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Renia Ehrenfeucht
New Mexico
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I am submitting comments on Fannie Mae’s strategic priorities for the manufactured housing markets. I support the plan’s focus on better understanding chattel markets and providing liquidity to support chattel loans and conventional mortgages for manufactured homeowners. My comments here focus on manufactured housing communities. I am a professor in the Community and Regional Planning Department at the University of New Mexico. I have conducted a research project in which I spoke with representatives of nonprofit organizations and community land trusts about barriers and opportunities to acquiring manufactured housing communities as an affordable housing preservation strategy. The Duty to Serve plan recognizes that manufactured housing is an important form of naturally occurring affordable housing and very affordable homeownership. Manufactured housing communities are an important part of this but preserving manufactured housing and facilitating asset creation are impeded by an ownership structure that makes homeowners at risk of park closure, deteriorating conditions and limited options to sell and upgrade their homes. While pad production regulations are important (Regulatory Activity D), facilitating transition from investor ownership to ownership by a community land trust, a nonprofit organization, a public entity or residents provides a more stable, long term solution to maintaining high quality affordable housing. For Regulatory Activity C, when conducting outreach and research on MHC, one comment is that this section adds community land trusts. Community land trusts, as a nonprofit model that promotes collective governance of land with individual homeownership, are experienced with MHC’s dual land tenure system. A few community land trusts own MHC and more have tried to acquire them. The comment about including community land trusts extends to all cases when nonprofit organizations are considered in order to support different types of nonprofits organizations. For Regulatory Activity C, Objective 3, my comment is that it is critical not to create preferences for resident-owned communities over community land trusts and other nonprofit organizations. It is equally important that Fannie Mae pilot a program that acquires MHC mortgages on nonprofit and community land trust owned properties, or develop a pilot that can include all alternative land tenure options. While more research is needed to understand the dynamics of resident ownership, it is likely that those communities that successfully become resident owned have relatively more resources (human and monetary) than those for which a nonprofit organization or community land trust is a better model. It is likely that manufactured housing communities serving residents with the fewest resources will be more successful with a nonprofit or community land trust owner, and some of these entities need access to credit to acquire a MHC. Another factor that needs to be directly addressed is access to credit for ‘renovation’ loans to upgrade infrastructure when manufactured housing communities are purchased by residents, community land trusts and other nonprofit organizations. In some cases, the land must also be reconfigured to make sites that can accommodate homes built to contemporary HUD standards. In addition, manufactured housing communities are located in areas with risks of flooding and reconfigured sites can reduce environmental hazards. Aging infrastructure or environmental hazards can impede the purchase of a MHC by residents, nonprofits or community land trusts. Thank you for your consideration.

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