manufactured homeowners who rent lots lack …consumersunion.org/pdf/manhome.pdfmanufactured...

Publisher of Consumer Reports

Southwest Regional Office1300 Guadalupe, Suite 100

Austin, Texas 78701512-477-4431 ! 512-477-8934

Reggie James, Director

Janee BriesemeisterProject Director and Contact

[email protected]

Kathy MitchellSeries Editor and Design

Kevin Jewell, AuthorFebruary 2001

And very special thanks to Legal Aid of Central Texas forresearch assistance and information about individual

complainants.

Manufactured Homeowners Who Rent LotsLack Security of Basic Tenants Rights

In BriefUnlike apartment dwellers, manufac-

tured home occupants who rent the spaceupon which their unit is placed currentlyhave no legal rights if a park ownerdecides to terminate their stay. Thesefamilies have no right to a written leaseunder law, and are typically on month tomonth tenancies. This situation leavesthem without basic landlord-tenantprotections.

Although manufactured homes areoften referred to as mobile homes, theyare far from mobile. Few homes are evermoved from their original installation. Thecost and difficulty of moving these homesplace such tenants in a uniquely disadvan-taged position when dealing with land-lords who can give them 30 days notice atany time.

This poor bargain-ing position leavesresidents at risk oflandlords’ demands ofmore money for rent,utilities, or otherservices. Unexpectedexpenses are especiallydifficult for those onfixed income, such asretirees. Nationalstudies have shownthat those of retirementage are overrepre-sented in manufacturedhousing. Underconstant threat of eviction, tenants willlose almost any conflict with landlords.

Despite the unique problems facingthese manufactured homeowner-tenants,under current Texas law they have neitherthe rights nor the protections affordedapartment dwellers or conventionalhomeowners. Such protection is needed ifmanufactured housing is ever to become asafe, stable environment for Texasfamilies.! Manufactured home owners wholease a lot in a manufactured homecommunity in Texas have no lawsprotecting their rights, and are frequentlytrapped by skyrocketing rents, utility

costs, and community fees.! The cost to move a manufacturedhome severely limits a renter’s choices,and renters sometimes suffer significantpersonal loss if they must sell the homeback to the community owner or adealership at fire-sale prices.! Renters should have strong protec-tions against rapid and high rent increases,rights to a renewable long term writtenlease, and protections if a community issold for redevelopment and homes mustbe sold or moved quickly.

General FindingsTraditionally marketed to retirees and

very young families, today in Texasmanufactured homes have captured abroad market among all kinds of people

seeking affordablehousing. The December2000 Current PopulationSurvey reports 1.2million Texans live inmobile homes.

Manufactured homeoccupants in Texas tendto be younger and haveincomes several thousanddollars higher thanmanufacturedhomeowners nationally,reflecting the wideracceptance of suchhousing here. Themedian age of Texas

occupants is 29, and the median house-hold income is roughly $30,000. Thereare also noticeably more children inmanufacturedhousing inTexas: 37%of occupantsare under theage of 18, vs.29% nation-ally.2

Mostmanufacturedhomeresidents livein and near

August 2000: the San AntonioExpress-News reports on the plight

of a 90 year old retired schoolteacher. After 38 years in thesame mobile home park, the

landlord gave all the residents a30 day notice to move off. Three

days before the deadline, fewerthan half of the residents had been

able to arrange to move theirhomes.

December 2000: ConsumersUnion staff visit Bergstrom Mobile

Home Park, slated for redevelopmentafter decades of operation. Residentssay they cannot find spots to relocate

their homes, nor can they afford topurchase homes from the new owner,

Palm Harbor. Many parks are full,and those that have spaces will not

accept older models and/or styles ofhomes.

February 2001: Residents of an80-unit Grapevine mobile home

park must move out because FourPeaks, a company that bought the

property to redevelop it, plans tobuild single family homes priced up

to $300,000. “We have singlemothers with no place to go in thisarea,” a resident told City Council.

“Tell me, what are we to do?”.1

Manufactured Homes on Leased Lots, February 2001 Consumers Union SWRO

urban areas. 68% of Texas manufacturedhouses are found in urban areas, and11.5% of all mobile homes in Texas are inthe Houston PMSA (Primary MetropolitanStatistical Area). Another 9.9% are in theDallas PMSA. Rural counties generallyhave a higher percentage of the populationliving in manufactured housing, but manyof the rural counties with a very high ratioof manufactured homesare sparsely populated (seetables below).3

Manufactured homesare an attractive alternativefor many Texas familiesbecause down-paymentsand monthly payments aregenerally lower than those for site builthomes. Often, part of the up-front costsavings comes from placing the home onrented lots.

In Tarrant County, for example, 65percent of manufactured home owners donot own the land on which the unit isplaced. Percentages may be slightlylower, but still significant, in rural

counties.4 National statistics aboutmanufactured home loans indicate thatless than 10% of loans include both homeand land as collateral.5

In 1999, there were 256,323 manufac-tured homes placed on rented lots in thestate of Texas.6 The tenants, about threequarters of a million people, rely upontheir lots for space to live.

Unlike regularrenters, however, thesetenants have no protec-tion under Texas law.And also unlike regularrenters, these tenantsstand to lose thousands ofdollars in moving costs if

they have to leave their lot. The industryestimates moving costs for manufacturedhomes to be $1500-$3500.7 Moving ahome can cause structural damage as well.A manufactured home retail salespersontold Consumers Union staff that aftermoving, homes often look like they havebeen through an earthquake, and requiresignificant work to repair.

Even if owners have the money, thesetenants may not be able to find a place fortheir homes because many parks are fullor won’t take used homes. Once a parkfills, turnover of units is very low: usuallyowners sell the unit in place in a park.Sun Communities, a park developmentcompany active in Texas, estimates onlyabout 3% of its occupied lots open up ayear.8 Newer parks, which have openspaces yet to be filled, often don’t acceptused homes.

State LawsThere are over 1,300 manufactured

housing communities in Texas.9 Some ofthe larger communities are owned orcontrolled by manufacturing companieslike Palm Harbor, Champion, or ClaytonHomes. The larger multi-state corpora-tions are used to working under regula-tion. As of 2000, 37 states had regulationscovering landlord-tenant relations relatingto mobile home owners.10 (See Inset Map)

Clayton runs 75 manufactured homecommunities across the country, including26 in Texas.11 These communities leaseland to new manufactured home buyers.Other national or multinational companiesoperate parks here as well. Most largernew parks are run by large companies ordevelopment funds. The Austin Edition ofthe 2000 Manufactured Housing Commu-nity & Land Guide lists only seven parkscurrently leasing spaces in Austin (thereare dozens of parks in the city). Of thoseseven parks, all of them are owned bycompanies based out of state.12

The 37 states with laws governing lotrentals have recognized the potential

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Most people who live in manufacturedhomes today live in the state’s most

populous urban counties.

In rural counties, a greater share ofthe population lives in mobile

homes.

Top Ten Counties by Number of Manufactured Home Titles.Source: MH Current Titles dbase, Texas Department ofHousing and Community Affairs.

Top Ten Counties by Number of Mobile Homes per 1000People: Source: MH Titles dbase, Texas Department ofHousing and Community Affairs.

TerminologyManufactured homes are often called mobile

homes or trailers. The industry encouragesthe use of the term “manufactured home”for units built after 1976, but only 10% ofresidents have adopted this terminology.1

In this report, we follow common practiceand use the terms interchangeably.

Source: Foremost Insurance “1999 Market Facts”Internet Source: http://www.foremost.com/market_facts/


problems faced by lease-less tenants.Illinois requires landlords to offer a 1 yearlease option with automatic renewalunless landlord has good cause to termi-nate. Arizona limits unreasonablecommunity rules. Florida requires oneyear notice before closure of a park.13

Oregon prevents a landlord from forcing ahome from the park based on age,architectural style or original materials, ifthe home meets the codes of the date ofmanufacture.14 These states and manyothers provide a wide range of protectionsto their mobile home park residents.

Texans purchased more manufacturedhomes than residents of any other state in1999,15 and our state has more parks thanall but two other states.16 In fact, Texansbought more homes than people in 25other states combined – 25 states, ofwhich 22 have laws covering mobilehome park residents. Despite the preva-lence of manufactured homes here,people who lease the land but own theirhome have neither the legal protectionsafforded homeowners, nor those affordedconventional renters. They fall betweenthe cracks.

Specific ProblemsThe specific problems facing mobile

homeowner-tenants are caused by theimbalance of power resulting from makinga long term investment in a home placedwithout the protections of a long termlease. Once placed, homeowners willhave little opportunity to move their homewithout suffering financial harm.Homeowners have no rights, despite thefact that the combined investment ofhomeowners in a park may surpass that ofthe park owners. An examination of thetax appraisal rolls for the Regency Villagecommunity in El Paso reveals thathomeowner property is valued at over 2.5times that of the park owner.17

No-Cause evictionsCarolyn18 is 64 years old, and lives in

a mobile home park where she rents a lot.She is disabled, and lives on a fixedincome: her monthly $512 SSI check.When she came to Legal Aid for help, shehad lived in the same park for 9 years onan oral month to month contract. Over theyears she had built out a permanent

addition to her home, planted trees andplants around her unit. She was current onher rent. Then one day, she received awarning that the park was consideringgiving her a 30 day notice. She inquiredat Legal Aid about her rights under thelaw, because she could not afford to moveon short notice. Their answer: none. Shecould be forced to move with only thirtydays notice from the landlord if thelandlord did not assert that she hadviolated the terms of her lease. She would

have to move with only three days noticeif the landlord claimed she had violatedher lease.

The most important reason thatmanufactured homeowners need theoption of a long-term lease is that withoutone, they have no rights. Tenants living ona month-to-month contract can be given30 days notice at any point in time, noreason required. Thirty days gives tenantsneither sufficient time to locate a new sitenor raise the necessary money to move the

Only a handful of states--including Texas--have not passed some kind oflegal protections for manufactured home owners who lease their land.

Ten years ago, Deborah Chapman bought a manufactured house in Strasburg, Pa.Like many young people, she had opted for manufactured housing because shecouldn’t afford the down payment for a site-built home. When she was ready to tradeup, however, her landlord, who had written into the lease the right to approve anysubsequent buyer, rejected each of the six people who made an offer on the $9500home. He then made a lowball bid of his own for $2000.

Rather than abandon her home, Chapman paid some $1500 to have it moved toa new location, where it sat empty until she sold it a year later for $7000. She usedthe proceeds to pay legal costs she’d racked up fighting her landlord, in the endnetting nothing for all the trouble she went through. Says Chapman, who is now thechairwoman of the National Foundation of Manufactured Home Owners, “Had I beenforced to sell, the landowner would have sold my home for much more than he paidfor it.” – “Dream home. . . or nightmare?” Consumer Reports, February 1998

Landlords can collect homes at firesale prices by rejectingother potential buyers then making bids themselves


home. Nationally, 84% of mobile homeoccupants have lived in a mobile home formore than 5 years, and over half plan onliving in their current homes for the rest oftheir lives.19 Yet for many, lack of a longterm lease places their future on perilousground.

Without a long term lease, non-renewal may happen at any time- afteryears in a park, or merely months later.The Roberts family of Austin bought a

new house, signed a month to monthlease, and moved in. Just months afterinvesting in the move and installation,they had a disagreement with parkmanagement over whether or not thehusband was listed on the lease. Manage-ment decided not to renew the monthlycontract, and they were forced to pay torelocate their home

Park ClosuresMany mobile home parks were built

decades ago on low cost land outside ofcity limits. Today, that land is prime real-estate, often sold for large-scale commer-cial or retail development. For example,recently Home Depot purchased a mobilehome park outside of Longview withplans to develop a store on the site.20

Sections of Bergstrom Mobile Home Parkin Austin are being closed for the openingof a manufactured home retail center.21

This year, the Grapevine City Councilapproved the redevelopment of an 80-home park into a single-family residentialarea with homes priced up to $300,000 on7,500 square foot lots.

When parks close, dozens, if nothundreds, of homeowners are left search-ing for spaces to relocate. Under normalcircumstances, the number of availablespaces for used homes are limited. Theclosing of a park not only reduces thesupply, but also increases the demand forspaces. This is exacerbated by rules inmany parks excluding used homes, homeswith metal roofs or siding, or otherlimitations (See park rules, below). Allthe residents of the old park end upattempting to move to the same few spotsthat will accept their homes. ManyGrapevine residents told their CityCouncil that they have been unable toarrange to move their bulky homes andhave considered abandoning their invest-ment. Despite five months notice,Bergstrom residents told Consumers

After decades of operation, the residents of Hillside Mobile Home Park in Bexar Countywere given 30 days notice. The land was rezoned for commercial development and beingcleared. Three days before the deadline, fewer than half of the residents had been able toarrange to move their homes.

Each of the households has been disrupted by the action. Cesar Martinez laments thelack of warning. He thinks with more warning, he could have saved enough to purchasesome land and move his home. He is still paying installments on his home.

Henrietta Castanon, a 86 year old resident, sold her home at less than a third of itsappraised value. She moved into a home already occupying a lot in another park. Anotherelderly resident, living on a Social Security check of $500 per month, received offers of aidfrom local moving companies after her plight was aired on a television newscast.

Rae Jean Alonso moved to an apartment building, abandoning her yet unsold home.Keeping her son in the same high school was a priority that limited her moving options.

Dana Walters, a 44 year old nursing student, had trouble getting other parks to returnher calls looking for spaces. Her other attempts to find help were also unsuccessful. Walterscontacted the [Texas Manufactured Housing] Association but received no help. “These peopleonly represent the (park) owners.”

Source: “Zoned Out of a Lot ; Mobile-home owners in manufactured mess,”San Antonio Express-News, August 27, 2000.

When Park Owners Redevelop, Tenants May Have Few Options


Union that they have also been unable tomove and place their homes elsewhere. Astudy of two park closures in Oregonestimated that it would take 14 years forlocal parks to absorb the used homesdisplaced by the closures.22

Rent increasesWithout a lease, renters are at the

whim of the owners. Month to monthrenters may have some “understanding”about rent with the current owners, butsuch “understandings” can leave the renterout in the cold, especially if park owner-ship changes. Ownership changes can berelatively common: one real estate website currently lists 59 mobile home parksfor sale, representing about 4,900 lots inTexas.23

Shortage of spaces, combined withthe immobility of manufactured homes,gives park owner/operators extraordinaryleverage to exact large increases in rentsand other fees. According to AARP, rentincreases of 50 to 60 percent are notunusual.24 Rod Nelson at Legal Aid ofCentral Texas (LACT) recalls one parkwhere rents jumped from $350 to $500 amonth. For a renter on a fixed income,unbudgeted rent increases can be devastat-ing.25

Park RepairsLandlords rent out spots for place-

ment of manufactured housing. As such,they are responsible for the roads, sewers,water pipes, and electrical system of the

community. That environment is impor-tant to all the residents. Not only is thisimportant in terms of health and safety(especially for the 37% of all mobile homeresidents that are under the age of 18), butthe park environment is an importantfactor in the value of the home for thehomeowner. With no minimum standards,no lease, and few other options, residentscan be trapped in unsafe or unsanitaryliving conditions surrounding their homes.

The National Housing Institutereports: “Mobile home parks effectivelyput landlords in the position of localpublic works director, in charge of roads,sewers, water pipes, and electricalsystems, seriously magnifying the effectof an owner who neglects repairs. Parkowners, like many landlords, are alsoknown to cut corners when they do makerepairs. [Janet]Dermotty [ofVermont’s MobileHome Park Project]recalls a landlord whoinstalled an old oildrum in place of aseptic tank.” Faultywiring caused two fatalaccidents in a Califor-nia park in 1998.26

Control of localutilities is often used byparks as another sourceof revenue. Surchargeson water services of up to 9% of the billare allowed under current Texas law.27

Parks Restrict AccessParks often restrict access based on

the age, brand, or size of a mobile home,and on the type of materials used inconstruction. Some parks restrict thechoice of tenants by restricting the brandsaccepted for placement. Colorado RealEstate and Investment Company(CREICO) has a section of one of theirTravis county parks reserved for homesmanufactured by Oak Creek (a division ofAmerican Homestar). CREICO has over1,800 spaces in Texas in 11 parks.28

Tying of products like this not onlyrestricts consumers’ ability to makechoices in products, but fear of evictionmay limit their ability to complain shouldthere be a problem with the purchase.

Nelson Mock, an attorney at LACT,recalls such a case. A client had pur-chased a used mobile home from the parkowner. Shortly after moving in, he foundthat there were problems with the installa-tion: specifically, the heating and airconditioning were not functioningproperly. The client withheld rentpayment from the park in protest, and inreturn was given three days notice tomove his unit off the premises. As moremanufacturers get into the park develop-ment business, these types of issues arepositioned to become a larger problem.Texas law puts mobile home owners in abind on installation. The home owner isresponsible for site preparation, but if thelot is rented the owner has no control overwhether a site is properly prepared.Studies estimate at least half of major

problems withmanufactured homesare caused byimproper installa-tion.29

New homecovenants restrict theoptions for place-ment of used homes,thereby making itdifficult to relocatefrom a bad parksituation. Thesecovenants can alsobe used to force

homeowners to remove the home if thehome ownership changes. Due to the highinterest rates on manufactured homeloans, the cost of moving a home (includ-ing damage caused by transit) can easilydestroy years of equity owners may haveearned on their units.

The tying of purchases is not re-stricted to homes themselves. Forexample, “Deerwood,” a manufacturedhome community in Austin, requires thetenant to purchase from Deerwood a list ofitems. This list includes a storage shed,skirting, and deck – all items that areavailable on the open market.30 Onceagain, consumers are losing choices.

Parks may require approval from thepark management before a new ownermay move into the home. It is notuncommon for park owners or manage-ment to be involved as a bidder or agent

“Some parks require an in-home inspec-tion to be performed by park managementbefore a homeowner can even put theirhome—their property—up for sale. In-home? We can concede some on outsidethe home inspections, but in-home?” -MFG Housing News

Internet Source: http://www.mfghousingnews.com/park_owners_business_tactics.htm


on in-park resales. This creates a potentialfor abuse of the approval process. (seesidebar)

Community RulesParks often further restrict options

through use of extra rules and regulations.Many parks have a long list of communityrules. These rules can help regulate thecommunity for the benefit of all. How-ever, rules can also become arbitrary andinfringe upon the rights of the individualhomeowner. Landlords can evict on shortnotice for violation of community rules.

Some community rules allow thelandlord entry (at will) into the homesowned by the residents. One residentbelieved the landlord had entered histrailer and removed property. Less than ayear after this dispute, the landlord evictedhim.

Another homeowner was given 30days notice because park management feltthat drying clothes outside of her homewas a violation of community rules. Shewas especially upset to leave the manyimprovements she had made on her lotspace.

The Austin Hills Mobile HomeEstates explicitly prohibits its residentsfrom organizing though the use ofpetitions. This park also charges thetenant for any work done on the leased lotbut retains ownership of the improve-ments. The community rules at this park

require the tenant to give 30 days noticebefore vacating, but allow management toterminate the tenancy, effective immedi-ately, for violating any part of the rentalagreement. Other specific rules include:children must be quiet and orderly, andbikes may not be ridden to the communitypool.31

RecommendationsGive Manufactured Homeowner Tenantswarning before closing parks. Twelvemonths warning should give all theresidents enough time to locate spaces thatwould accept their homes. It would alsogive the tenants time to make an offer tobuy out the current owner of the park andcontinue operating it themselves.

Clarify the relationship between home-owner and the park owner. Give tenantsthe right to a one year, written, renewablelease that clearlydiscloses rent levelsand the rate of rentincreases.

Require landlordsto show good causefor evictions.Evictions can costhomeownersthousands of dollarsin moving costs anddamage to units.

Respect the individual rights of thetenants and require community rules torelate to the health, safety, and welfare ofpark tenants. Void unreasonable andarbitrary park rules and return the rights ofprivacy and freedom of speech andpetition to homeowners. Thesehomeowners are not renting the home: it istheir property. Landlords should not havea right of entry except in emergencies.

Current LegislationH.B. 557 would provide some of theprotections needed in Texas. This bill:! Requires renters to have the option ofa one-year written lease. This is the law inat least 13 states, including Illinois, Iowa,Washington and Florida. Written leasesare required or must be offered in 24states.! Requires renewal of leases.! Requires 12 months notice prior topark closures. At least 20 states requirenotice of change of use, including NewMexico, Ohio, and Nevada.! Provides legal protections equivalentto those of tenants under the PropertyCode on matters such as security depositsand repair/repair-payment procedures. Atleast 28 states, including Arizona, Minne-sota, Oregon and Florida require landlordsto show good cause for evictions.! Prohibits evictions without cause.! Prohibits interference by landlords inthe sale of a home, landlords fromrequiring that tenants use them as a salesagent, and prohibits landlords fromrequiring that tenants move the home outwhen they sell it.


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States Legislate a Wide Variety of Protections Designed to Help FamiliesMaintain the Equity in their Home and Enjoy a Secure Future

This bill does not:

! Require multi-year leases. Long termleases provide the long-term stability andpredictable rent increases which would beneeded to make manufactured housing ahousing option for those living on a fixedincome. The National CommunitiesCouncil, a park-owner industry group,recently found that leases five yearslonger than financing terms (i.e. 35 yearsfor a 30 year loan) would be needed toobtain conventional financing on manu-factured housing.32

! Address “tying” of manufacturedhomes or required services. Consumersshould have access to the whole marketwhen buying homes or add-ons. TheUrban Land Institute found that “in all butthree states, the developer must admit anyhome that meets the communities designguidelines.”33 Our lack of a specificstatute leads us to believe Texas is one ofthose three states.! Provide right of first refusal. Resi-dents should have the opportunity to buythe park out at the same price as otherpurchasers to prevent change of use. Atleast six states provide for this.! Prohibit forced removal of homesfrom parks because of age. Once acceptedinto a park, a home should not be forced

out of a park solely because of its age ormodel. At least seven states provide forthis.34

Texas has a long way to go to protect thisunique class of homeowners. They needaccess to stable, safe, and fair environ-ments for placement of their homes. It istime we act to give them the rights theyneed. HB 557 is a long overdue first step.

Endnotes1 Dickson, Gordon, “Mobile HomeTenants will be forced to move; Grape-vine approves single-family houses forpark,” Fort Worth Star-Telegram, 2/21/01.Unless specifically citing to other sourceslike news clips, all personal exampleswere provided through interviews withLegal Aid of Central Texas (LACT).

Ms. Lopez came to Legal Aid of Central Texas in the fall of 1998 with a problem: herlandlord had given her a 30 day notice to vacate her lot of 16 years. The park managerclaimed that Ms. Lopez had failed to repair a water leak, her lot was not well kept, and an air-conditioning unit had been on her porch for over a month.

70 year old Ms. Lopez had attempted to get the water leak fixed previous to her evictionnotice. The repairman, however, refused to work on her water because of standing sewage inthe area around her home, caused by problems with the park sewage system. The worker felt itwas dangerous to work under such conditions. Several boxes and some furniture were outsideher unit from her daughter’s recent move, awaiting rental of a storage unit. The air-condition-ing unit, which was functional, was on her porch while she waited for help to move it intostorage.

Ms. Lopez had no recourse under current statutes in Texas. Her 16 year residency could beterminated with little notice or provocation. In this case, because the absentee landlord droveby her property and didn’t like what he saw from his car window on that day.

Source: Interview with Legal Aid of Central Texas personnel.Name of tenant changed to protect her privacy

No Protection from Eviction, Even After 16 Years

2 December 2000 Current PopulationSurvey, Bureau of Labor Statistics.3 Number of Titles from Texas Depart-ment of Housing and Community Affairs(TDHCA). Titles by county report,August 2000. County Populationsfrom “Population Estimates Pro-gram January 1, 2000 Estimates ofthe Total Population of Counties”,Texas State Data Center. Countytype from Comptroller of PublicAccounts: Reference Table,County Definitions.4 Tarrant Appraisal District, 2000 StateUse Code Statistics, September 2000. Inrural counties, land ownership is morecommon. In Angelina County, forexample, nearly two thirds of manufac-tured home owners own their lot.5 Manufactured Home Financing 1998,Manufactured Housing Institute6 State Summary of School Reports ofProperty Values, Comptroller of PublicAccounts, 1999. Texas A&M UniversityReal Estate Center, 2001 Real EstateReview and Outlook, January 2001, p.7.Texas A&M estimates that 2.8 people livein a manufactured home in Texas. Ourestimate uses the number of rental homesreported in property tax roles, minus theestimated number of vacant homes,multiplied by 2.8 persons per non-vacanthome.7 Testimony by Steve Rogers of theTMHA before Texas House of Represen-tatives, Urban Affairs Committee on 8/30/

00.8 December 1999 10-K, Sun Communities,Inc. Pg. 5.9 Internet source: http://www.Mobilehomeparks.com10 Unfair and Deceptive Acts and PracticesManual, Cumulative Supplement 2000,National Consumer Law Center.11 June 1999 10-K, Clayton Homes, Inc p.9 & p. 11.12 Travis County Appraisal District,Appraisal Roll search, www.traviscad.org,and Securities and Exchange Commissioninformation about company ownershipand affiliates.13 Unless otherwise cited, information onstate statutes is from: ManufacturedHousing Park Tenants: Shifting theBalance of Power. AARP 1991.14 Oregon Revised Statutes Title 10§90.632.15 “Statewide Manufactured HomeShipments (1970-1999)” NationalConference of States on Building Codesand Standards, as reported by the Manu-factured Housing Institute.16 According towww.mobilehomepark.com, Californiaand Florida have more parks than Texas.Both of these states have laws covering lotrental, including the requirement ofoffering a one year lease.17 El Paso County Appraisal District 1999tax values. A study in Oregon found “Thecombined investment of the homeowner’saverages a 65% greater investment than

that of the park owners” ManufacturedHome Owners of Oregon, inc./OSTA.Internet Source: http://www.mhoo-osta.com/html/facts/html18 Names of tenants have been changed toprotect their privacy in all stories.19 Foremost Insurance “1999 MarketFacts” Internet Source: http://www.foremost.com/market_facts/20 2000 Real Estate Market Overview:Longview-Marshall MSA, the Real EstateCenter of Texas A&M.21 Interviews with Park Residents, Dec2000 and Feb 2001.22 “The Problem of Mass Evictions inMobile Home Parks Subject to Conver-sion” Michael Sheehan and Roger Colton,Fisher, Sheehan and Colton PublicFinance and General Economics, Decem-ber 1994 p. 9.23 Internet Source: http://www.mobilehomeparkstore.com24 AARP, 1991, p. 3.25 Personal Interview, February 2001.26 “Homeowners, and Tenants Too”Shelterforce, July/August 2000, NationalHousing Institute.Internet Source: http://www.nhi.org/online/issues/112/rosenbloom.html27 Texas Natural Resource ConservationCommission Chapter 291 – UtilityRegulations subchapter H rule §291.124.28 Internet Source: http://www.creico.com/texas.html29 “Final Report,” National Commissionon Manufactured Housing, August 1,1994, p. vi & p. 54.30 “Home Specifications,” DeerwoodSales package.31 "Rules and Regulations" Austin HillsMobile Home Estates, dated 8/97.32 “Conventional Mortgage Financing OnHomes in Communities a Reality,”Communities Council, Summer 2000.33 Manufactured Housing: An AffordableAlternative Diane Suchman, Urban LandInstitute March 1995.34 Manufactured Housing Park Tenants:Shifting the Balance of Power. AARP1991 And Oregon Revised Statutes§90.632

Consumers Union SWROConsumers Union SWROConsumers Union SWROConsumers Union SWROConsumers Union SWROReporReporReporReporReportststststsTexas eye doctors limit access to contact lens prescriptions.

Bereaved families suffer even more when funeral plans go bad.

Texas is #1 in waste from large-scale animal production operations.

Inequities continue in home purchase, refinance markets.

Payday lenders disguise usury.

And Much More...

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