ADVANCED POLICY CONSULTING, LLC

Monitor manufactured housing issues. Lobby against a Department of Energy proposal that uses the 2021 International Energy Conservation Code. Regulation proposal EERE-2009-BT-BC-0021-0592. The law requires the DOE to establish energy standards for manufactured housing based on the most recent version of the IECC unless using such a code is found not to be cost effective. The DOE's proposal is not cost effective as drafted and would increase the price of manufactured housing. Place language in the Energy and Water (E&W) Appropriations and Transportation, Housing and Urban Development (THUD) Appropriations legislation to fix the DOE regulation so it is workable. Same regarding any Senate appropriations legislation. Support changes to appropriation bills to ensure that HUD would be the primary regulator over DOE regulations that would impact the HUD housing code for manufactured housing. HUD should update FHA's guidelines to ensure Title I and Title II programs support manufactured housing. Support federal efforts to preserve and develop manufactured housing communities to include all eligible homeownership types. Affordable HOMES Act HR 5184

Monitor tax issues as they relate to manufactured housing. Support Section 45L Energy Efficient Home Credit.

Congress took a critical step in 2005 to include home-only loans in the definition of a principal residence- but without aligning 1322(b)(2), the protection remains incomplete. Congress should enact a clarifying amendment to extend 1322(b)(2)s protection to all loans secured by a debtors primary residence, as it intended with the 2005 amendment. This would prevent cram downs on manufactured home-only loans, which constitute nearly two-thirds of all loans in the manufactured housing market. By aligning treatment with site-built home mortgages, the bankruptcy code will help preserve lending in this vital affordable housing sector.