The Manufactured Housing Institute Penned a Letter to the Consumer Financial Protection Bureau Asking to See Change that Supports Financing for Manufactured Housing
The Manufactured Housing Institute (MHI) hosted Mick Mulvaney, acting director of the Consumer Financial Protection Bureau, at the Legislative Fly-In in Washington, D.C., this summer.
Acting Director Mulvaney expressed a willingness to work with MHI to address regulations that hinder financing for manufactured housing. Following the Fly-In, MHI sent a letter to the bureau in response to Mulvaney’s comments.
At Mulvaney’s recommendation, MHI’s letter stressed the importance of prompt implementation of Section 107 of the “Economic Growth, Regulatory Relief, and Consumer Protection Act” (Pub. L. 115-174 § 107), regarding the definition of loan originator and the need for adjustments to the Home Ownership Equity and Protection Act’s (HOEPA) “high-cost mortgage” triggers.
MHI Asks For ‘No-Action Letter’
MHI asked the bureau to issue a “No-Action Letter” confirming that it will not pursue administrative action against any retailer or seller while it revises its regulations to be consistent with the new law. The recently passed definition clarifies that manufactured housing retailers and sellers are no longer considered mortgage originators simply because they provide customers with some assistance during the mortgage loan process.
Regulations need to be changed to be consistent with the law. And, such changes will take time because they have to go through a formal rule-making process. A “No-Action Letter” would provide cover for retailers and sellers who want to immediately take advantage of the flexibilities offered by the new law.
Also, MHI requested that the bureau make immediate adjustments to the “high-cost” thresholds for smaller-dollar manufactured home loans under HOEPA, so these loans are not unfairly swept under this designation simply due to their smaller size.
MHI will continue to utilize its relationships with administration officials and manufactured housing champions in Congress to advocate for these changes. At MHI’s June 2018 Legislative Fly-In, members of Congress were asked to contact Acting Director Mulvaney about them. MHI raised these issues again with Mulvaney and his leadership team, stressing that both requests will spur lending for manufactured housing without impacting existing consumer protections.
MHI said it will continue to pursue these and other legislative and regulatory changes that support improved availability of financing for consumers interested in purchasing a manufactured home.