Skip to content

CHLA, MHI, and MBA Send Joint Comment Letter Commending RHS on Their Proposed Rule Changes 

(Washington D.C.) – The Community Home Lenders of America (CHLA), The Manufactured Housing Institute (MHI), and Mortgage Bankers Association (MBA) submitted a joint comment letter in response to the Rural Housing Service (RHS) proposed rule which would give borrowers increased mortgage loan options to finance the purchase of manufactured homes, under RHS Section 502 and SFH Guaranteed Loan Program. 

“MHI, MBA, and CHLA are interested in working with RHS to explore the causes and solutions for RHS manufactured home loans so significantly trailing the ratio of manufactured home loans in the single-family home markets,” said Scott Olson, Executive Director of CHLA.

The letter commends RHS for the three constructive changes associated with the proposed rule, which would: 

1.       Update the current regulations language to meet conditions of the ownership requirements for energy efficient manufactured and modular home financing in Land Lease Communities Operating on a Nonprofit Basis pilot (and expand this to include Tribal Lands). 

2.       Remove the administrative requirements from the regulations for review and approval of applications from manufactured housing dealers for direct loans. 

3.       Revise the definition of “Manufactured home” in the regulations to remove reference to RHS Thermal Performance standards for Direct Loans.

The joint comment letter closes by supporting these proposed rule changes and proposes extended work with RHS to “identify other potential impediments to the ability of RHS direct and guaranteed loans to achieve their full potential with regard to the financing manufactured home loans. In particular, we have heard concerns about the Direct Loan program regarding long approval times and requiring an on-grade frost wall foundation system (which can burden the homeowner with substantial additional unnecessary expenses) instead of manufacturer/state approval systems.”