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Comment

Thank you for the opportunity to respond to your Request for Input (RFI) on how the Federal Housing Finance Agency (FHFA), in its oversight of Fannie Mae and Freddie Mac, can best provide affordable housing opportunities for renters.
The Family LLLP listed above is invested in several manufactured home land lease communities as well as holding stock in a company that is primarily involved in manufactured home communities. I worked in the manufactured home industry as a regional property manager from 1976 until my retirement in 2015 managing properties in 29 states at one time or another during this period of time. I interacted directly with the residents of the MH properties that I managed so I have a grass roots knowledge of who lives in manufactured home communities.
If it is the goal of the proposed regulations to improve affordable housing, more regulations is not the answer. The government regulations enacted by the SAFE Act and Dodd-Frank were supposed to help the lower end of the economic ladder afford housing and both caused the absolute opposite to happen. Prior to the SAFE Act and Dodd-Frank, owners of manufactured home communities would purchase or otherwise obtain homes in their communities, refurbish the homes and then sell the homes and carry the loan. This was necessary because there are no lenders for many of the people who wish to live in manufactured home communities. Prior to the SAFE ACT and Dodd-Frank the group of communities that I was overseeing put 300 plus families into their own home with payments they could afford. These buyers were the typical lower economic group who have jobs, work hard but do not have much or any credit so none of the traditional avenues to purchase a home are available to them. We would run the potential purchaser and space renter through the standard background and credit checks but if nothing negative came back and they could prove employment we would often sell them a house with a minimal down payment ($500 to $1,000) and structure the payments on the balance to something they could afford. In the 10 years or so that we offered this option the default rate on the loans was approximately 5% and often due to a job change out of the area or some family issue. Our policy was that if you left the home clean and did not destroy it on the way out we would not chase you for the balance owing. We simply did the necessary repairs and put the home back on the market. It was essentially the used car business. The vast majority of the people who purchase our homes were great residents and liked living in our communities, they also realized that we were their only option for home ownership. The majority of the homes that were returned to us were in better condition than when the original purchase was made. Then along came the government to save these people with the SAFE Act and Dodd-Frank which effectively said community owners could not lend their own money without a raft of licensing and meeting draconian regulations. The net impact was that the program that allowed the community owner to keep their sites full and provided affordable housing to those lower economic people was forced out of business. The penalties for not adhering to the draconian regulations made the program not feasible for the vast majority of community owners.
The government effectively prevented hundreds of lower economic people from owning their own homes.
It is my hope that whomever is in charge of the proposed regulations will realize that most government interference in the free market providing of affordable housing has the opposite effect for the majority of lower income people. The best thing that could happen would be to have some if not all of the existing regulations repealed.
The last thing that would considerably help affordable housing in the manufactured housing segment would be for Freddie, Fannie or any other financial arm of the government to create a secondary market for manufactured home loans and treat it like conventional housing. When the manufactured housing business can put people in homes for under $100,000, there should be many more people living in manufactured housing. it is a great alternative but there are no good lenders in this market who will cater to the lower economic level people because there is no secondary market for the paper. The manufactured housing industry continues to suffer from the old adage that the scariest words in the english language are "We are from the government and we are here to help you".