The first MHI Summer in several years was held at the Alexander Hotel in Indianapolis, IN on June 8-10, 2014. IMHA was well represented among near 100 registered attendees by Executive Director, Frank Bowman and Board Members, Ken Rishel and George Allen.
MHI presented an overview of the new CQ Engage program for contacting your legislators (federal, state and local). The system emails legislative action requests and alerts, provides contact information for all your elected officials by entering your zip code and permits the direct sending of emails to the targeted elected officials with the click of your mouse button on your computer. Over 5,600 emails have been sent to members of congress using the system in the past month. If you have not signed up to receive industry emails using MHI’s system do so by clicking here.
MHI is also beta testing a tracking mechanism for state and local legislation in a few states for a trial period of one year (May to May). Illinois has been chosen as a participant in the program. We are looking forward to seeing how it works for our association and will be providing updates as the test continues.
HUD Administrator in the Office of Manufactured Housing Programs, Pamela Beck Danner, was the keynote speaker for the event and sat in on a few committee meetings to hear our issues first hand. Ms. Danner has only been on the job for six weeks, but is no stranger to the MH Industry and will certainly champion MH issues within HUD and interactions with other federal agencies.
There was considerable discussion on attached garages and the upcoming enforcement efforts at HUD regarding added loads from the garages, carports, patios and porches. Final rules regarding “on-site construction” are pending review and are expected to be issues soon. Enforcement efforts will require Manufacturers to request and receive Alternate Construction (AC) letters from HUD to add garages going forward in time and also require a review of all existing manufactured structures with accompanying Subpart I reports as necessary looking back. Look back may be for a period of one or more years.
Red flags that will likely trigger Subpart I compliance issues are:
- Any units manufactured with 3 exterior doors
- Units manufactured with 2 exterior doors, one of which is fire rated
- Units manufactured with beefed up roof loading for perpendicular additions
- “Garage Ready” advertising and sales programs
No AC letters are required if you are not taking the home out of HUD compliance but there may be other issues that come into play with Subpart I like various statutes of limitations, bankruptcies, etc.
RVIA has initiated changes to add clarity between the definition of park model RVs (a.k.a. recreational park trailers), which are intended for temporary destination occupancy, and Manufactured Homes, which are designed, built and intended as permanent dwellings, under current HUD regulations. It appears that the issues distills down to whether Dodd-Frank consumer finance issues apply to consumer lending on RVs and some tax authorities who are seeking to tax RVs as manufactured homes. No action was taken by the MHI Board.
