FHFA Sets Schedule for Input on ’22-24 Duty to Serve Plan

FHFA duty to serve
Dr. Lesli Gooch, the CEO of the Manufactured Housing Institute, provides input on behalf of the manufactured housing industry regarding the need for support in chattel lending during a virtual meeting on March 25, 2021.

The Federal Housing Finance Agency has published the proposed Underserved Markets Plan for Fannie Mae and Freddie Mac for 2022-2024.

The Housing and Economic Recovery Act of 2008 mandates that Fannie and Freddie serve three specific underserved markets by increasing the liquidity of mortgage financing for families with very-low, low and moderate incomes.

The Duty to Serve underserved markets identified are manufactured housing, affordable housing preservation, and rural housing.

FHFA asks for and will take public input on the 22-24 proposed plans within a 60-day period that ends July 19.

MHI believes FHFA should not allow Fannie Mae and Freddie Mac to abandon efforts to meet the needs of manufactured home buyers.

“Chattel loans represent the vast majority of manufactured home loans but the GSEs have been going backwards when it comes to their statutory Duty to Serve manufactured housing,” Gooch said. “Now, Freddie Mac has abandoned the effort completely and Fannie Mae only promises to ‘consider’ the viability of a chattel loan pilot program. This was not the intent of Congress for meeting the affordable homeownership needs for the manufactured housing market.”

Gooch said Fannie Mae and Freddie Mac need to re-affirm their previous commitment to buying – and ultimately creating a flow and securitization program – for chattel loans. And FHFA needs to hold them accountable to that.

“MHI has been pleased to see the efforts that Fannie Mae and Freddie Mac have taken and plan to continue to take on increasing the volume of manufactured home real estate loans, including the creation of programs for the industry’s new class of manufactured homes – CrossMod Homes,” she said.

Calabria Confirmation Lesli Gooch MHI
Dr. Lesli Gooch, MHI’s CEO, met with FHFA Director Dr. Mark Calabria on December 12, 2018, to talk through his nomination and DTS activity.

Enterprises’ Focus on Manufactured Home Loans Essential

The focus of DTS credit should remain on secondary market support for the financing of homes within land-lease communities (chattel financing) as opposed to the commercial financing of the communities themselves, Gooch said.

“Further, DTS should not favor one form of community ownership over another. Professionally managed communities provide high satisfaction levels of land-lease homeowners,” she said. “Residents of these communities say they are less likely to pay additional maintenance fees and value professionally managed amenities over those found in other forms of community ownership. In fact, research shows these communities provide a preferable lifestyle for many.”

Gooch said incentivizing one form of ownership over another will be a disservice to those in need of safe, decent, quality attainable homeownership opportunities.

“FHFA must hold Fannie Mae and Freddie Mac accountable for meeting their statutory Duty to Serve manufactured housing,” Gooch said.

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