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The Reporter
January - February 2024
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“Far and away the best prize that life offers is the chance to work hard at work worth doing.”
-- Theodore Roosevelt --
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THA Sends Comments to DOE on Proposed Enforcement Rule of its Manufactured Housing Energy Efficiency Requirements | |
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State Associations across the nation have weighed in on the Department of Energy's (DOE) proposed rule on enforcement of its manufactured housing energy efficiency requirements. The Manufactured Housing Institute expressed concern that the DOE proposal yet again demonstrates the complete lack of understanding of our industry and will impose significant problems, costs and uncertainties for our manufacturers. (The deadline for comments was February 26th.)
For example, the DOE’s proposal states that “the costs of complying with DOE’s enforcement mechanisms will be minimal.” This shows how out of touch the DOE continues to be. In the last several days, HUD’s Manufactured Housing Consensus Committee (MHCC) met to prepare comments to DOE about the Proposed Rule. The MHCC and MHI will be commenting on and expressing concerns about significant problems with the proposed enforcement rule and both organizations are very much aligned in their collective thinking.
It is impactful for state associations to corroborate the MHI and MHCC’s points about issues and concerns with the DOE’s proposed enforcement rule.
You may read THA's comment letter here.
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House Hearing Highlights Role of Localities in Housing Policy | |
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On Thursday, Feb. 22, the House Financial Services Subcommittee on Housing and Insurance held a field hearing in New City, New York, titled, “Restoring Prosperity in American Communities: Examining the Failures of Status Quo Housing Policy.”
The hearing primarily focused on New York’s housing issues, but also discussed potential solutions to the affordable housing crisis, including how burdensome regulations, excessive bureaucracy, and a top-down and one size fits all approach in Washington contribute to affordable housing shortages.
Rep. Mike Flood (NE-1) highlighted the benefits of manufactured housing during the hearing and mentioned that Fannie Mae and Freddie Mac have set manufactured housing as a priority. He said manufactured housing could be of great benefit in suburban and rural areas; however, the cost of land in urban areas may be too high to make it an option in more urban areas. Rep. Flood (R-NE) highlighted his bill, H.R.3507, the Yes In My Backyard Act, as a solution to burdensome land-use policies for ensuring affordable housing.
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Legislation to Remove DOE Authority over Manufactured Housing Energy Standards
The Affordable HOMES Act repeals Section 413 of the Energy Independence and Security Act (EISA) of 2007 and would ensure that the Department of Energy’s (DOE) final rule on Energy Conservation Standards for Manufactured Housing will have no force or effect.
Halting implementation of the EISA’s flawed approach and re-affirming HUD’s long-standing exclusive control over federal manufactured housing standards is the best way to ensure the timely adoption of improved energy efficiency standards for factory-built housing in a way that preserves the availability of affordable manufactured homes for Americans.
THA supports the passage of the Affordable HOMES Act and asks you to show your support by going to the MHI Advocacy Action Center and telling your Representative in Congress to support the passage of the “Affordable HOMES Act” (H.R. 6421). Congress must hear from all sectors of the manufactured housing industry about the urgent need to stop DOE overreach.
Connect with your Representative by following the simple steps on MHI's website. MHI has written a letter that you can send by simply inserting your home address and clicking submit.
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The Federation of American Scientists Discusses Eliminating the Chassis Requirement for Manufactured Housing | |
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".... Despite their efficiency advantage, manufactured homes face discriminatory barriers to fair competition with site-built construction. Many state laws and local zoning codes restrict or exclude manufactured homes, often based on architectural features common only on manufactured homes, like the congressionally-mandated permanent chassis.
The permanent chassis under every manufactured home must be retained even after permanent installation onto the land. This requirement is meant to retain nominal interstate portability, even though manufactured homes are rarely moved after they are attached to the land. The permanent chassis limits architectural flexibility by requiring the home to be installed higher off the ground to account for the chassis’s vertical height, makes basements less practical, and effectively precludes using HUD Code construction for upper floors due to the weight and bulk of the chassis.
In the past, organizations like the National Association of Homebuilders opposed reforming the HUD Code chassis requirement in an effort to protect home builders from more efficient, factory-made competition. Today, with the construction sector at full employment, this motivation for opposition has subsided.... "
Read the full Article Here
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Tennessee Legislators Join Representative Norman in Urging the Appropriations Committee Stop DOE's MH Standards in Final Spending Package | |
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Representative Ralph Norman (SC-5) sent a letter to the House Appropriations Committee leadership urging them to ensure inclusion of his manufactured housing energy standards limitation amendment in the Department of Energy spending package for Fiscal Year 2024. During House consideration of the spending package, Rep. Norman’s amendment was unopposed and adopted by voice vote.
"Manufactured housing is truly one of the best opportunities for helping families make the dream of home ownership a reality." said Rep. Norman. "As a representative of South Carolina, a state with the largest proportion of manufactured housing in the country, I cannot allow ill-advised DOE energy standards to inappropriately threaten the affordability of these homes."
Twenty-three House members joined Rep. Norman in signing the letter, including Representatives Andy Barr (KY-6), Larry Bucshon, M.D. (IN-8), Tim Burchett (TN-2), Byron Donalds (FL-19), Earl L. "Buddy" Carter (GA-1), Jeff Duncan (SC-3), Scott Fitzgerald (WI-5), Mike Flood (NE-1), Lance Gooden (TX-5), Diana Harshbarger (TN-1), French Hill (AR-2), Michael V. Lawler (NY-17), Dan Meuser (PA-9), Mary E. Miller (IL-15), Alex X. Mooney (WV-2), Troy E. Nehls (TX-22), Andrew Ogles (TN-5), Bill Posey (FL-8), John Rose (TN-6), Pete Sessions (TX-17), Ann Wagner (MO-2), Randy K. Weber, Sr. (TX-14) and Rudy Yakym III (IN-2).
The Manufactured Housing Institute (MHI) appreciates the leadership of Representative Norman and the support of other House members to protect the 50-year framework under which HUD has exclusive jurisdiction over the establishment of strong safety and construction standards for manufactured homes, including with respect to energy efficiency. MHI is strongly urging Congress to include this solution in the final spending package.
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ICYMI: The Joint Center for Housing Studies of Harvard University Released a 2024 Report on America's Rental Housing | |
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The Joint Center for Housing Studies of Harvard University released a new report examining rental housing in the U.S., including critical affordability and policy challenges. The researchers identified six key findings:
- Rental markets are softening.
- Affordability is worse than ever before.
- Housing instability is rising.
- Rental assistance falls far short of the need.
- The rental stock has significant investment needs.
- High interest rates are dampening rental market activity.
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National Flood Insurance Program (NFIP) | |
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In January, the Senate Banking Committee held a hearing titled, “Reauthorization of the National Flood Insurance Program: Local Perspectives on Challenges and Solutions.” The recently passed Continuing Resolution (CR) extended the authorization for the National Flood Insurance Program (NFIP) to March 8, 2024.
The NFIP has been receiving short-term extensions through government funding processes, and this trend is expected to continue. Chair Sherrod Brown (D-OH) called for a long-term reauthorization of the NFIP, while Ranking Member Tim Scott (R-SC) suggested reforms to address repeatedly flooded properties. Senators Kennedy, Menendez and Cassidy criticized NFIP’s Risk Rating 2.0, arguing that it will cause homeowners to drop their coverage. They introduced the National Flood Insurance Program Reauthorization and Reform Act of 2023, which proposes capping premium increases at 9 percent per year. There is bipartisan support for increasing investment in mitigation to reduce damage from natural disasters.
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THA Board Approves Floor Due Increase | |
As published in the December yearend newsletter, the THA Board of Directors voted to increase manufacturer floor dues from $125 per floor to $175 per floor. A rate change of floor dues had not been implemented since 2016. The rate change will go into affect beginning with April 1st production. THA will be utilizing a portion of that increase for legislative activities to better serve the growing demand for education and support within the local and state regulatory body of legislative officials who make decisions affecting our industry everyday. | |
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Yearend Shipment Data For Tennessee | |
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MHI Sends Letter to the FTC:
"Junk" Fee Rule Harmful to Housing Providers
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On behalf of the industry, MHI sent a letter to the Secretary of the Federal Trade Commission, April Tabor, regarding the FTC’s newly proposed “Rule on Unfair or Deceptive Fees.” MHI also joined a coalition of real estate industry associations in a comment letter to Secretary Tabor.
In November, the FTC proposed the rule that would require the disclosure of all mandatory fees in advertised prices to give the customer the total price of an item upfront. The rule targets multiple industries including the rental housing industry. MHI expressed concern that the blanket regulations complicate the lengthy list of state, local and municipal laws regarding rental housing and may reduce housing supply. Given the anecdotal sources of the numbers used to include the rental housing industry in this rule, the coalition raised doubts about the legality of enforcing such a proposal.
MHI will continue monitoring this proposed rule for future implications for the manufactured housing industry.
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FinCEN Proposes Rule to Combat Money Laundering and Promote Transparency in Residential Real Estate | |
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On February 7th, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking to combat and deter money laundering in the U.S. residential real estate sector by increasing transparency.
The proposed rule would require certain professionals involved in real estate closings and settlements to report information to FinCEN about non-financed transfers of residential real estate to legal entities or trusts. FinCEN’s proposal is tailored to target residential real estate transfers considered to be high-risk for money laundering, while minimizing potential business burden, and it would not require reporting of transfers made to individuals.
“Illicit actors are exploiting the U.S. residential real estate market to launder and hide the proceeds of serious crimes with anonymity, while law-abiding Americans bear the cost of inflated housing prices,” said FinCEN Director Andrea Gacki. “Today marks an important step toward not only curbing abuse of the U.S. residential real estate sector, but safeguarding our economic and national security.”
The proposed rule describes the circumstances in which a report would be filed; who would file a report; what information would need to be provided, including information about the beneficial owners of the legal entities and trusts; and when a report about the transaction would be due. Data from the reports would assist the Department of the Treasury and its law enforcement and national security partners in addressing vulnerabilities that leave the U.S. residential real estate market exposed to abuse by illicit actors.
The proposed rule is consistent with the Bank Secrecy Act’s longstanding directive to extend anti-money laundering measures to the real estate sector and builds on the success of FinCEN’s Real Estate Geographic Targeting Order program, which has demonstrated the need for increased transparency and further regulation of this sector nationwide. Under the proposed rule, persons involved in real estate closings and settlements would continue to be exempt from the anti-money laundering compliance program requirements of the Bank Secrecy Act.
FinCEN strongly encourages the public to submit written comments in response to the proposed rule. Comments will be accepted for 60 days following publication in the Federal Register.
A Fact Sheet on the Notice of Proposed Rulemaking is available on FinCEN’s website.
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Make Plans Now to Attend These Events | | |
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2024 THA Annual Member’s Meeting
"Make Every Connection Matter"
June 9 - 11, 2024
Dollywood's HeartSong Lodge & Resort
1210 Dollywood Resorts Blvd
Pigeon Forge, TN 37863
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Member Updates and Reminders | |
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2024 Member Dues Renewals were mailed in late November with a due date of December 31st! Check your mailbox and get those renewals returned to continue receiving the latest industry news, information and educational discounts. Non-renewals will have their online listings removed from both the Association's member's tool website and the consumer-facing website, which is the lead-generating site.
Member resources and social media:
THA Association Website: https://tnmha.org/
Go to THA’s main website for the latest industry news, show dates, legislative action items, licensing educational news, scholarship information, member listings, PAC updates and so much more! There is no log in or password needed for this site!
THA Educational Website: https://education.tnmha.org/
This is the direct link to the educational platform where courses are available for initial licensing/certification and continuing education! Please check the Association website (tnmha.org) throughout the year for special announcements, field updates, and yearend deadlines. You must have a log in and password for your educational account, but not the Association website.
THA Consumer Website: https://www.tennesseemanufacturedhomes.com/
This is a consumer-facing website which allows consumers to tour homes and send messages directly to THA members for home quotes, community inquiries, inquire about financing or reach one of our service/suppliers. You must be a THA member to have your business listed on this site.
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Follow us on social media! | |
THA Educational Assistance/Scholarships | |
Deadline Rapidly Approaching!!!! | |
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Stan & Thelma Plumlee Scholarship Committee
$2,000 Technical Scholarships
available through the
Factory-Built Home Industry.
Up to four (4) will be awarded in 2024.
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Scholarship applicants MUST be associated with the manufactured or modular housing construction industry in some way, to be considered.
For example:
- the student/individual currently lives in a manufactured or modular home; or
- the student/individual has a close relative who works in the manufactured housing industry (i.e., father, mother, grandfather, grandmother, brother, sister, aunt, or uncle); or
- the student/individual is currently working in the industry via one of the intern/apprenticeship programs; or
- the student/individual is directly employed by a manufactured or modular housing construction-related company.
In order for a student to be eligible to receive one of the stated financial awards from the Stan & Thelma Plumlee Scholarship fund, the following criteria must be followed:
- Must have graduated from a Tennessee High School (public, private, parochial) or equivalent (GED).
- Must be accepted by an accredited Tennessee Trade or Technical School/Program or other institute of higher learning.
- The institute of higher learning must be a Tennessee public or private university or college, a junior college, or an accredited trade or technical school/program.
Scholarship assistance opportunities are not limited to graduating seniors, but are specific to the pursuit of technical or trades-related training which supports the construction industry.
Deadline to receive applications is is 4:00 pm, Thursday, March 7, 2024.
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News articles from around the country! | |
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A New ‘Holy Grail’ in the Housing Crisis: Statewide Rent Caps, The New York Times
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PHAM: Biden Administration Misfires On 'Junk Fees', Daily Caller
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Eliminating the Chassis Requirement to Free Manufactured Homes from Local Discrimination and Regulatory Dead Weight, fas.org
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The Maine Millennial: On mobile homes, let's move with the times, The Portland Press Herald
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How Mill Creek mobile home residents bought the land under their feet, Herald.net
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Trailer park property rezoning prompts Cape City Council discussion on place in city, Southeast Missourian Newspaper
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Bill that limits rent increases should be passed, MyNorthwest.com
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Michigan mobile home parks may see limits on rent increases, Crain’s Detroit Business
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Council extends manufactured home moratorium again, Sequim Gazette
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Defying Critics: How a Young Couple Transformed a Mobile Home into a Dream Abode, BNN Breaking
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The promise of modular homes, Adirondack Explorer
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Can 3D Printing Help Address the Affordable Housing Crisis in the United States?, Smithsonian Magazine
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Annually, we encourage our members to support Tennessee's legislative efforts, by contributing to the Political Action Committee campaign. Click on the Donate Button [right] to make an online contribution or you may choose to download a contribution form.
The 2024 Campaign has a goal of $65,000. Please follow along with us this year and view the list of contributors as we build our PAC account in anticipation of the 2024 elections.
Find the PAC webpage here!
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Pretty Home? Let Us Film It! | |
The production team at ManufacturedHomes.com is currently looking for installed manufactured and modular homes that will represent the industry in our state. If any of our THA members have recently set a home and the landscaping is now complete, drop a picture of the exterior to Rick@manufacturedhomes.com
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Did you see the THA Member Tool Kit emails
in January and February?
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Download the graphics and videos from from your e-mails! If you missed them, go back and search the dates or the subject lines with these titles...
January dated 1/11/2024 -
"Step into the New Year with a New Manufactured Home"
February dated 2/7/2024 -
"I Love Manufactured and Modular Homes"
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is making a difference! Leads are coming in!
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Take a look here: TennesseeManufacturedHomes.com
As a THA member, you have a free site listing allowing consumers to directly access your business. What a fantastic member benefit! As of this writing, since mid-March 2023, approximately 463 customers have inquired to retailers, finance companies or communities for home quotes or community living availability! We have their names, e-mails and phone numbers! Many of those customers inquired to more than one retailer asking for quotes on more than one home model! Those are serious inquiries and real opportunities!
However, to provide the best consumer experience, retailer listing profiles should display the makes and models of new homes offered, and communities should have full descriptions with amenities. In order for you to best utilize this consumer-facing website, it is imperative that you verify your listing and provide all necessary changes. The site's architect will directly receive your requests for changes or additions (see buttons below).
In all events, ensure any leads generated are going to an email address that is checked daily. Please take a minute to click the appropriate button below and provide/update your free member listing. If your business is not listed, you have not completed your required listing information. Non-member companies will not be allowed to list on this website for consumer searches.
Remember! This is THA’s consumer-facing website. Our existing association website remains active as your continued resource for industry news, legislative announcements, educational offerings, and general business information.
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Use these links to make changes or additions to your TennesseeManufacturedHomes.com listing. | |
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Tennessee MH Education
New Classes Began on January 5, 2024
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Pick your course. Pay online. Access Online.
Print your certificate of completion right from your dashboard!
The educational portal opened on January 5th and will close on December 6th, 2024.
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Discounts are available for THA member companies ONLY!
(Email Office@tnmha.org for your member discount coupon, prior to purchase!)
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Community Owners and Managers Education | |
Accredited Community Manager (ACM) - Designation -
The ACM curriculum is a two-part course for owners and managers of manufactured home communities. Topics include management and resident policies, community maintenance, leasing and sales techniques, marketing communities, taxes, insurance, financial management, business planning, physical asset management, and federal and fair housing laws.
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Professional Housing Consultant (PHC)
- Designation -
The PHC curriculum is a comprehensive study of manufactured housing for retail salespeople. Topics include retailer responsibilities, land-home and personal property financing, fair housing, and selling skills.
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