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August 2016

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AUGUST 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 No. 8 on Get It Quick Page playing out, MHI's agenda in the nation's capital has seemingly been dominated by the drive to re- form the high-cost loan and loan originator provi- sions of the Dodd-Frank law. While a worthy cause, the pursuit of those reforms – involving major resources -- has tended, as MHI members themselves have recognized, to eclipse many other extremely serious regulatory matters that have ei- ther been overshadowed or given short-shrift. Again, as with MHI's actions concerning DTS, this "tunnel vision"-type focus – particular on high-cost loan amendments -- represents a con- scious policy choice that appears to prioritize the interests and objectives of the few industry-dom- inant lenders, while other concerns within the broader industry have taken a backseat, at best. This is particularly the case for the industry's post-production sector – and its thousands of smaller businesses – which have no independent national association to monitor issues in the na- tion's capital, mobilize for effective action and fight for their interests and their issues, rather than the few industry-dominant lenders and the corporate conglomerates that stand behind them. It should, therefore, be no surprise that produc- tion – which should be in the hundreds of thou- sands of homes – continues to struggle under the weight of out-of-control regulatory burdens and costs originating from Washington, D.C. Meanwhile, back in the DTS arena, as trans- parency continues to be stonewalled, MHI reports an "ongoing dialogue" with both Fannie Mae and Freddie Mac. The nature of that "dialogue" re- mains obscure. What is known, though, is: (1) that Fannie and Freddie are the "regulated parties" under DTS; (2) that FHFA, under HERA, is the regulator charged with crafting, implementing and enforcing DTS; and (3) that, as a result, the ul- timate structure and scope of DTS will be deter- mined by FHFA, not Fannie and Freddie. Consequently, the point and relevance of this "ongoing dialogue" is unclear, at best, particularly when reports have indicated that the GSEs will not accept the inclusion of chattel loans in DTS unless compelled to do so by FHFA. FHFA, though, has been mum since the April "industry meeting." MHARR, for its part, has consistently worked for the full inclusion of manufactured home chat- tel loans in DTS on a going basis since HERA was enacted – and will continue to do so. It has also sought to provide the entire industry – and the post-production sector – with relevant, accurate and factual information regarding this crucial issue that might not otherwise be available. But MHARR, while fighting to "move mountains" on DTS-chattel, is hampered in its efforts by the ab- sence of an independent national post-production association with which to partner on this matter - - which most directly involves the finance com- ponent of that sector. Thus, while efforts have already been launched within the industry to pro- vide education, information and promotional services for post-production businesses – offering good value for what they do – an independent, targeted advocacy entity is still needed to effec- tively advance post-production interests and es- pecially those that have significant impacts on other segments of the industry. In MHARR's view, continuing difficulties and setbacks for the industry's post-production sector in Washington, D.C. – particularly concerning consumer financing – illustrate the dire need for the establishment of such an independent, na- tional post-production association. 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

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