On October 12, TMHA submitted our comment letter to the Department of Housing and Urban Affairs (HUD). The comment letter was in response to HUD’s notice of proposed rulemaking, which invited public comments on amendments to HUD's affirmatively furthering fair housing (AFFH) regulations.
HUD is looking to make changes that will:
Minimize regulatory burden while more effectively aiding program participants to plan for fulfilling their obligation to affirmatively further the purposes and policies of the Fair Housing Act; create a process that is focused primarily on accomplishing positive results, rather than on performing analysis of community characteristics; provide for greater local control and innovation; seek to encourage actions that increase housing choice, including through greater housing supply; and more efficiently utilize HUD resources.
There were 1,449 total comments filed with HUD. TMHA joined MHI and our numerous industry state associations in submitting comments primarily focused on improving the acceptability and opportunity for manufactured housing.
Our comment letter focused on the aspects of local control, increasing housing choice, increasing housing supply, and better use of HUD resources.
We requested that HUD examine policies and implement solutions that preserve housing choice options that would include manufactured homes. Additionally, we asked that HUD ensure when state and local housing programs are designed that are supported by HUD and federal tax dollars that these programs be required to include manufactured housing and include them in such a way as to achieve parity with the other housing options. And if the local programs do not include manufactured homes, then they should have an obligation to disclose the basis for this housing choice exclusion. We also asked that we are included on a fair playing field, and if we are to be excluded locally, a mandated justification for manufactured home exclusion or disparate treatment from those local programs that HUD must scrutinize vigorously.
This notice of proposed rulemaking is the start of a long process HUD is undertaking. The ultimate results of our industry-wide efforts will not be known for a while, but we will remain vigilant in our advocacy efforts throughout.