July 10, 2017 — Comments

These comments will focus on the Plans’ activities and objectives, which aim to improve the manufactured housing marketplace. However, the three markets addressed in the Plans overlap considerably, and manufactured housing cannot be addressed in a vacuum. We strongly encourage the Enterprises and the FHFA to encourage innovations that can impact multiple markets. For example, owners of older mobile homes in Appalachia pay disproportionately high utility costs, which threaten their housing stability. Effective Enterprise strategies to replace these homes with highly energy-efficient manufactured homes would support both the rural and manufactured housing components of the Plans, as well as help standardize underwriting for energy efficiency, a serious need in today’s mortgage market.