Weekly Updates for Our Members & Affiliates

A Message From THA

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THA had a successful legislative year! Now it is time to support the many legislators who supported us!

The THA 2020 Political Action Committee (PAC) Campaign is in Progress!

As the campaign season for November elections has now begun in Tennessee, your political contribution of funds is critical to our industry's state success.

Access to our legislative members is key, as was just proven by THAs successful passing of much needed changes to our transportation law.

Please support the THA-PAC, to allow THA's continuance of educating key lawmakers on the importance of our industry, while also providing general counsel of promoting manufactured homes as a viable option for addressing the affordable housing crisis.

The THA-PAC is accepting contributions!

Thank you for your consideration!

DID YOU KNOW... in Tennessee?

Every legislative session 2,000 – 5,000 bills are introduced.

Everyday Legislators make decisions which impact our industry.

The wrong decision could cripple or eliminate your livelihood.

Every year our legislative issues become tougher.

Having a strong, well-supported Political Action Committee (PAC) is critical in propelling the industry towards its legislative goals.

To legislative candidates, a PAC represents numbers, constituents and strength.

The THA Political Action Committee provides a unified voice for the manufactured housing industry in Tennessee, which positions us to meet the challenges of an ever-changing legislative political environment.

The ability of THA to impact the outcome of important decisions made by the Legislators is strengthened by our success in backing winning candidates who are industry-friendly.

Your personal contribution is vital if we are to continue supporting industry-friendly candidates.

Every dollar you contribute to the THA-PAC goes directly to targeted candidates.

Your Contribution Form is HERE. Please contribute today!

Tennessee accepts corporate, personal and LLC contributions. Your contribution is critical!

As noted in last week's member update, THA passed important transportation legislation during the 2020 legislative session, which has now concluded. Special thanks to our transportation bill sponsors, Senator Becky Massey (District 6 - Knoxville) and Representative Rick Tillis (District 92 - Lewisburg) , for getting our bill through all of the various committee hearings and up for floor votes! These legislators are very knowledgeable on the needs of our industry, and we appreciate their efforts on our behalf!

SB 1775, Senate Vote: 31-0

HB 2201, House Vote: 90 - 0

A message to our members:

As most of you know, the THA Offices are located in Mount Juliet (Wilson County), Tennessee. Just this week, Wilson County's Mayor declared a State of Emergency effective Wednesday, June 24, 2020, until further notice .

This means area businesses and residents must be hyper-vigilant, to ensure personal safety and the safety of others.

Mayor Randall Hutto based his declaration decision after reviewing COVID-19 data and tracking how quickly the virus is spreading throughout the county. Specifically:

On June 1, the 14-day average daily number of new cases in the county was 6.9.
On June 23, the average was 11.4, and has continued to rise for seven consecutive days.
There were a total of 8 deaths from COVID-19 in Wilson County from May 12th through June 5th.
From June 9th to June 23rd, that increased to 15 people.

Mayor Hutto stated this increase is cause for concern and is the main reason he has declared the State of Emergency. State health officials are monitoring Wilson County and are working with local officials to complete contact tracing, in an effort to inform anyone who may have been exposed.

Mayor Hutto went on to state he wants people to stay safe as they resume activities. County Officials are asking (strongly encouraging, without an official mandate), all residents wear masks in public places, and are urging businesses to take this change very seriously . Businesses should strive to keep their customers and staff safe, by reconsidering the number of people in the business area and by requiring masks for all who enter their stores and businesses.

THA continues to follow local, state and federal guidance, by maintaining a clean environment for those who enter our premises. As well, hand sanitizing stations and visitor face coverings are readily available for all who enter the premises. However, we continue to urge you to contact THA electronically ( Office@tnmha.org ) for your servicing needs, and refrain from visiting the office at this time.

Florida Manufactured Housing Association Sends Letter to the

U.S. Department of Commerce

National Oceanic and Atmospheric Administration

National Hurricane Center

This linked letter penned by FMHA Executive Director Jim Ayotte, addresses the NOAA's weather statements relative to the safety of manufactured homes during strong wind events, up to and including hurricane events. Florida has 1M plus manufactured homes and is certainly qualified to discuss weather related issues. This is a great read, and we appreciate Jim's presentation of the known facts of manufactured home performance.

Read the Letter HERE

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HUD Addresses MHI’s Concerns and Recommendations about

Manufactured Housing Regulations

and Financing

At the end of May, MHI sent a letter to HUD about the President’s recently signed Executive Order about “Regulatory Relief to Support Economic Recovery” encouraging the prompt adoption of needed changes to the HUD Code and Federal Housing Administration finance programs to support manufactured housing. MHI has long been advocating that not only must the OMHP be elevated within the Department’s hierarchy, but HUD Code updates must follow a distinct administrative path and be prioritized separately from unrelated policy matters. Further, MHI continues to urge HUD to update its FHA Title I and Title II programs for manufactured housing because outdated rules make the programs an impractical financing option.

MHI has received a response from HUD providing an update on the agency’s progress on these key initiatives. The response letter affirms HUD’s work on MHI’s priorities, and it acknowledges the roadblocks that need to be addressed to streamline the process for updating the HUD Code. According to the letter, the Office of Manufactured Housing Programs (OMHP) has been “unable to process many other revised standards updates on a regular cadence due to numerous choke points and dependencies within the process.” Further, the letter states that “enhanced organizational authority for OMHP may improve prioritization of manufactured housing initiatives, particularly by offices involved in rulemaking (notably the Office of General Counsel and the Office of Policy, Development, and Research), and thereby reduce competing priorities from the Office of Risk Management and Regulatory Affairs or other unrelated HUD offices.”

HUD to Host Virtual Sexual Harassment in Housing Training Forums

In a release yesterday, U.S. Department of Housing and Urban Development (HUD) announced it will host two virtual training forums for the HUD Fair Housing Initiatives Program and Fair Housing Assistance Program agencies. These forums will focus on effective strategies to address sexual harassment in housing and will be conducted through HUD’s National Fair Housing Training Academy (NFHTA).

The first forum, titled “A Conversation on Sexual Harassment in Housing Situations” will be conducted on June 25, from 2 p.m. to 3:30 p.m., and cover what constitutes sexual harassment under the Fair Housing Act, who is most vulnerable, investigation techniques, case highlights and outcomes, and resources for education and outreach activities.

The second forum, titled “Investigating Complaints of Sexual Harassment in Housing Situations,” will be held July 9, from 2 p.m. to 3:30 p.m., and cover topics related to the Fair Housing Act, relevant case law, prompt judicial relief, and the emotional support and care of victims of sexual harassment. Also highlighted will be sexual harassment cases in which HUD, the U.S. Department of Justice, and the National Fair Housing Alliance have collaborated their efforts on.

For up-to-date information about the upcoming sexual harassment training forums, go HERE .

HUD Affirms Progress on MHI Key Priorities

At the end of May, MHI sent a letter to HUD about the President’s recently signed Executive Order about “Regulatory Relief to Support Economic Recovery” encouraging the prompt adoption of needed changes to the HUD Code and Federal Housing Administration (FHA) finance programs to support manufactured housing. MHI has long been advocating that not only must the Office of Manufactured Housing Programs (OMHP) be elevated within the Department’s hierarchy, but HUD Code updates must follow a distinct administrative path and be prioritized separately from unrelated policy matters. Further, MHI continues to urge HUD to update its FHA Title I and Title II programs for manufactured housing because outdated rules make the programs an impractical financing option.

MHI has received a response from HUD providing an update on the agency’s progress on these key initiatives. The response letter affirms HUD’s work on MHI’s priorities, and it acknowledges the roadblocks that need to be addressed to streamline the process for updating the HUD Code. According to the letter, the Office of Manufactured Housing Programs (OMHP) has been “unable to process many other revised standards updates on a regular cadence due to numerous choke points and dependencies within the process.” Further, the letter states that “enhanced organizational authority for OMHP may improve prioritization of manufactured housing initiatives, particularly by offices involved in rulemaking (notably the Office of General Counsel and the Office of Policy Development, and Research), and thereby reduce competing priorities from the Office of Risk Management and Regulatory Affairs or other unrelated HUD offices.”

FHFA and FHA Extend Eviction and Foreclosure Moratoriums

The Federal Housing Finance Agency (FHFA) and the Federal Housing Administration (FHA) announced they are extending their respective foreclosure and eviction moratoriums to August 31, 2020. The current moratoriums, which were initiated to help borrowers and renters who were financially impacted by the coronavirus national emergency, were originally set to expire June 30, 2020.

Fannie Mae and Freddie Mac’s (Enterprises) single-family moratorium on foreclosures and evictions applies to Enterprise-backed, single-family mortgages only. FHA’s extension continues to apply to all FHA Title II single family forward mortgage and Home Equity Conversion Mortgage (reverse) programs, except for those secured by vacant and/or abandoned properties. The extension does not apply to Enterprise-backed multi-family loans.

Housing Groups Join Together to Urge FHFA and FHA to Change Forbearance Policy

MHI joined a politically diverse set of housing groups to express concerns with the Federal Housing Finance Agency’s (FHFA) and Federal Housing Administration’s (FHA) recent changes to their forbearance policies. The letter cautions that these restrictions on the mortgage markets will prolong the recession and hamper economic recovery by reducing access to credit, particularly in those communities hardest hit by the national pandemic.

According to the letter, “since there is no way to underwrite loans for the contingency of COVID-19 related unemployment, lenders will inevitably apply deep overlays across their book of business to avoid penalties that wipe out the profit on these loans and many more that never go into forbearance. This is the equivalent of collective punishment on all borrowers, particularly first-time homebuyers with smaller down payments, less than pristine credit, or those employed in areas that have already withstood the majority of likely job loss.”

The letter points out that at a time when there is a national conversation about racial equity, the credit overlays required will not only deter first-time homebuyers but also prevent existing homeowners of color from refinancing and benefiting from historically low interest rates, further locking them out of the prospect of building wealth through homeownership.

MHI Submits Recommendations for 2020-2021 HUD Code Updates

Keeping our building code current and more regularly updated is critical for ensuring our industry can continue to produce safe, affordable homes with the innovative features and amenities today’s consumer demands. As part of this effort, MHI submitted recommendations to the U.S. Department of Housing and Urban Development (HUD) for the 2020-2021 HUD Code development cycle. These recommendations are a continuation of MHI’s ongoing efforts to make critical updates to the HUD Code. In March, MHI submitted recommendations in response to the Department’s most comprehensive proposed update to the HUD Code in over a decade, which included 44 proposed revisions.

The four recommendations submitted were based on discussions with MHI’s Technical Activities Committee, which provides MHI with valuable input and recommendations to ensure updates to the HUD Code are appropriate and allow for even greater innovations by our industry.

( Read more )

CFPB Includes Manufactured Housing

in Proposed Rulemaking for

Qualified Mortgage (QM) Patch

This week, the Consumer Financial Protection Bureau (CFPB) included manufactured housing among its targets for new proposed rulemaking aimed at making much-needed revisions to Qualified Mortgage (QM) loans and the Government Sponsored Enterprises (GSE) Patch.

The two Notices of Proposed Rulemaking (NPRMs) issued by the CFPB would significantly revise the definition of a QM loan and address the approaching expiration of the GSE Patch that has exempted GSE loans above 43% DTI limit from QM.

The NPRMs are extremely detailed, but they generally aim to:

Extend the GSE QM Patch (scheduled to expire in January 2020) until a final revised QM rule is put in place, and
Replace the current 43% DTI test with a 200 over APOR test – but with two higher thresholds for smaller loans sizes. The current 150 BP over APOR Safe Harbor would be unchanged.

MHI sent a letter to CFPB Director Kathleen Kraninger in response to the Bureau’s January letter to Congress committing to change the definition of an eligible QM loan. The Director’s letter stated that the CFPB would “move away from” the current 43 percent Debt to Income (DTI) cap and “instead include an alternative, such as a pricing threshold” that would be the difference between a loan’s Annual Percentage Rate (APR) and the Average Prime Offer Rate (APOR) for a comparable transaction. MHI strongly reiterated to the CFPB that it was critical under an APOR measure to have much higher APOR thresholds for manufactured housing chattel loans (or alternatively for smaller loans which would cover chattel loans).

The NPRM released by the CFPB included a discussion of manufactured homes and the following specific higher APOR levels for smaller dollar loans:

Specifically, proposed § 1026.43(e)(2)(vi)(B) would provide that, for first-lien covered transactions with loan amounts greater than or equal to $65,939 but less than $109,898,270 the threshold would be 3.5 percentage points over APOR. Proposed § 1026.43(e)(2)(vi)(C) would provide that, for first-lien covered transactions with loan amounts less than $65,939, the threshold would be 6.5 percentage points over APOR.”

MHI will be assessing the practical impact of these thresholds, as well as other provisions in the proposed rule to ensure any new rule making reflects our industry’s priorities and creates greater access to financing for manufactured home buyers.

Tennessee joins Kentucky and the entire manufactured housing industry,

as we mourn the sudden passing of Carol Barr,

wife of U.S. Representative Andy Barr (R-KY).

In a statement released by his office, the family has asked for support through prayer:

At this time of tremendous grief and pain, we ask for prayers for our beautiful, dear and precious Carol, the greatest, most selfless and giving wife, mother, daughter, sister and friend anyone could ever have. We also ask for love and prayers for Carol’s greatest legacy — her loving and devoted daughters Eleanor and Mary Clay — through whom Carol’s extraordinary life, high character and irrepressible spirit will continue,” he said. “In this moment of profound grief and heartbreak, we are so grateful for the gift and blessing of Carol’s life, for her strong faith in her Lord and Savior Jesus Christ, for the comfort of fond memories and her victory in heaven and for all those who have surrounded Carol’s family, the girls and I with beautiful expressions of love, compassion and sympathy.

Carol Barr, wife of U.S. Representative Andy Barr (R-KY), passed away unexpectedly last week at the age of 39, due to natural causes associated with a heart condition. She is survived by her husband and two daughters, Eleanor and Mary Clay. Our deepest condolences go out to Representative Barr and his family during this difficult time.

During his time in Congress, Representative Barr has been a consistent and vocal champion of manufactured housing. He was the sponsor of the Preserving Access to Manufactured Housing Act and ensured provisions from that legislation were a part of the Dodd-Frank Act reforms that were signed into law in 2018. He successfully secured a congressional directive to HUD that resulted in HUD changing its carport requirements, reviewing the on-site completion of construction rule, and not moving forward with the frost-free foundation proposal. This year, he is pressing HUD for updates to the Federal Housing Administration’s (FHA) financing guidelines to support FHA loans for manufactured homes.

COVID-19 RESOURCES

By Member request, THA will continue to maintain a resource section on our Website , for an extended period of time.

Click for THAs COVID-19 Resource Dashboard

MHI Joins Coalition in Support of Expanding Employee Retention Credit

Through New Legislation

MHI joined a coalition of business associations in telling Congressional leaders to include H.R. 6776, the “Jumpstarting Our Businesses’ Success (JOBS) Credit Act of 2020” in future legislative packages aimed at helping people and businesses recover from the economic impact of COVID-19.

The JOBS Credit Act is a bipartisan effort on behalf of American businesses to expand the Employee Retention Credit (ERTC), which was created as part of the CARES Act to incentivize employee rehiring and retention in the wake of COVID-19. Per the letter, the JOBS Credit Act would enhance the ERTC by:

Increasing the credit from 80 percent to 50 percent;
Increasing the wage base to $15,000 per quarter for up to three quarters—previously $10,000 per year;
Easing the qualifying rules for revenue decline;
Including health benefits in the definition of qualified wages; and
Allowing businesses that receive a loan through the Paycheck Protection Program loan to qualify for the credit.

Incentivizing American businesses to maintain employment is crucial to ensuring the long-term success of the economy as it recovers. MHI will continue to push for this and any legislation that helps our industry and others survive and thrive after this national health emergency.

Visit MHI's COVID-19 Resources for Manufactured Housing

Coming July 15th! GET TICKETS

Governor Lee Press Conference Highlights

(Tuesday - 6/23/20)

Governor Bill Lee, in conjunction with Speaker Sexton and Lt. Gov. McNally, is exploring options of potentially calling a special session to take up a COVID-19 liability protection bill for Tennessee businesses, including churches, healthcare providers, and schools.

Tennessee Business Relief program is planning to begin distributing monetary relief by early July. The Governor encouraged businesses to ensure their Tennessee Department of Revenue information is current and up to date, to ensure proper distribution of the funds.

The Harvard Opportunity Insights Tracker has ranked Tennessee #1 in the country for recovery in restaurant and hotel spending.

Tennessee has achieved the second-highest recovery rate in the nation for apparel and general merchandise spending.

Tennessee has seen a 145% increase in out-of-state travelers from April to May, and an increase of hotel demand by 54% from April to May.

Track State Recovery - Here - Explore the data for yourself!

EDUCATION - It's Go Time

Now more than ever, it is important to earn a college degree or certificate to be prepared for a career and a high demand job. It’s not too late to sign up for college this fall in Tennessee. To Learn More, Click Below!

It's Go Time

The State’s Economic Recovery Group Enlists

Flagship Tennessee Brands to Get More Masks

in Hands of Tennessee Residents

Announced: June 17, 2020

Tennessee Governor Bill Lee’s Economic Recovery Group (ERG) has developed the TN Strong Mask Movement, partnering with more than 30 flagship brands to distribute close to 300,000 free or low-cost cloth face coverings, at a projected value of more than $3 million, across the state. Now, residents can stay safe while wearing brands synonymous with Tennessee from the worlds of sports, education, and business.

Each business will distribute branded cloth face coverings at little to no cost across their own channels or with the help of the State of Tennessee, which could include employees, fans or nonprofit partnerships. Companies can visit TN Strong Mask Movement for additional information. The general public can also visit the link above to order a TN Strong branded mask.

Get your branded face cloths here!

Become part of the Mask Movement. If your organization is interested in purchasing customized branded masks to distribute throughout your community, order online by visiting HERE!

Where opportunity for new job creation exists ...

so does the need for affordable housing!

Economic and Community Development Commission Announce

TTI Floor Care - North America Expansion of Cookeville Operations!

TTI Floor Care North America, the company behind brands like @HooverUSA and @oreck , announced Wednesday morning that it will invest $20 million to increase manufacturing at its Cookeville facility.

TTI will create 500 jobs over the next 5 years.