The Reporter

September - October 2024

The offices of the Association will be closed on Monday, November 11th, in observance of Veteran's Day.

 “The only place where success comes before work is in the dictionary.”

-- Vidal Sassoon --

If you have not already early voted, please remember to exercise your right to vote, on Tuesday, November 5th. It is your right and a privilege to vote. Your voice does matter!

THA is a bi-partisan non-profit organization who works across the aisles to promote the benefits of attainable, affordable factory-built housing. Please do your due diligence in researching your candidates of choice, to ensure they promote the benefits of your industry in meeting the housing needs of your local city, county, and state, when addressing the shortage of available housing.

If you would like more information on understanding the respective platforms of specific candidates, please visit the party or candidate websites directly. Candidates will clearly state their respective positions on issues, on their own websites. Do your research!

FEMA is interested in whether there are vacant sites or expansion opportunities at manufactured housing communities located in or near impacted areas in Northeast Tennessee, as a result of Helene. 

THA has already reached out to our community members directly who are in and around the affected areas, however, if you missed the correspondence and would like to get involved with FEMA by providing (renting) home sites for homes, or you have vacant homes available for rent, please follow the steps listed below.  Your correspondence will be directly with FEMA and not THA.

• NOTE: This is not for home replacements! That is a separate issue. This is to identify where temporary homes could be placed quickly for displaced residents! 
• There would be a vetting process, so please make sure your property would have the infrastructure capable of accepting additional temporary housing units, or any expansion opportunities would be highly likely on the property you already own.

• FIRST, Register at sam.gov. (TN declaration is DR-4832-TN)
• To be able to do business with the government, registration is required. There is no cost to register.
• Instructions on how to register are linked below.

If you still have residents who need individual assistance, please visit our Disaster Resource web page for a full list of resources. At a minimum, individuals need to register as soon as possible at https://www.disasterassistance.gov/. (TN declaration is DR-4832-TN)

As a reminder, companies interested in contracting with FEMA to help in relief efforts in any way must also be registered on sam.gov.

THA has been made aware of some power distributor areas requiring additional electrical permits and inspections inside NEW manufactured homes, prior to releasing the home to a customer.

New manufactured homes are inspected at the plant by state IPIA personnel and do not require an additional 2nd electrical inspection (and permit), locally. We have reported this issue to the Department of Commerce and Insurance and have specifically noted occurrences with Appalachian Electric Cooperative, Greeneville Energy Authority, and Sevier County Electric.

There will be a series of five meetings across the state in November and all Deputy Electrical Inspectors (DEIs) are required to attend these meetings. Director Jimmy Hightower will be at each of the five meetings to discuss the federal HUD-Code program and inspection process.

In the meantime, Marcus Frey, Electrical Program Manager, Commerce & Insurance, is conducting an investigation to determine what generated this 2nd inspection process for the inside of NEW manufactured homes.

ACTION: If you have been required to pull a second permit for an electrical inspection, for the specific purpose of testing the inside electrical wiring and components of a NEW manufactured home before a final release was granted, please e-mail Marla@tnmha.org, with your:

1. Permit #;
2. Cost of Permit; and
3. Name of Power Distributor.

The information will be collected and submitted to the Electrical Department and the Manufactured Housing Department of Commerce & Insurance.

HUD awarded the Manufactured Housing Institute (MHI) a grant to study the impact of removing regulatory barriers to manufactured housing to address the nation’s housing crisis. As part of this research, MHI has launched an industry survey to collect data and examples of zoning barriers that hinder the expansion of attainable housing. 

THA is collecting examples here in Tennessee, and is now reaching out to you for your input.

ACTION: If you have experience with local jurisdictions which have prevented the placement of manufactured homes either through an outright ban (permit denial) or possibly through acreage requirements, or stricter aesthetic requirements than placed on site-built homes, please e-mail your experience to Marla@tnmha.org.

You will need to provide SPECIFIC details which can be verified by researchers prior to submittal to HUD. If you have copies of permit denials, zoning paragraphs or customer letters of denial, that is certainly helpful, as well.

The THA Board of Directors is pleased to announce that Bill Boor, CEO of CAVCO Industries, Inc., will be joining THA members during the 2025 Annual Member's Meeting & 70th Anniversary Celebration in June 2025, at the HeartSong Lodge & Resort in Pigeon Forge, Tennessee.

Members should save the date! June 8 - 10, 2025!

THA Annual Member's Meeting Website!

The U.S. Department of Housing and Urban Development's (HUD) Office of Manufactured Housing Programs (OMHP) published a timeline recognizing industry milestones in honor of the 50th anniversary of the HUD Code.

The timeline begins with the National Manufactured Housing Construction and Safety Standards Act of 1974, includes many significant health, safety and performance milestones, and culminates in the recent HUD Code update, the largest to date.

In conjunction with the release of the timeline, OMHP Administrator Teresa Payne released a message commemorating the anniversary.

"Today's manufactured homes boast energy-efficiency that rivals site-built homes, and can incorporate smart home technology, sustainable materials, and innovative designs that cater to diverse lifestyles and needs," she said. "In an era of rising housing costs and a nationwide affordable housing crisis, manufactured homes offer a path to the American dream for countless families, seniors, and first-time homebuyers." 

Rep. Mike Lawler (NY-17) introduced the “Revitalizing America’s Housing Act,” on October 18. The bill, H.R. 10009, combines elements from several previously introduced housing-related bills with additional actions to create a package to increase housing supply, incentivize construction and address housing cost, among other housing solutions. In a press conference with local officials in Hudson Valley, New York, Lawler called for the construction of more single family housing and said, "The issues confronting our housing system are myriad and manifold and they require a comprehensive set of policy prescriptions to address."

The bill, containing 38 provisions, includes a number of MHI’s main legislative priorities, including language to prevent the Department of Energy from establishing energy conservation standards for manufactured housing and to restore HUD as the sole regulator for the construction of manufactured housing, including with respect to energy efficiency. The bill also removes the requirement in the law that manufactured homes are built on a permanent chassis, an important step toward allowing a broader range of home types to be built under the HUD Code.

The 209-page bill also requires HUD to annually report on significant regulatory barriers to affordable housing and how to reduce or remove them; enhances opportunity zones; bolsters the U.S. transformer supply chain; incentivizes localities to reform their zoning requirements; provides a business-related tax credit for certain development costs for the acquisition, rehabilitation, or remediation of qualified property; among other things.

The bill is cosponsored by Housing Subcommittee Chairman Warren Davidson (OH-8), Rep. Mike Flood (NE-1) and Rep. Andrew Garbarino (NY-2) and is the result of more than two years of work by the Subcommittee on policies to address the housing crisis. MHI has been engaged with the Subcommittee during this process and we are pleased that our priorities are included in Rep. Lawler’s comprehensive legislation.

In advance of the 2025 “Tax Super Bowl,” the House of Representatives’ Ways & Means Committee created “Tax Teams” earlier this year and accepted comments from interested parties.

MHI submitted comments highlighting how actions such as extending tax credit incentives for Energy Star® homes, ensuring any home purchase tax incentive applies to manufactured homes, and creating incentives for the replacement of non-HUD Code "mobile homes" would help increase the affordable housing supply for working families. Additionally, MHI detailed how lawmakers can support land-lease communities through measures like improving Opportunity Zone tax incentives, preserving Section 1031 like-kind exchanges, opposing proposals that undermine community preservation, and opposing the elimination of depreciation benefits based on rents.

In addition to its own letter, MHI also signed a coalition letter supporting the inclusion of the “Middle Class Mortgage Insurance Premium Act” in a tax package. This Act would make permanent the mortgage insurance premium tax deduction and increase the adjusted gross income phase-out to $200,000 ($100,000 if married filing separately.)

On October 10th, the Federal Housing Finance Agency (FHFA) released its new Manufactured House Price Index. The Index is based on data from real-property conventional mortgages acquired by Fannie Mae and Freddie Mac. Fannie Mae and Freddie Mac are Government Sponsored Enterprises (GSEs). GSE loans are land-home. The majority of manufactured homes are purchased as home-only. According to Home Mortgage Disclosure Act data, land-home loans accounted for less than 14% of manufactured home loans in 2023. These were the key findings from the Manufactured House Price Index: 

• The quarterly index found that manufactured home sale prices (purchase only) increased 7.9% from Q2 2023 to Q2 2024. In comparison, the FHFA's core House Price Index (HPI), which measures home prices for site-built homes, increased 5.7% during that same period. 

• For all transactions, manufactured homes with conventional mortgages acquired by Fannie Mae and Freddie Mac appreciated 6.9% over the past four quarters while site-built home prices increased 5.9%. 

• The median price of manufactured homes purchased with a real-property conventional mortgage issued through one of the GSEs, such as Fannie Mae or Freddie Mac, was $231,000 in Q2 2024. The majority of manufactured homes are purchased as home-only. GSE loans are land-home. According to Home Mortgage Disclosure Act data, these loans accounted for less than 14% of manufactured home loans in 2023. 

“FHFA’s new data resource on manufactured homes provides relevant, up-to-date information on an important but less-understood segment of the housing market,” said FHFA Director Sandra L. Thompson in the agency's press release. “In a housing market with elevated home prices, manufactured housing remains an affordable option. This new data should help advance discussions on responsible efforts to expand homeownership opportunities.” 

The Environmental Protection Agency (EPA) issued a final rule that will require drinking water systems nationwide to replace lead service lines within 10 years. The Lead and Copper Rule Improvements (LCRI) also strengthens tap sampling requirements and lowers the threshold for taking action (the lead action level) from 15 µg/L to 10 µg/L. Full details are available on the EPA website.

The Corporate Transparency Act (CTA) requires many companies doing business in the United States to report information about who ultimately owns or controls them to the Financial Crimes Enforcement Network (FinCEN). Most companies must report this information to FinCEN on or before January 1, 2025. Failure to report before the deadline could result in penalties.

FinCEN’s website hosts a wide range of resources for companies regarding filing the beneficial ownership information, including a series of nationwide Public Service Announcements (PSAs).  

More On This Topic

The following information is to provide you with more detail on this significant change in federal law which will impact nearly everyone operating a business through a legal entity such as a corporation, limited liability company, limited partnership or other similar entity. This is for informational purposes only and you should seek the guidance of your personal or corporate attorney, or accountant, if you have additional questions.

The Corporate Transparency Act (signed into law on January 1, 2021) expanded anti-money laundering laws and created new reporting requirements for certain companies doing business in the US beginning in 2024, and many [existing] small businesses are required to report information about their beneficial owners to the Financial Crimes Enforcement Network (FinCEN) in an effort to create a national database for use by national security and law enforcement agencies to prevent the use of shell companies for criminal activity. 

Additional information about the reporting requirements, including answers to questions such as “is my company required to report beneficial ownership information to FinCEN,” “who is a beneficial owner,” and “when do I need to report my company’s beneficial ownership information” is available on FinCEN’s beneficial ownership information webpage, https://www.fincen.gov/boi.

Important Filing Dates:

For existing reporting companies created or registered before 2024, the initial report is due by January 1, 2025.  For reporting companies created or registered in 2024, the initial report is due 90 days after the entity’s creation or registration.  For reporting companies created or registered after 2024, the initial report is due 30 days after the entity’s creation or registration.

If there is a change to previously reported information about the reporting company or its beneficial owners, an updated report must be filed within 30 days of the change.  So, it is imperative that your company implements a system to identify reportable changes and file an updated report with FinCEN in a timely manner.  The penalties for willfully failing to file both initial and updated reports are steep-$500 per day that the report is late, up to $10,000 and imprisonment for up to two years.

How to File:

• BOI reports must be filed electronically. FinCEN’s e-filing portal, available at https://boiefiling.fincen.gov/, provides two methods to submit a report: (1) by filling out a web-based version of the form and submitting it online, or (2) by uploading a completed PDF version of the BOI report.  The person who submits the BOI report will need to provide their name and email address to FinCEN.  There is no fee for filing the report. For online step-by-step instructions, visit https://boiefiling.fincen.gov/help.

What Information Must be Provided:

• Beneficial ownership information (BOI) must be reported for the reporting company’s beneficial owners and (for entities formed or registered after 2023) company applicants.  BOI includes an individual’s full legal name, date of birth, street address and a unique ID number.  The unique ID number can be from a non-expired US passport, state driver’s license, or other government-issued ID card.  If the individual does not have any of those documents, then a non-expired foreign passport can be used. An image of the document showing the unique ID number must also be included with the report.

Beneficial Owners:

• Two groups of individuals are considered beneficial owners of a reporting company: (1) any individual who directly or indirectly owns or controls at least 25% of the ownership interests of the reporting company; or (2) any individual who exercises substantial control over the reporting company.

• Individuals with substantial control are those with substantial influence over important decisions about a reporting company’s business, finances, and structure.  Senior officers (president, CFO, general counsel, CEO, COO, and any other officer who performs a similar function) are automatically deemed to have substantial control, as are individuals with the authority to appoint or remove senior officers and board members.  There is no requirement that these individuals have actual ownership in the company to be considered a beneficial owner for reporting purposes.

Company Applicants:

• The company applicant is the person who actually files the document that creates or registers the reporting company (e.g., an attorney).  Company applicants must provide the same information that is required of beneficial owners, but only if the reporting company is formed or registered after 2023.  Because of the difficulty in tracking down information about company applicants for reporting companies that have been in existence for a number of years, reporting companies formed or registered before 2024 do not have to supply BOI for their company applicants.

FinCEN Identifiers:

• Individuals and reporting companies can request a FinCEN Identifier (FinCEN ID) to use in place of supplying detailed information on the report.  A FinCEN ID is a unique number assigned by FinCEN which is obtained by submitting the same information as is required of a beneficial owner or reporting company.  A FinCEN ID may be useful to individuals that prefer to send their personal information directly to FinCEN rather through a reporting company, or to individuals that may be required to supply information as a beneficial owner or company applicant of several reporting companies.

Again, this is for informational purposes only and you should seek the guidance of your personal or corporate attorney, or accountant, if you have additional questions or need further guidance.

ATTENTION RETAILERS!

ENTER YOUR CUSTOMERS TO WIN $2,500

Two (2) PRIZES WILL BE AWARDED

HOMES MUST BE SOLD BETWEEN

April 1, 2023 - March 31, 2025

Announcement of winners will be made during THA's 70th Anniversary celebration, scheduled for June 8 - 10, 2025.

2025 THA Annual Member’s Meeting

"Power of the Past - Force of the Future"

June 8 - 10, 2025

Dollywood's HeartSong Lodge & Resort

1210 Dollywood Resorts Blvd

Pigeon Forge, TN 37863

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 Annual Meeting Website: https://thaannualmeeting.com/

This annual meeting website has been established for the purpose of collecting and posting annual notices and ongoing developments for future member meetings or special events. The main website will link to this site and save space on the member’s ‘business tool’ website to allow for more member photos of those special events!

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.

Follow us on social media!

https://www.facebook.com/tnmha.org

https://www.instagram.com/tennesseemha/

https://www.linkedin.com/company/tennessee-housing-association/

https://www.youtube.com/@tennesseemha

Download the graphics and videos from your e-mails!

If you missed them, go back and search the dates or the subject lines with these titles...

September dated 9/12/2024 -

"Transforming Housing Solutions: The Future of Development with Manufactured Homes"

October dated 10/7/2024 -

"Trick or Treat Yourself to a New Home!"

Use these links to make changes or additions to your TennesseeManufacturedHomes.com listing.

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.

Discounts are available for THA member companies ONLY!

(Email Office@tnmha.org for your member discount coupon, prior to purchase!)