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would develop and acquire any skills, models, practices or procedures needed to properly serve the manufactured housing market, including chattel loans. Second, FHFA cites a "high level of de- faults," but in a May 24, 2012 meeting with MHARR, FHFA officials acknowledged that the agency has not conducted a single inde- pendent study of this issue and lacks specific current -- or even recent -- data concerning manufactured home chattel loans. Third, any risk presented by AHG credit for chattel loans (or full S/P support under DTS) would pale in comparison to ongoing losses in the site-built housingmarket. The performance ofmanufactured housing loans – at less than one percent of the GSEs' portfolios – was not re- sponsible for the GSEs failure and, because of the relatively small size of the manufactured housing market and the much lower cost of manufactured homes, would not present a sig- nificant credit or operational risk for the GSEs even if they provided AHG credit (and S/P support) for every manufactured home chattel loan. Fourth, FHFA cites "depreciation." But in- dustry experience shows that modern, post- 2000 reform law manufactured homes, when properly located, installed and maintained, hold their value. Furthermore, with no inde- pendent studies and no current data regarding either value trends or the performance of man- ufactured home chattel loans, there's no fac- tual basis for any such assertion anyway. And, even if this claim were factually accurate, it would still not be a legitimate reason for ex- cluding chattel loans fromeither AHG or DTS. If it were, then virtually all home loans since 2006 should be excluded, because values for all types of homes have consistently and substan- tially depreciated since that time. In short, none of the arguments for exclud- ing chattel loans from AHG or DTS hold water as both the GSEs and FHFA have been shown this time and again; which begs the question whether these agencies -- knowing that chattel financing is the life-blood of the entire industry and that full S/P backing for chattel loans is key to its survival and future growth (except for a few corporate conglomerates with ready access to private market capital) -- are just grossly misguided or intend to put the affordable man- UPCOMING ISSUES This issue is a look at the Financial Institutions and their programs. Material deadline is August 15, 2012 This issue will feature the upcoming shows in 2013. Material deadline is October 15, 2012 SEPTEMBER OCTOBER NOVEMBER DECEMBER Louisville Show Special This issue is an overview ofthe Show with complete list ofexhibitors. Additional circulation for this issue. Material deadline is November 15, 2012 For easier application use the Excalibur Applicator. * on qualified orders 32nd Anniversary Issue This issues celebrates The Journal's 32nd Anniversary. Material deadline is September 15, 2012 Show Preview Issue Financial Focus Issue ufactured housing industry out of business. In either case, it's noteworthy that the industry would not be in this position had there been – all along – an independent national post-pro- duction association which would have recog- nized and headed-off such problems with public and private consumer financing long ago, be- fore the structure evolved to the point that the only beneficiaries are a few large corporate con- glomerates. In MHARR's view, absent a major change in course by FHFA, proper S/P support for chattel financing will – and must -- be a key priority for further engagement with the Ad- ministration and the 113th TJ Danny D. Ghorbani is President of the Manufactured Housing Association for Regulatory Reform. MHARR is a Washington, DC-based national trade association representing the views and interests of producers of fed- erally-regulated manufactured housing. Danny can be reached at 202-783-4087. CarpetArmour Carpet Protector - "Shield your carpet from stain, dirt & wear." C - Easy Application 18"Wide Carpet Armour Stock # CS-180200 18"x200' CS-180600 18"x600' CS-181000 18"x1000' Excalibur I Applicator 23.5" Wide Carpet Armour Stock # CS-24020023.5"x200' CS-24100023.5"x1000' Excalibur II Applicator *Free Shipping Call for the name of your nearest distributor. V.P. Products & Sales Inc. 800-462-1775 FAX 800-462-1779 219 Challenge Ave., Prattville, AL 36067 www.vpproductsandsales.com No. 8 on Get It Quick Page AUGUST 2012 11 THE JOURNAL Congress once the dust settles after the November 2012 national elections.