGLDWHO\ WR ORFN LQ \RXU IDYRUDEOH UDWHV DQG WR HQVXUH WKDW WKHVH ƓQDQFLDO LQVWUXPHQWVZLOOEHDYDLOEOHWR\RX WE CLOSE LOANS! ABOUT MAVERICK 0DYHULFN &RPPHUFLDO 0RUWJDJH ,QF DUUDQJHV D ZLGH YDULHW\ RI FRPPHUFLDOUHDOHVWDWHORDQVUDQJLQJIURPWR IRULWVPLGGOHPDUNHWUHDOHVWDWHGHYHORSHUDQGLQYHVWRUFOLHQWV $1M+ MHP Loans Acquisition Loans 5HƓQDQFLQJ/RDQV Finance Co. Loans $SDUWPHQWV Industrial Bridge Loans )L[HG/RDQV Mezzanine Loans 2IƓFH Self-Storage 0L[HG8VH :HƓQDQFHDOOSURSHUW\W\SHV Please contact Ben Kadish at 312-268-6000, 312-953-4344, or at ben.kadish@mavcm.com Des Moines, Iowa. 4 park portfolio. Regional bank lender RQD\HDUƓ[HGUDWHRIMXVWRYHU. Cedar Rapids, Iowa was 5HQWDO+RPH3RUWIROLR 5HƓQDQFLQJ/RDQV No. 10 on Get It Quick Page face, particularly as it – again -- does not include any testing, enforcement, or regulatory compli- ance costs. And, even more importantly for smaller industry businesses, DOE concedes that "since the proposed standards could cause com- petitive concerns for smaller manufacturers, DOE cannot certify that the proposed standards would not have a significant impact on a substantial number of small businesses." (Emphasis Added). Yet, despite all this, the development of this draconian rule has been supported, assisted and materially advanced by MHI and larger manufac- turers, at every step, consistently since 2010. That support includes, but is not limited to: re- viving a moribund DOE standards development process in 2010 that had been brought to a stand- still by MHARR efforts; closed-door collaboration with DOE on a selectively leaked 2011 "draft" proposed rule; closed-door collaboration with DOE in 2013 and 2014 – after the 2011 "draft" proposed rule had been rejected by the Office of Management and Budget (OMB), consistent with MHARR objections -- to railroad a supposedly "new" proposed rule through an obscure DOE ap- pliance standards committee using a sham "nego- tiated rulemaking" with "a minimum of meetings;" and collaborating with DOE, directly and through its "research" affiliate, the "Systems Building Re- search Alliance" (SBRA), to promote DOE reg- ulation, mislead the industry and soften industry opposition to DOE regulation, including lucrative "research" contracts awarded by DOE to a busi- ness entity controlled by SBRA's Executive Di- rector. Much more detail on all of this will be presented in MHARR's comments opposing the proposed rule. For now, though, industry members and MHI members, in particular, should be question- ing why MHI would support and promote such a disastrous assault on the industry and its con- sumers. Is it because the industry's largest cor- porate conglomerates have shown they have the resources to cushion or even eliminate the impact of such drastic cost increases for their customers - - to the detriment of smaller industry businesses? Is it a convenient crony-capitalist opportunity to eliminate smaller competitors in one fell-swoop? And, given the fact that the draconian require- ments of this rule have not – and are not – being applied to other types of housing over the vast ma- jority of the U.S., is it being used to level-off the price advantage currently enjoyed by manufac- tured housing? Or is it simply poor judgment? With all of the setbacks that the industry con- tinues to suffer at the hands of HUD, the Federal Housing Finance Agency (FHFA) and now DOE, the question increasingly being asked in Washing- ton, D.C., is – when will industry members stand up, stop toeing the "company line," and join forces with MHARR to fight these tough battles in the nation's capital for the entire industry and the millions of American consumers who rely on affordable manufactured housing? Remaining silent during carefully choreographed meetings at lush resorts will simply not get the job done. MHARR, for its part, has – and will continue to – aggressively oppose the DOE proposed rule in all its aspects and in all available forums, and it is high time for every industry member to join this effort to block DOE's destructive and scandalous proposed rule and send DOE back to the drawing board. In MHARR's view, the DOE proposed energy rule should be a wake-up call for the entire indus- try that while go along to get along is bad enough, enabling DOE's assault on the industry and its consumers is inexcusable and unacceptable. Mark Weiss is President & CEO of the Manufactured Housing As- sociation for Regulatory Reform. MHARR is a Washington, DC- based national trade association representing the views and interests of independent producers of federally-regulated manufactured hous- ing. Mark can be reached at 202-783-4087. T J

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