Issue link: https://read.dmtmag.com/i/733263
OCTOBER 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 shown by minimal referral levels in the federal and representative state dispute resolution sys- tems established under the 2000 reform law). While it has thus been obvious all along that this expanded in-plant regulation has been all about maintaining and increasing contractor billings, revenues and de facto authority in the face of a prolonged industry downturn, there is now direct evidence showing that this is little more than a "make-work" enterprise for the contractor, as MHARR has maintained. At the June 2016 HUD-SAA-PIA meeting in Washington, D.C., the monitoring con- tractor presented a chart showing its top ten "audit findings" (from May 2015 to April 2016) in connection with: (1) the in-plant home pro- duction process itself, on the one hand; and (2) the "quality control" (i.e., paperwork) proce- dures required by HUD under its program of ex- panded in-plant regulation, on the other. Of the top ten "production" issues found by the contractor, the most frequent rate of occurrence – 16.4% -- involved "loose or missing fasteners in … vinyl siding" and "inadequate installation of vinyl siding trim around doors and windows," not ideal, but not a life-safety issue either. Of the remaining nine (alleged) "production-re- lated" issues, six had occurrence rates below 10% and one of the top four – with an occur- rence rate of 12.1% -- involved "inadequate re- porting of [Alternate Construction] homes" and/or "use of expired AC letters," in reality a paperwork issue, not an actual construction error. By comparison, for the top ten "quality con- trol" paperwork issues found by the contractor, the most frequent rate of occurrence was a whopping 52.3% for, among other things, the "improper use of terminology for initial determi- nations." Analyzing the two charts, the top rate of occurrence of "quality control"/paperwork is- sues is nearly 220% greater than the top rate of occurrence for actual production issues, while the average rate of occurrence for "quality con- trol" – i.e., paperwork issues – is 113% higher than the average rate of occurrence for actual "production"-related issues. Rather than a legitimate and bona fide in- spection system, HUD's program of expanded in-plant regulation is a "paper chase," with high – and rising -- costs in return for little or no cor- responding consumer benefits. This entire sys- tem, in which an entrenched 40-year contractor calls the shots and effectively dominates the fed- eral program for its own benefit and interests, must end. The system needs to be revamped, from top to bottom, to ensure a competitive and legitimate bidding process and an end to the current de facto sole source contract. And that, in turn, will require an appointed, non-career program Administrator, consistent with the 2000 reform law. In this regard, it's time for industry members who have gone along and en- abled the current indefensible system, to now join forces to pursue such necessary reforms. In MHARR's view, with a new administra- tion taking office in Washington in 2017, the industry and consumers have an opportunity to seek real and necessary change in the HUD en- forcement system to reduce unnecessary costs and regulatory burdens through fundamental contract reform, while preserving consumer protection and the bedrock quality and afford- ability of today's manufactured housing. Mark Weiss is President & CEO of the Manufac- tured Housing Association for Regulatory Reform. MHARR is a Washington, DC-based national trade association representing the views and interests of in- dependent producers of federally-regulated manu- factured housing. Mark can be reached at 202-783-4087. T J