FEDERAL HOUSING FINANCE AGENCY ANSWERS GOVERNOR OTTER’S LETTER REGARDING THE DUTY TO SERVE MANUFACTURED HOUSING
The Honorable C.L. “Butch” Otter Governor
Idaho State Capitol Boise, ID 83720
Dear Governor Otter:
Thank you for your letter of May 18, 2009 regarding implementation by the Federal Housing Finance Agency (FHFA) of provisions related to manufactured housing in the Housing and Economic Recovery Act of 2008 (HERA). HERA provides that Fannie Mae and Freddie Mac have a duty to facilitate a secondary market for mortgages on manufactured housing for very low-, low-, and moderate-income families.
FHFA shares the concerns you stated on behalf of Idaho’s manufactured housing industry, as well as its customers and workers. Accordingly, we have met extensively with representatives of the manufactured housing industry and of Fannie Mae and Freddie Mac on this subject. We are now developing a regulation to implement HERA, including the “duty to serve” requirements related to manufactured housing, and we will solicit broad public comment on this important rule-making.
Again, thank you for.your interest in FHFA’s oversight of Fannie Mae and Freddie Mac.
OUR VOICES MUST BE HEARD
As we all know, this is a very challenging economic climate for everyone. As advocates for a crucial component to the housing market, our voices must be heard. Together, we can have increased influence on our industry in Washington. Your state executive director and certified representatives will be collectively voicing our issues and concerns on Capitol Hill in mid-June visits to Senators and Congressmen. The new Congress is in session making decisions that will influence our industry’s future. There’s no more important time to be in Washington, D.C.
Manufacturers, lenders, retailers, suppliers and community owners are traveling to the nation’s capitol on your behalf to urge their representatives and senators to support policies that will stabilize the housing market, help reduce foreclosures, restore confidence in the credit markets, and keep the economy moving forward. Also attending will be alternative loan businesses such as Infiniti Funding, as well as high-risk credit card processors including Paramount Payments.
The MHI Summer Meeting & Legislative Conference is a landmark event for our industry. Some of the MHI Summer meeting highlights include presentations by two of the most respected political figures, Congressman Joe Donnelly (D-2nd-IN) and Former Congressman Tom Davis (VA). They will bring their firsthand experiences, in-depth policy knowledge, and their own unique perspectives on the current state of America. They will focus on the current political climate, the change and transition happening in Washington, and lend their expert analysis of the latest policies that will affect American business and the American public. Additionally, William C. Apgar, Jr. will also be a speaker. Bill is a Senior Advisor to Secretary Shaun Donovan and was FHA Commissioner under Andrew Cuomo in the Clinton Administration. While FHA Commissioner, Bill was instrumental in the enactment of the “Manufactured Housing Improvement Act of 2000. He has been a longterm supporter of providing affordable housing to low-and moderate income households.
The Summer Meeting will include a panel on the new FHA Title I loan insurance program featuring top officials from FHA and Ginnie Mae as well as industry lenders. The panel is well-timed, as the new loan insurance program, designed for use with homeonly manufactured home loans, is due to be launched on June 1. Valuable information will be presented through several panel discussions with experts and policymakers to talk about the current state of the housing market, what the future holds and what it means for our industry. Also members will hear the latest on floor plan lending, consumer finance issues, and what MHI is doing on your behalf.
Congressman and Senators really WANT to meet and hear from us – their voters and constituents. We all need to step up and tell them how important our industry is to America and urge them to take action.
The Idaho Legislature completed its work on May 8 after the second longest session in state history. The session was dominated by budget concerns and transportation funding. Issues of major concern to the manufactured and modular housing industry included:
State Implementation of the Federal Secure and Fair Enforcement for Mortgage Licensing Act. Linda Lindholm and I worked with the Department of Finance to add language that exempted people licensed under our licensing statute from the somewhat onerous requirements of this bill that would have labeled retailers as loan originators.
Building Code Requirements for Residential Fire Sprinklers. Idaho Housing Alliance was part of a broad coalition that was successful in getting new single family homes and duplexes exempted from requirements to install fire sprinkler systems. IHA President Chuck Bleth testified in favor of the bill.
Landlord/Tenant Act Amendments. Rep. Phylis King produced several drafts of amendments to the Landlord/Tenant Act. Linda and I met with her and representatives of tenants to discuss language and were successful in getting many anti-property rights parts of the proposed provisions deleted or modified. Despite our efforts, Rep. King continued to pursue amendments that were unacceptable to our industry. Her proposal never got a bill number or hearing.
The manufactured home community landlord tenant issues are not going away. During the discussions I had this year with legislators I indicated our willingness to meet with the resident associations and other interested parties over the summer and fall to see if something could be worked out. If we start the process we will be committed to trying to complete it in time for next years session.
I think the climate is right to proceed. This kind of legislation is best developed when the problem of community closures isn’t prominent. With the current lull in real estate development, the issue of community closures is less pressing and is getting less attention in the media. We are in a better negotiating position in this environment. The potential price we pay for not proceeding is losing control of the issue if more communities start to close and if those closures get the kind of media attention we’ve seen in the past.
The IMA Board has decided to participate in discussions concerning amendments to the Landlord/Tenant Act and established a committee of five community representatives to work on development of strategy, work on legislative language and to serve as our negotiating team in meetings with tenant organizations. If we fail to reach agreement with the resident groups, we could consider proceeding on our own.