Billions in Economic Harm to Millions of Mobile Home and Manufactured Homeowners – FHFA Attorney Kevin Sheehan Responds to Mobile and Manufactured Home Living News Publisher’s “Concerns”

Even though tens of millions of Americans understandably believe that “the system is rigged,” the case can be made that the system is more rigged than most realize. The response from the Office of General Counsel at the Federal Housing Finance Agency (FHFA) to this writer and MHLivingNews publisher L. A. “Tony” Kovach is an example of that which will be unpacked below. Senior FHFA attorney Kevin J. Sheehan message below is in response to a formal FHFA “Listening Session” related public statement which arguably exposed the harm being caused to literally millions of mobile and manufactured homeowners. No less important is the harm caused to tens of millions of renters, millions of conventional housing owners, taxpayers, and most others. For reasons found in linked reports found further below, only a few who are benefiting from the currently “rigged system” are not being harmed.

In a step-by-step fashion, the following will make some of the key points above that led to this message from Sheehan to Kovach shown below. Note that FHFA attorney Sheehan copied several other FHFA team members involved in this issue in his email that was time-stamped April 23, 2021 at 4:51:38 PM EDT. The quotation mark is not in the original. That quote symbol is shown to reflect to  new and longtime readers alike that the comments shown are being directly quoted. The word “Controlled” is part of the original, and is rather common in emails that are outgoing from a federal official to others. See the screen capture of the item below linked here.



quoteMHLivingNewsPXMr. Kovach—Thank you for your note.  In recognition of your concerns about the video and transcript, we have revised those to omit your presentation.   FHFA has posted your full written remarks as you previously requested, and those written remarks will remain posted.  However, if you still would like to present your remarks by video, we can work with you to record and post your statement in the same way that the listening session itself was recorded and posted.  Thanks, Kevin

Kevin J. Sheehan
Office of General Counsel
Federal Housing Finance Agency


According to the FHFA website, “Kevin Sheehan, Associate General Counsel, Office of General Counsel.” Per attorney Sheehan’s LinkedIn profile is the following.

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One must keep in mind that the FHFA is responding to this statement made as shown in report linked below during their so-called  listening session.

As a disclosure, this is not about ego or chest thumping. Rather, it is to highlight the fruits of efforts that have been ongoing for years to benefit consumers and white hat (ethical, honest) independent businesses alike. With the proper credit, the research found published at the link below could be useful to any others that want to make intelligent use of the years of study, reporting, and efforts to break the logjam that has for too long harmed literally millions of Americans.


The full text of Kovach’s public comments to the FHFA are found in this report. Those comments carefully cross-linked years of research, all summed up in a ten minute talk. The transcript of that talk is linked here.


The statement by this writer, acting in a professional but not a journalistic capacity when speaking to the FHFA and others on 3.25.2021, is attached as a download here. That download is currently available on the FHFA website too, at this link here. It is currently only 1 of 3 presentations that are shown independently of the transcript of the other speaker-presenters made on 3.25.2021. Will that presentation by Tony Kovach to the FHFA remain unchanged and posted there? Sheehan’s message says yes. But the fact that they have removed an accurate transcript and replaced it with another that is no longer accurate – and did so without any update notice on their own webpage – raises new concerns. See the evidence-and explanation linked here. That raises an Orwellian 1984 style “memory hole” issue, another question or concern which only time will reveal.


Why This Issue Matters to Millions…

Why do those items merit a careful, even a repeated reading and sharing by mobile and manufactured homeowners, affordable housing advocates, and most others?

The answer to that can be spotlighted in part by this comment quoted below from four co-authors writing for the Urban Institute.

Lower appreciation for manufactured housing may be because of the lack of financing options available for older manufactured homes, which affects resale value.” While accurate, the case can be made that the same holds true for all manufactured homes. Namely, a “lack of financing options” impacts all resale values. That is true for all housing, not just mobile or manufactured homes.

The good news? The Urban Institute researchers correctly said that research does point to the fact that manufactured homes can and do appreciate. But because of fewer financing options, they may lag behind the appreciation rates of conventional housing. As those four Urban Institute researchers framed it (italics added), “While manufactured homes have lower initial costs, the homes do not have the same price appreciation of site-built homes. Yet much of the appreciation in single-family, site-built home values is because of the appreciation of the land, not the structure. Since 2000, the value of the land has, on average, appreciated 2.35 times the rate of the structures.”

Note that the FHFA came out with their own research which stated that manufactured homes do appreciate. The Urban Institute and HUD Secretary Ben Carson are among those who later referred to that FHFA study, and why it was important to manufactured homeowners, as well as those who are seeking affordable home ownership.

Note that years before either of those studies, MHLivingNews made a similar evidence-based point. Namely, that manufactured homes appreciate, or decline in value, for the same types of reasons as conventional housing does. When someone relies of facts and evidence, facts can be stubborn and useful things.

In pondering the meaning of that Urban Institute and FHFA research, keep in mind that former Duty to Serve (DTS) manager Jim Gray made this admission.


While true, this is an understatement. What this farewell message does not answer is why is it that after a dozen years had elapsed, so little progress has been made? Who does the status quo benefit? Who does it harm? The answer to those questions and more are found in the four pages summary with hotlinked references and evidence that can be downloaded from this link here. That same document is currently on the FHFA website at this page linked here.


That may have ranked among one of the great understatements of the year. A more accurate statement could have been if he had said that the FHFA, Fannie Mae, Freddie Mac, and others in the mix have so allowed or caused the DTS law to be twisted or ignored in a fashion that jut happens to suit the benefits of the few at great harm to the many. MHProNews’ mentioned this video below in his message to FHFA, GSEs, Berkshire, MHI, and other leaders or officials who are connected to this controversy.



According to the Yahoo Finance comments in the YouTube page where the video above was posted, Warren “Buffett speaks at the 2019 Berkshire Hathaway Annual Shareholders Meeting in Omaha, Nebraska. Buffett said it would be “very good for America” if Fannie Mae and Freddie Mac did more to help finance manufactured homes, such as those made by Berkshire-owned Clayton Homes.” That statement, at face value, is quite accurate. But almost two years after that video was posted, the DTS program Buffett was speaking about has still avoided doing most manufactured home loans.  Almost everyone who has been directly involved in the matter make that admission. Jim Gray’s statement above underscores that point.




But Mark Weiss, J.D., president and CEO of the Manufactured Housing Association for Regulatory Reform (MHARR) that said to the same listening session that this writer addressed that what is going on is a shell game.


Additionally, it is Doug Ryan who previously accused the Manufactured Housing Institute (MHI) of giving cover to Berkshire Hathaway owned brands. Clayton Homes, and their affiliated lenders – 21st Mortgage Corporation and Vanderbilt Mortgage and Finance (VMF) are benefiting from that pattern, said Ryan. While Gooch deflected from that claim at the time, her own more comments – shown above – now arguably contradict her prior claim. Rephrased, Gooch has been shown to be paltering, while Ryan’s comment has been revealed as more accurate.


It is not just more sales that more lending by the GSEs would benefit the industry and millions of consumers. More lending options also would create more equity in the homes of millions who currently own a manufactured home. See the Urban Institute comments and analysis further above to learn more.
The significance of this comment by Buffett in context is found in the report linked here. Note for now that resale values as well as an ability to arrange for resale financing are interwoven, as any honest housing economist can confirm.


That statement by Warren Buffett is true on its face value but are also arguably a head fake. Why? Because the status quo benefits Berkshire Hathaway while harming the interests of the industry’s independents, homeowners, and potential consumers. Who says so? Samuel Strommen at Knudson Law. Strommen and Ryan likely do not know each other. But they have said similar things to what Mark Weiss, J.D., President and CEO of the Manufactured Housing Association for Regulatory Reform has said. Evidence that Buffett’s comment is a head fake will be provided further below.




What change has occurred since Buffett made that statement? Virtually none that benefits the millions. Are thinking people to believe that Buffett to influence this if he wanted to do so?


One should also keep in mind that this isn’t just a case of mere supposition or speculation. Tim Williams, President and CEO of 21st Mortgage, has never denied this confirmed statement shown below. Neither has anyone at MHI responded to these sobering words. MHI and the Berkshire owned brands long praised our work before we began to spotlight the contradictions in their own words and behavior. In time, they went from praise to silence. Note that our spotlighting so-called Berkshire and MHI disconnects began during the timeframe that they were clients of our firm and while we were an MHI member. Rephrased, once the lightbulb went off, thanks to tips from several sources, our reporting and commentary shifted to meet the emerging facts and evidence.


Williams’ admission in front of his MHI colleagues is an apparent case of the blinding truth hiding in plain sight. DTS has been and still is being subverted by some of the very people that posture and claim that they support it.

The system is rigged.

It is rigged to benefit many, buy not all, billionaires. It is rigged to benefit political figures willing to manipulate the U.S. system in favor of crony capitalist billionaires who are fine with making deals with Communists in China while that nation oppresses its own people. But meanwhile, they posture and claim to be against racism and authoritarian behavior in the U.S.? Who do they think they are fooling? Sure, some are being conned, but not all. You see, not much has changed about human nature since Abraham Lincoln’s famous quote below about being able to fool many but not all was first shared.



What the Above Means to Mobile and Manufactured Homeowners, Affordable Housing Seekers, and Most Other Americans

There are millions of Americans who are seeing record high values in their homes. But one must keep in mind that there are warnings that the system could have cracks that result in a sharp drop in values, much as occurred in the 2008 housing/finance crisis.  That might be avoided if more new manufactured homes were being sold, because added supply is part of the obvious need.

Also, more affordable homes provided by the private sector would benefit taxpayers.

Further, as several research studies have proven, the presence of manufactured homes near conventional housing has little or no harmful impact on housing values. See the report linked here which goes into detail about the chart below.




If every mobile or manufactured home’s resale value was being harmed by an average of say $3,000 each, a relatively modest sum, that would be equal to a lost sum of about $26,400,000,000  (8.8 million units @ $3,000 each).  Whatever that exact sum is, it should be available to those estimated 22 million Americans who are living in mobile and manufactured homes. But instead, it is being deprived of homeowners, why?

In no particular order of importance, the evidence and logic arguably point to the following having created or fostered the issues that now fester to the harm of millions of Americans.

  • Warren Buffett, Berkshire Hathaway, Clayton Homes, 21st and VMF, among others.
  • FHFA for not enforcing the law as intended.
  • Fannie Mae and Freddie Mac, both of who have paid MHI to co-sponsor events. Doesn’t it seem odd that Fannie and Freddie are paying money not to do what the DTS law requires?
  • Allies and minions of the above.



For instance. While giving MHAction full credit for their research reports that make clear that many manufactured home community residents are being harmed, where is their outcry about something specific like the above? Why has MHAction failed to push this kind of report? Why is it that the narrative that they have produced indirectly benefits the very people that they claim to be blowing the whistle on?




Given repeated opportunities to refute or deflect those concerns, Kevin Borden and his colleagues involved at MHAction have remined silent instead.

Back to Kevin Sheehan’s Reply Above

Said Sheehan, “…In recognition of your concerns about the video and transcript, we have revised those to omit your presentation.   FHFA has posted your full written remarks as you previously requested, and those written remarks will remain posted.  However, if you still would like to present your remarks by video, we can work with you to record and post your statement in the same way that the listening session itself was recorded and posted.  Thanks, Kevin…”

That is an interesting reply. First, let’s acknowledge that it was polite and professional.

But then, let’s note that it came only after an email was sent out by this writer to dozens of manufactured housing professionals, mostly in Ohio, that showed the emailed response made to the FHFA, Berkshire Hathaway connected attorneys and leaders, and which blind copied Donald J. Trump Jr, son of President Trump, and a few others. The email clearly stated that point.

The system is rigged.

For whatever faults or failures some hold against President Donald J. Trump, even numbers of authentic Biden-Harris voters are already concerned that the new White House resident is causing economic, social, and other harm and breaking his word on numerous issues. By comparison, the Trump-Pence years are already looking better to many than the first 100 days of what Washington’s Mall journalist turned pundit Chris Plante has called “the Biden-Harris Junta.” This isn’t about picking sides in politics. Because politicos in each of the major parties have failed our profession and homeowners for years.  But it is to make the point that by comparison, millions were getting ahead during the Trump-Pence years, and now large numbers have lost jobs or other benefits earned during the Trump-Pence era, and more will do so, unless the current dynamic in Washington is changed.  Who says? Democrat Robert F. Kennedy Jr., among others.




The system is rigged, BUT, MHAction and their colleagues have made some true statements. One is that the many can beat the money.

 MHLivingNews will plan a follow up on this report. Our plan at this time is to press FHFA to do what our original message to them requested. Their offer to cut a video of my statement may be accepted.

But bear this in mind. What is now posted on the FHFA website is no longer an authentic transcript. As Kevin Sheehan’s stated, “…In recognition of your concerns about the video and transcript, we have revised those to omit your presentation.” But there is no disclaimer on the FHFA website that reflects the point that the transcript and video are now edited.

It is arguably a clever move which offers to post the video that one or more at FHFA wrongfully interrupted. For the full context, see the linked reports that follow.

Because the devil is lurking in the details. It would be nice if this was simple, cut, and dried. But those who have rigged the system have made it murky. Only by studying the details carefully can this Gordian Knot be untangled.

This is a battle that has been going on for some 13 years on DTS connected manufactured housing financing, and years longer on other laws. While there were issues in the industry pre-Berkshire Hathaway, they case has been made that they pale in comparison to what has occurred in the Berkshire era.

But the good news is that years of research and reporting has made the issues ever more evident. By focusing on facts, evidence, and research that spans the left-right divide, MHLivingNews and our MHProNews sister site have amassed an array of research that has now made it increasingly more difficult for those involved in “rigging the system” to avoid some level of responsibility.

Manufactured home owners, and similarly for pre-HUD Code mobile home owners too, have been artificially harmed by market manipulation. There are voices across the left-right divide that have said that the system is rigged. Okay.


They cite similar facts, but approach the problem with quite different solutions.
Democrat Jerry Brown made that statement over 2 decades ago.




But the question is, who will actually do something about this rigging of the system? Sadly, talk can be cheap. Someone might say all of the right things, but still not do what their words logically imply should be done. That’s a diabolical tread worn tactic that should no longer fool thinking people.

To learn more, see the related reports. To see what has been causing a month of hullabaloo with the FHFA, see the document that Sheehan was responding to which includes linked information here. To end a rigged system, it must be understood.

Then, it must be exposed. Then, motivated people who have been harmed should work together with like-minded souls to force public and corporate officials to do what the law requires. In the absence of following the law, there are legal options that will be explored in a planned future report.  We the people have a God-given, Constitutionally protected right to seek redress for grievances.  The many can defeat the money, with a combination of prayer and proper action.

This report, analysis, and commentary above are evidence-based protected speech that if others will dig into the facts and issues raised will reveal the root causes as well as the possible solutions possible by simply using existing laws. It is that need to understand the full scope of the issues and then press to have good laws enforced that could end the harm to millions of mobile and manufactured homeowners, and give new opportunities to millions of other Americans. ##




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That’s a wrap on this installment of “News through the lens of  manufactured homes and factory-built housing” © where “We Provide, You Decide.” © ## (Affordable housing, manufactured homes, reports, fact-checks, analysis, and commentary. Third-party images or content are provided under fair use guidelines for media.) (See Related Reports, further below. Text/image boxes often are hot-linked to other reports that can be access by clicking on them.)

All on Capitol Hill were welcoming and interested with the discussion of manufactured housing related issues on our 12.3.2019 meetings. But Texas Congressman Al Green’s office was tremendous in their hospitality. Our son’s hand is on a package that included the Constitution of the United States and other goodies. MHProNews has worked with people and politicos across the left-right divide.

By L.A. “Tony” Kovach – for

Tony earned a journalism scholarship and earned numerous awards in history and in manufactured housing. For example, he earned the prestigious Lottinville Award in history from the University of Oklahoma, where he studied history and business management. He’s a managing member and co-founder of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and This article reflects the LLC’s and/or the writer’s position, and may or may not reflect the views of sponsors or supporters.

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Recent and Related Reports:

The text/image boxes below are linked to other reports, which can be accessed by clicking on them.







Addressing Growing Affordable Housing Crisis, Income Inequality by Enforcing Good Current Laws – Illustrated Report, Analysis

Manufactured Homeowners Interests Threatened by Manufactured Housing Institute “Deceptive” Scheme, Per Modular Home Builders Association’s Tom Hardiman



Saving Time, Money, Hassles – How Can You Buy a Manufactured Home Without Encountering Problems? Pissed Consumer Video Interview of L. A. “Tony” Kovach on Manufactured Housing

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