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Contact: Merrit Gillard,

Dec 14, 2016

CFED Applauds Duty to Serve Rule that Strengthens Financing Options for Owners of Manufactured Homes


Contact: Merrit Gillard, 202-207-0121

Washington, D.C. -- The Federal Housing Finance Agency (FHFA) released its long-anticipated final Duty to Serve rule yesterday, which specifies how Fannie Mae and Freddie Mac (the Enterprises) will meet their obligations to support three underserved markets, including manufactured housing. The rule has the potential to significantly improve housing financing options for buyers of manufactured homes who are often relegated to high-cost, short-term loans that put vulnerable homeowners at unnecessary risk.

"The Duty to Serve rule is an important step toward ensuring that low- and moderate-income Americans have the opportunity to build wealth through homeownership," said Andrea Levere, president of CFED. "With this rule, the FHFA has responded to the concerns of manufactured home residents and advocates with a set of tools to advance safer, fairer and more affordable lending options for families to make their dreams of homeownership become a reality."

The FHFA included a number of strong provisions recommended by CFED and its partners during the public comment period, including:

  • Support for a chattel loan pilot. The rule will make Duty to Serve credit available for Enterprise activities supporting manufactured homes titled as real estate or as personal property. This is important because most states present significant barriers to titling manufactured homes as real property and instead classify these homes as personal property, like cars. CFED and other advocates strongly endorsed a safe chattel pilot for loans on manufactured homes titled as personal property, and the final rule stipulates that such a pilot would be eligible for Duty to Serve credit. The rule also offers Duty to Serve credit for Enterprise research into a chattel loan program, which is vital to creating a safe and sustainable loan product.
  • Removing the manufactured home community size standard for blanket loans. The original Duty to Serve proposed rule, released in December 2015, would have granted Duty to Serve credit to the Enterprises for blanket loans to manufactured home communities with 150 or fewer pads, without regard to other factors. CFED and its partners expressed reservations about using any maximum threshold for Duty to Serve credit, since community size is no indication of good consumer protections or long-term sustainability. CFED is pleased with the acceptance of its recommendation that Duty to Serve credit be available to blanket loans for community purchases by residents, nonprofits and government instrumentalities, as well as communities that protect certain minimum tenant protections. This is good because Duty to Serve should advance sustainable homeownership, which mission-driven communities and tenant protections can help ensure.

CFED applauds the FHFA for taking action to meaningfully expand opportunities for manufactured home owners to build stability and financial security through homeownership, and looks forward to working with Fannie Mae and Freddie Mac to build on this foundation to further advance the financial futures of low- and moderate-income homeowners.

To read CFED's full comment letter to FHFA, click here.


CFED's work makes it possible for millions of people to achieve financial security and contribute to an opportunity economy. We scale innovative practical solutions that empower low- and moderate-income people to build wealth. We drive responsive policy change at all levels of government. We support the efforts of community leaders across the country to advance economic opportunity for all. Established in 1979 as the Corporation for Enterprise Development, CFED works nationally and internationally through its offices in Washington, D.C.; Durham, North Carolina, and San Francisco, California.

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