A New Danger

[Ken Rishel]

The Proposed Regulatory Prudential Standards for Non-Bank Mortgage Servicers put out by the CSBS could put all small lenders who are financing purchases of manufactured homes out of business in states that adapt these standards. http://www.csbs.org/regulatory/Documents/MSR-Propo...

There is a commentary period and I would suggest you contact them with a detailed response of how it would hurt both your business and the consumers you serve. The commentary period ends June 23d.

A few state trade associations have commented as has Rishel Consulting Group. You should contact your state association and encourage them to comment. The national association (MHI) responded with comments last week.

Consider asking for chattel lending to be specifically excluded in writing, and failing that, to be excluded from the capital requirements. If we are subject to the capital requirements less than 50 out of 5000 (known) captive finance lenders could survive. Note there is absolutely no exemption for very small operators.

The CSBS is stating orally that chattel lending on manufactured homes is not subject to these proposals, but we have all seen how that went with the SAFE Act and the Dodd-Frank Act where the same oral assurances were given to MHI.

For those of you with your head in the sand about getting compliant with state and federal laws, regulations, and rules, please note the CSBS states the current rules (which you are ignoring) aren't strong enough. You need to clean up your act, or stop lending - no matter how small you are.