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.

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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.

This fire is, unequivocally, a tragedy—particularly because it was so preventable. Investigators say the root causes were lax regulation and an unwillingness to invest in basic safety features. Residents had repeatedly warned that their living conditions were dangerous, pointing out that the building didn’t have fire alarms, sprinklers, or a fire escape, and there was only one stairway for people to get out and one road for firefighters to get in.

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The fire has been a wake-up call for British politicians about a dangerous lack of investment in safe housing. Unfortunately, Britain is not the only country that has underinvested in safe homes.

A report by the Federal Healthy Homes Work Group found that more than 30 million homes in the United States are putting their occupants at risk. Six million homes have moderate to severe infrastructure problems, such as substandard heating, plumbing, and electrical wiring. Another 23 million homes have lead-based paint hazards, and 6.8 million homes have dangerously high levels of radon exposure. This means that millions of families face increased risk of lung cancer from radon exposure, fire-related injuries, and lead poisoning.

So far, the Trump administration has stymied efforts to address these problems. The administration’s proposed $6 billion in budget cuts to the Department of Housing and Urban Development (HUD) would severely curtail efforts to provide safe and affordable housing.

At least $300 million in cuts would come from rental assistance programs such as the housing choice vouchers program, which means that 250,000 people could lose access to housing vouchers. Landlords participating in the housing choice voucher program commit to extensive property maintenance and safety standards that other private landlords serving very low-income families are often not required to meet. When families who cannot pay their rent are evicted, they often move into homes with more health and safety hazards, which is why children who are evicted are twice as likely to be in poor health.

The Trump administration’s budget also calls for direct cuts to the HUD public housing Capital Fund, the program that funds repairs to public housing. The budget would slash the fund by more than half, so that 212,000 fewer units would receive the repairs they need next year. It also means that local public housing authorities—which rely on this funding to address fire hazards before they become disasters and address health risks like mold, lead, and rodent infestations—could be short on their budgets.

Even indirect cuts, such as the proposed elimination of the Legal Services Corporation (LSC), will put more people at risk. LSC funds civil legal aid organizations that help low-income households bring lawsuits against landlords who refuse to deal with potentially deadly living conditions. After similar cuts to legal aid in Britain, residents of Grenfell Tower were unable to afford legal advice when they had concerns about their building’s safety.

We’re not doomed yet. Fire deaths have been dropping across the United States due to stronger building safety codes. Most states ban the usage of flammable aluminum cladding in tall buildings, which contributed to the Grenfell Tower fire.

Still, the Trump administration has promised to dramatically cut back on important safety regulations. Trump’s recent executive order that requires eliminating two regulations every time a new one is created forces agencies to choose which life-saving regulations they should prioritize to comply with the rule. Congress is now considering the Regulatory Accountability Act, which would add so many hurdles to the regulatory process that companies that produce dangerous products could delay regulations indefinitely. The Environmental Protection Agency faced similar roadblocks when it tried to ban asbestos—a known carcinogen—more than 25 years ago. Asbestos manufacturers used hurdles in the regulatory process to their advantage and blocked the agency from removing this toxic substance from commerce. Since 1999, at least 12,000 Americans have died every year because of asbestos exposure. Under the Trump administration, long-awaited asbestos regulations and many other critical protections may never be implemented.

In a chilling letter written just months before the building caught fire, residents of Grenfell Tower warned that “only a catastrophic event will expose the ineptitude and incompetence of our landlord, the KCTMO, and bring an end to the dangerous living conditions and neglect of health and safety legislation that they inflict upon their tenants and leaseholders.” Americans shouldn’t wait for a tragedy of this magnitude. Investing in the health and safety of low-income Americans begins with the funding decisions Congress will make this year.

By the time Carson was confirmed last month, there had been a shift. Media coverage softened, as some newspapers moved from being incredulous about his qualifications to arguing that his health background made him uniquely suited to running the department. During his confirmation hearing, Carson made that case himself by noting “good health has a lot to do with a good environment.” Some housing advocates, in turn, were hopeful he could be a good partner to their communities.

Less than a month into his tenure as HUD secretary, Carson is already beginning to undercut this argument. The Trump administration’s FY 18 budget, released today, proposes a $6.2 billion cut to the HUD budget—targeting programs that keep families housed and healthy.

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Today’s “skinny budget” was light on detail, so it didn’t account for all of the resources that would be slashed as a result of the 13.2 percent cut to HUD’s funding. According to earlier documents, about $1.5 billion of the cuts would come from the funds local governments rely on to clear public housing of mold and lead. That would add to the backlog of major repairs needed for public housing, which already stands at  $26 billion. The budget does propose a $20 million increase in funding specifically for lead remediation, but that restores less than 1 percent of what is being cut.

The budget also cuts programs that help prevent and alleviate homelessness, which is associated with health problems due to weather exposure, untreated conditions, and inconsistent medical care. About 200,000 low-income households could lose the rental assistance they need to afford housing, and the development funds that local governments use to prevent homelessness stand to be gutted. These programs have reduced homelessness by 10 percent since 2010— including a 15 percent reduction in family homelessness, and a 33 percent reduction in veteran homelessness.

The cuts also eliminate programs that support entire communities in their effort to provide a healthy environment for children. Community Development Block Grants (CDBG) and Home Investment Partnership (HOME) grants build and fix affordable housing, finance health care centers, and create community centers that give children safe places to play. In 2013 alone, 9.8 million people lived in areas that benefited from CDBG-funded projects, and HOME grants have helped build or saved 1.2 million affordable homes since the program was created in 1990.

Sec. Carson knows that living in poverty makes children sick. Living in structurally unsafe, substandard housing places children and families at a higher risk for fire-related injuries, asthma, and lead poisoning. It is also responsible for more than 18,000 preventable deaths each year. Carson has acknowledged this time and time and time again over the years. And, in one of Sec. Carson’s first messages to staff and the housing community last week, he pledged to “use every fiber of [his] being to work to improve America’s neighborhoods.” So, where is he this week when communities and families need him to defend the vital dollars they rely on?

During his confirmation hearing, Carson told U.S. senators, under oath, that he no longer supported the extreme cuts he had once campaigned on for President. He called such cuts “cruel and unusual punishment.” His support of this budget breaks his oath to Congress, and it calls into question the ethical oath he swore to live by when he became a physician: to do no harm.

Carson’s decision to support the current budget would dishonor his lifetime Hippocratic creed to uphold the human dignity of the people he serves—the people, families, and communities that rely on HUD. They deserve housing that keeps them safe from winter storms and summer heat. They deserve roofs without leaks, paint without lead, and walls that aren’t bubbling with black mold. They deserve to be able to turn the stove on without worrying if the apartment will catch fire.

They deserve to be healthy.

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.

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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.

One of the best ways to prevent unnecessary foreclosures is to provide struggling families with a legal aid lawyer.  While the state guarantees legal representation for any criminal proceeding, there is no such guarantee in civil cases. Therefore, access to fair representation depends largely on the availability of free legal aid lawyers who have a long track record of helping people with no other options—such as battered spouses, people with disabilities, parents seeking child support, homeless veterans, and others without means.

Legal aid lawyers have the necessary training to help homeowners navigate the byzantine mortgage servicing system. They can identify mortgages that were illegal or predatory, and also help families make their mortgage payments by securing resources like unpaid wages, child support, public benefits, or unemployment insurance. Legal aid programs have saved many thousands of homes since the start of the financial crisis, but recently have struggled to secure funding for their vital work.  The Bank of America settlement will hopefully be helpful in this regard  but we need to do much more.

Early in the foreclosure crisis, the Center for Responsible Lending, a national advocacy group, received a $15 million grant for an innovative grant-making enterprise called the Institute for Foreclosure Legal Assistance (IFLA).  Over the course of three years, IFLA more than doubled the number of attorneys devoted to foreclosure prevention work and created a national infrastructure of training, informational materials, and networking that served as a powerful force multiplier. The program ultimately reached tens of thousands of borrowers either through individual assistance, broadly applicable policy changes, or access to critical information and materials.

Yet funding for IFLA was only available for three years, and at the end of that period, IFLA closed its doors. Since then, resources for foreclosure prevention work have dwindled even as the significant risk of foreclosure for millions of homeowners continues. Yet the IFLA infrastructure still exists, and an infusion of funds could immediately be put toward productive use without the need to build a new program.

While the Bank of America settlements directs monies to states, there is another source of federal monies that could be used to restart IFLA’s critical work: the remaining funds from the Independent Foreclosure Review (IFR).

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The IFR was initiated when financial regulators found evidence that mortgage servicers had engaged in rampant misconduct when troubled borrowers came to them for help with their mortgages. The regulators first attempted to review every case individually, but that effort foundered. Instead, they decided to compensate homeowners who were most likely to have been harmed by the servicers, setting aside $3.6 billion for this effort. Borrowers ultimately claimed roughly 86 percent of the monies set aside but approximately $500 million remains unclaimed.

Regulators are considering giving those remaining funds to states for their “unclaimed funds” accounts in case homeowners file late claims. However, under this scenario, it is unlikely that much of that money will end up in the hands of homeowners seeking compensation. In fact, according to a recent letter to federal regulators from the National Housing Resource Center—an advocate for the nonprofit housing counseling community—only 2.8 percent of unclaimed funds held by New York State, and about 6 percent held by the state of Texas, reach the rightful owners every year. These funds are much more likely to end up in a state’s general funds where they could be used for just about anything, as has occurred with proceeds from other mortgage settlements.

Instead, regulators should send the states only the amount of remaining IFR funds that are likely to be claimed by homeowners. The rest of the money should be used for other foreclosure prevention efforts—including re-funding IFLA—to reinvigorate critical civil legal aid efforts, prevent unnecessary foreclosures, and help stabilize communities that are still being left behind in the economic recovery.

With the Bank of America agreement, hundreds of billions of dollars have now been collected in settlements with lenders and servicers, and families and neighborhoods should be far better off than they are now. Adequately funding national, state and local civil legal aid programs is one of the most effective ways to ensure that these settlements provide meaningful assistance to the people and communities that have been hit the hardest by the bad behavior of financial institutions.