It’s a wonky bill, and it’s flown under the radar so far. But—particularly given the political war being waged at the Consumer Financial Protection Bureau—it shouldn’t get buried. More than 1 in 10 homes in rural or small-town America were built in a factory, and they are usually owned by older, poorer Americans. Even though the average sale price for a new manufactured home is $68,000, consumers who take out a loan to buy one typically pay high interest rates and fees that can add hundreds of dollars to their monthly housing payment.

Get TalkPoverty In Your Inbox

Proponents of the new legislation argue that this change will allow salespeople to help consumers find financing more quickly. However, it also creates a powerful incentive for retailers to drive consumers toward the loans that are most profitable for the business—even when there are less expensive options available for the consumer.

Carla Burr, who owns her home in Chantilly, Virginia, was surprised by the interest rate she was offered after she sold her condominium to purchase a manufactured home in 2004. She had good credit and could make a sizeable down payment—she had just netted more than $100,000 from the sale of her condo. But lenders were asking her to pay an interest rate greater than 10 percent for a 20-year mortgage, more than double what she paid on the mortgage for her previous home. “It’s as if they are treating manufactured homeowners as if we were substandard, or uneducated,” Burr said. Today, even though mortgage interest rates are generally lower than they were 13 years ago, manufactured housing consumers like Burr are still being charged high rates.

About 70 percent of mortgages for manufactured homes are already higher-priced mortgage loans Higher-priced mortgage loans have interest rates and fees (APR) above the standard rate (APOR) by 1.5 or more percentage points.
, compared with only 3 percent of mortgages for site-built homes. That’s due, at least in part, to the lack of competition within the manufactured housing industry. Companies affiliated with a single large corporation, Clayton Homes, were responsible for 38 percent of manufactured housing loans in 2016 and for more than 70 percent of loans made to African American buyers in 2014. That leaves companies with little need to lower their rates to attract consumers—and that would be especially true if there was a steady stream of referrals from affiliated retail shops.

Clayton Homes is also the largest producer of manufactured homes and sells these homes through 1,600 retailers. That gives the company thousands of opportunities to solicit customers for loans offered by its mortgage lending affiliates, 21st Mortgage and Vanderbilt Mortgage, which make far more loans each year than any other lenders. They also charge consumers higher interest rates than much of their competition.

In Virginia, for instance, this company’s interest rates for higher-priced loans averaged 6.1 percentage points above a typical mortgage loan, whereas interest rates charged for similar loans by the rest of the industry in the commonwealth averaged 3.9 percentage points above a typical loan. For a Virginian taking out an average-size loan from a lender affiliated with Clayton Homes, this means they could pay about $75 more each month and about $18,000 more over the life of a 20-year loan than if they had gotten a mortgage elsewhere. Since owners of manufactured homes in Virginia earn about $40,000 each year—about half the annual income of other homeowners in the commonwealth—these additional payments can be a significant financial strain.

Interest rates aren’t the only thing on the line. The House bill under consideration would also allow lenders to include higher up-front fees, prepayment penalties, balloon payments, and hefty late fees on higher-interest loans, leaving many manufactured housing buyers with expensive loans that are difficult to pay off. Manufactured housing industry lobbyists claim that regulations preventing these practices have made it more expensive to do business and, as a result, consumers can’t get loans to buy manufactured homes. However, Center for American Progress analysis shows that 2015 loan volumes were fairly similar to the volumes before the regulation went into effect; the biggest difference is that fewer consumers received loans with exorbitant rates and risky terms. Last year, there was a modest 5 percent decrease in the number of loans originated, but lending quality remained stronger.

If Congress is serious about giving consumers more borrowing choices, more high-quality lenders need to offer mortgage loans for manufactured housing. However, by giving further advantage to today’s largest providers, these bills could derail efforts to expand financing options available for consumers. Fannie Mae, Freddie Mac, and state housing finance agencies are taking steps to make it easier for lenders to offer mortgages for manufactured homes. For instance, both Fannie Mae and Freddie Mac have committed to buying more manufactured housing loans from banks, which should encourage more lending. They are also launching pilots to buy manufactured housing loans titled as chattel, which represent the majority of manufactured housing lending. Allowing the largest manufactured housing companies today to tighten their grip on consumers could put newer lenders, who do not have salespeople at retailers promoting their offerings, at a disadvantage.

Consumers of manufactured housing deserve the same rights and protections available to those buying site-built homes. And since families that live in manufactured housing are more likely to be teetering on the edge of financial stability, they are the least well-positioned to shoulder additional burdens. Congress should take further steps to expand options for these consumers, not pave the way for more abuses.

Earlier this month, when rumors of erstwhile presidential candidate Ben Carson’s role in a future Trump administration started flying, Carson made it clear that he wasn’t interested in an agency appointment. In the words of his business manager, “Dr. Carson feels he has no government experience, he’s never run a federal agency. The last thing he would want to do was take a position that could cripple the presidency.”

A lot can change in a month.

Get TalkPoverty In Your Inbox

Despite Carson’s earlier objections, last week it seemed like President-elect Trump was on the verge of nominating the former neurosurgeon as Secretary of the Department of Housing and Urban Development (HUD). And Carson, citing the fact that he once lived in a city, now believes he’s up to the task.

Here’s the problem: HUD is a critically important federal agency with a budget of almost $50 billion, 9,000 employees across the country, and programs that affect the lives of millions of people. The Secretary of HUD isn’t a vanity appointment to be bestowed upon any half-willing volunteer.

Here are six reasons why the agency deserves a qualified leader who is up to the task.

HUD Makes It Possible for Families of Color, Middle-Income Families, and Millennials to Buy Homes

One of HUD’s core missions is to help families buy a home, which is critical for building wealth. That’s why it manages the Federal Housing Administration (FHA), which insures private mortgage loans against the risk of default by the borrower. That makes financial institutions more willing to provide credit—particularly to groups who have been historically excluded from homeownership, like families of color.

FHA has insured more than 40 million homes since it was established in 1934, and it’s becoming even more important in the current tight credit environment.  FHA’s market share of single-family purchase loan originations more than doubled between 2004 and 2015, and many of those loans are going to underserved communities of color where conventional credit continues to be limited.

HUD Makes Sure Low-Income Families Have Access to Housing

For many years, the private market has failed to provide enough affordable rental housing for low-income families. HUD helps fill this gap through a variety of rental assistance programs—from public housing to housing vouchers—in order to ensure that more low-income families have a decent, safe, and affordable place to live. More than 5 million low-income households use federal rental assistance, and without it, many of these families would likely experience homelessness.

HUD Promotes Economic Mobility for Whole Communities

HUD is working to break up the concentrated poverty and de facto segregation that put some communities at a major disadvantage. Last year, the department finalized a rule that requires local governments that use HUD funding to examine patterns of poverty and residential segregation—and to put forward a credible plan for addressing these challenges. That’s essential in a country that is becoming increasingly diverse—and where discrimination in housing is still alive and well.

Through programs such as the Housing Choice Voucher Program, HUD also helps many families move out of distressed neighborhoods to higher opportunity areas, where there is better access to jobs and good schools.

HUD Addresses Discrimination in the Housing Market

HUD is able to process significantly more housing discrimination complaints than any other government agency—an average of 9,201 per year from 2010 to 2013. The complaints are typically rooted in someone’s race or disability, and nearly a third result in some form of penalty against an offending lender or landlord.

There are a few other agencies that share some of the responsibility for enforcing fair housing law—specifically the Justice Department’s Housing and Civil Enforcement Section—but they are not set up for efficient, large scale enforcement. As a result, the Justice Department’s annual case load is a tiny fraction of what HUD processes each year.

HUD is the Biggest Source of Funding to Prevent Homelessness

HUD provides more funding for homeless assistance than any other federal department. The department has also been responsible for the development of tens of thousands of housing units to house people who are homeless, or at risk of homelessness. HUD also helps to ensure that residents living in these units receive the social support services they need to get back on their feet, and to avoid homelessness in the future. Since hundreds of thousands of Americans still experience homelessness every day, these services are critical.

Too often, the root cause behind homelessness is domestic violence. Through its Office of Special Needs Assistance Program, HUD plays a key role in rapid re-housing and in providing homeless families and survivors of domestic violence with options that let them transition into safe, stable, and affordable housing.

HUD Helps Rebuild Communities After Natural Disasters

HUD serves as an important partner to communities rebuilding after disasters have struck. For example, the department played a major role in the recovery of the Gulf Coast after Hurricane Katrina displaced more than 1 million people, through the Community Development Block Grant Disaster Recovery (CDBG-DR) Program.  The department invested $20 billion in affected states, which supported the long-term recovery of the region’s housing stock, economy, and infrastructure.

HUD can deploy CDBG-DR funds in the case of any presidentially-declared natural disasters, as long as funds are available. Just this fall, HUD deployed $500 million to help communities in Louisiana, West Virginia, and Texas recover from historic flooding. As extreme weather events increase in frequency, HUD’s role in rebuilding communities will be even more vital.

Housing is one of the biggest determinants of where and how we live, and it is intimately linked with broader issues of wealth and poverty. HUD’s vital role necessitates engaged, qualified, and experienced leadership.  Ben Carson—by his own admission—is simply not up to the task.

The new rule improves the reporting requirements of lenders under the Home Mortgage Disclosure Act (HMDA). Signed into law in in 1975, HMDA was enacted as a response to widespread urban disinvestment and redlining—the systematic exclusion of neighborhoods of color when marketing and offering home mortgage loans. Under the HMDA, mortgage lenders are required to report information about their applicants and loan decisions, including the race and ethnicity of borrowers and people who have been denied. But lenders haven’t had to disclose any data on applicant creditworthiness. As a result, the law has been severely limited in its ability to reveal discriminatory practices.

With the CFPB’s new rule in effect, there will be increased attention paid to the creditworthiness of applicants, including information on their debt-to-income ratios and credit scores—data that are key to uncovering discriminatory lending patterns and determining whether financial institutions are meeting the housing needs of the communities they serve. The new rule also requires more specificity in reporting on the ethnicity and race of applicants—a vital measure to ensure that HMDA data reflect our nation’s increasing diversity.

Prior to this new rule, while HMDA reporting requirements had been useful in shedding some light on mortgage practices in the Black and Latino communities, they have been completely inadequate for capturing the experiences of other communities of color, especially Asian Americans and Pacific Islanders. This is because HMDA data—like numerous other statistics—currently treat AAPIs as a uniform racial group, despite the fact that Asian Americans and Pacific Islanders represent more than 30 countries and ethnic groups that speak more than 100 languages.

The results of data analysis on AAPIs are therefore often misleading. For several years, HMDA data have portrayed the mortgage outcomes of the group as much better than those of other borrowers of color, thus reinforcing the “model minority” myth which asserts that people of color should follow the example of Asian Americans and Pacific Islanders. While it’s true that many hard-working AAPIs have done well in the US—getting a good education and good jobs, becoming homeowners, and building wealth—we also know that this story by no means applies to all AAPIs.

In fact, Asian Americans and Pacific Islanders are not only one of the fastest growing populations in the United States, but also one of the fastest growing populations in poverty since the Great Recession. They come from diverse socioeconomic backgrounds and therefore arrive in the US under widely different circumstances. They have a relatively high median household income compared to African Americans and Latinos, but this is largely due to the fact that AAPIs tend to have larger households and are geographically concentrated in the most expensive states—Hawaii, California, New York and New Jersey.

As a whole, the AAPI poverty rate is 12.6 percent. But if we look at individual groups within the AAPI community, we see just how misleading that figure is. Many individuals and families—especially refugees from Southeast Asia—are among the poorest people in the US. The Hmongs have a poverty rate of nearly 39 percent and Cambodians have a poverty rate of 29 percent—two percentage points above the African American poverty rate. AAPI homeowners were also hit very hard by the housing market crash. Falling housing prices, high rates of foreclosures, and low property values have resulted in a significant loss of wealth in this community. Asian Americans and Pacific Islanders have also endured the largest percentage decline in homeownership rates of any racial group.

Southeast Asians have been particularly vulnerable to foreclosures, as they have higher concentrations of workers in low-wage sectors, lower education levels, and higher rates of linguistic isolation than the broader AAPI community. The Central Valley in California—home to one of the largest concentrations of Southeast Asians—is among the areas that have been most devastated by the foreclosure crisis. Along with the Inland Empire area of Southern California, Central Valley counties feature the highest concentration of foreclosed/Real Estate Owned (REO) properties—and loans at risk of foreclosure—in the state of California. In 2010, the City of Merced had the third worst foreclosure rate in the country at 11 percent. Hmong and Lao comprise 25 percent of the residents in the Merced neighborhoods that were targeted for foreclosure programs.

Like other people of color, many AAPIs still suffer from disparate treatment when looking for housing: one in five AAPIs experience discrimination in the rental and home buying process. Addressing the barriers to housing faced by a diverse AAPI community and others is critical to ensuring that everyone has the opportunity to build wealth for their families—essentially, to achieve the American Dream.

Kudos to the CFPB for taking a powerful step in the right direction.

For many, the images recall other past uprisings still fresh in our nation’s collective memory. Take Ferguson, or the Los Angeles uprisings of 1992, for example. Different locations, similar scenarios, and the usual suspect – police brutality against people of color. But the similarity between what has happened in Baltimore and in other places suggests an inconvenient truth: The unrest in Baltimore is not a sporadic accident. Rather, it is a dramatic example of what has gone wrong in our society for several decades—most notably, how we have failed to deal with residential segregation and the concentration of poverty which are the underlying causes of repeated unrest.

Despite the promises of the fair housing movement and subsequent policies addressing residential segregation and poverty concentration, each continues to persist in our inner-cities and has proliferated well into the suburbs. Current efforts to break up concentrations of poverty often involve the movement of families from high-poverty areas to more affluent neighborhoods through the administration of Housing Choice Vouchers. Although vouchers and the programs relying on them – like Moving to Opportunity – have yielded positive results for many families, moving families from high-poverty areas through vouchers cannot be our nation’s only answer to residential segregation.

First, such dispersal efforts face significant barriers due to political opposition and resistance from both displaced individuals and receiving communities. Leaving one’s neighborhood and support networks can represent a critical source of social and psychological hardship. In addition, vouchers are often difficult to use in low-poverty areas, due to the current shortage of affordable housing, some landlords’ reluctance to accept vouchers, and persistent housing discrimination. Therefore, the implementation of dispersal programs often risks re-concentrating the poor into low-income neighborhoods with very few opportunities.

The primary reason we cannot rely on vouchers alone, however, is simple: the problems that inner cities face are structural – rooted in institutions that restrict the resources and opportunities that are available to residents. Baltimore’s civil unrest is not really just a reaction against police brutality. It is a cry for recognition and social justice from marginalized communities who do not have full access to basic rights – including the right to their city – because they are locked in areas of concentrated poverty. Baltimore should serve as a wake-up call for policy makers, practitioners and advocacy groups who – in spite of their good intentions – still operate in an un-coordinated fashion and in separate silos.

There is no doubt that the revitalization of inner-city neighborhoods through housing construction and redevelopment represents a critical step to alleviate poverty concentration. Brick and mortar approaches alone, however, will not solve the problem.

Several actions would ensure that there are opportunities for self-development available to people residing in areas of concentrated poverty, including: (1) encouraging the development of job training centers and social entrepreneurship in inner cities; (2) retaining and improving existing affordable housing and protecting it from speculative private development; (3) raising minimum wages and providing access to better paying jobs; (4) encouraging a sense of hope and ownership to marginalized groups – especially among youth – by providing people of different ages the opportunity to make planning decisions in their own neighborhoods and institutions; (5) fostering healthier neighborhoods – by improving access to high-quality food resources, expanding recreational opportunities, and increasing protection against environmental hazards like lead paint, hazardous waste repositories, and landfills that are disproportionately present in low-income communities.

We, as a society, ought to stop trying to fix the symptoms of poverty concentration and instead attack its causes. How many more LA’s, Katrinas, Fergusons, and Baltimores do we need before we stop pushing the replay button as if these events were just another spectacle to watch on cable?