NAR MHI Comment Letter to Ginnie Mae Re FHA Title I Program

Issue Date: September 26, 2022


On September 26 The Manufactured Housing Institute (MHI) and NAR provided comments to Ginnie Mae in response to the Agency's Request for Information on potential policy enhancements for FHA’s Title I Manufactured Home Loan Program.
 
The original goals of the Federal Housing Administration (FHA) were to stimulate housing construction, broaden opportunities for homeownership, and ensure an adequate and balanced flow of mortgage credit. It has done a commendable job, ensuring that qualified borrowers have access to mortgage financing. However, the program is currently failing many families who wish to purchase a manufactured home.
 
The letter urges Ginnie Mae to review and revise their requirements so that they are set no higher than is necessary to protect itself against counterparty risk of loss in Title 1 loans. FHA is designed to ensure access to homeownership for qualified low and moderate-income families. The Title I program is not meeting this goal. Significant changes are needed to make the program operational, and to ensure families can obtain the appropriate financing for their home. We urge Ginnie Mae to work with FHA to create a functioning Title I personal property loan program, as well as a sustainable securitization program for these loans.