Vermont Legislature SmartTranscripts:

[Marc Mihaly (Chair)]: Alright, welcome back everybody, it is Tuesday Let's talk about that, yeah. It's Tuesday, January 27 still, this is still the House Committee on General and Housing, and we're hearing H757, which is a bill relating to manufactured home communities and limited equity cooperatives that are manufactured home communities. Our next witness is Jeremiah Ward, who's a specialist with the Cooperative Development Institute. Jeremiah, please identify yourself for us and take it away.

[Jeremiah Ward (Cooperative Development Institute)]: Hi, everyone. Thanks for having me. My name is Jeremiah Ward with Cooperative Development Institute, and actually, my current title is now Water Infrastructure Support Program Director or WSCC Director, and I work with co op manufactured housing communities and nonprofit owned manufactured housing communities in Vermont to raise capital to upgrade their infrastructure. And I should be able to answer questions on a lot of the parts of the bill that are related to manufactured home titling, but I was hoping to do a ten minute, seven slide presentation first to set some context, if that's okay. Please go ahead. Okay. Give me a second. It's always tricky to Did everyone see the slide? Yes. Okay. So I'm going to use shorthand to refer to limited equity co ops that are manufactured home communities in Vermont as co ops to avoid tripping over words. And to my knowledge, are 18 of them in the state serving about 1,700 households or almost a quarter of all the manufactured home lots and manufactured home communities in Vermont. And I was actually part of forming 16 of them. I've been with CDI since 2010, so almost sixteen years. And we continue to provide support to the 16 of the 18 of them through two programs. One program supports co ops with their day to day governance and operational support, it's called NEROC or New England Residential Communities, and my current program, WISP, Water Infrastructure Support Program, serves co ops with their infrastructure fundraising needs. And these limited equity co ops are a key source of affordable housing in the state. They're predominantly low income. At acquisition in the formation process of each co op and then to apply for grant and low interest loan funding for infrastructure projects are regularly income surveying the communities, and they are definitely low and moderate income. When you take the aggregate of the portfolio of sixteen, eighty four of the households living in co ops earn less than 80% of area median income and 60% of households earn less than 50% of area median income. So 60% are what HUD calls low income. Co ops operate on a not for profit basis. The members set their own budgets and the lot rents are set at cost. So the cost to run the community, which includes all the operating expenses plus the debt service that was required to acquire the community plus capital reserve amount and then a 10% cash flow buffer required by lenders. So they don't have any incentive to charge themselves more than what it costs to run the community, essentially. Pretty much every single co op we work with, the end of year surpluses, if there are any, get reinvested into replacement reserves for capital improvements. And because of this not for profit basis or the way that they're structured, rents in these co ops typically increase less than the market, even with the controls in place under the Title 10, Chapter 153 Mobile Home Park Law with some restrictions on rent increases. The co ops increased the rents at a lower rate, 1.2% per year, which is pretty impressive. But there's this looming issue that's been growing over the years, which is the condition of co op infrastructure or manufactured housing community infrastructure in general. Infrastructure in these manufactured housing communities was typically built in the 1960s and 70s, sometimes a little earlier, sometimes a little later, and back in the day they were built with little to no regulatory oversight and as such, they're pretty poorly built. We've seen some crazy things in my line of work. So now we're at the point all these decades later where the bills come due, so to speak, where all this infrastructure is at the end of its life cycle are well past and we're trying to cobble things together and the cost to replace infrastructure is extremely expensive, We're seeing on project budgets fifty to sixty thousand per home, and that's just for drinking water, which is DW, wastewater and storm water and the roads on top of that infrastructure. It would be even higher probably by another 10 to 15,000 per unit if you added electrical as well. And infrastructure ownership in these co ops differs from ownership in other residential neighborhoods. And this is, I think, a key point that speaks to the section in the bill talking about property taxes. My coworker made this graphic because it's really helpful to see with a visual. On the left hand, this is what co ops have to deal with right now, where the homeowner owns and maintains everything in the manufactured home envelope in purple, pays all the bills, you know, for the electric for the home, the any water lines in the home, and then the co op is responsible for maintaining and replacing the service lines that run from the homes to the street and then the mains that are under the street, plus the co op pays for, so that's water, sewer, storm water, electric, plus the road itself and plowing it and replacing it and resealing it and paving it. Whereas on the right hand side, if co ops were treated like a typical neighborhood, residential neighborhood, anywhere in Vermont or The US, this is what it would look like where the town or the utility would own and maintain the infrastructure in the roadway, including the water and sewer mains under the roadway and then the homeowner and co op would just be dealing with the home envelope and the service lines respectively. I guess in your typical residential neighborhood, the homeowner would not only have to do with their within the home envelope, but they would have the service line responsibility too where but it gives you a general idea of the co op on the left is dealing with a ton of infrastructure responsibility compared to what a traditional resident in a traditional neighborhood has to deal with on the right. And this slide kind of goes into that a little bit more. So it's really important to see that co ops have this whole layer of intermediary infrastructure between where the town's responsibility ends at the front entrance of the park and what the homeowner deals with inside the home. And people don't see this and we see this in my very niche special line of work and it's good to hammer home this difference, this, I would say, inequity. And I would point out that by putting all this responsibility on the co op to deal with this intermediary infrastructure, that's asking a lot of low and mod income households, a small universe of low mod income households to collectively pay for the typical or the range of co op sizes in Vermont is nine units on the small end to two sixty five units on the larger end. And that's not a big universe to spread millions of dollars of infrastructure replacement costs a month.

[Marc Mihaly (Chair)]: Jeremiah, a question.

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: Go ahead.

[Marc Mihaly (Chair)]: Well, first of all, the situation you're describing applies to any mobile, right, whether it's a limited equity co op or not? Correct. Second of all, is there any I mean, than the fact that local government just doesn't wanna pay more money, is there any policy justification?

[Jeremiah Ward (Cooperative Development Institute)]: Policy justification for that? I think it's just a lot of people don't see that this unfairness exists, and then when we ask a municipality to treat the community more like a typical neighborhood, they have a million excuses like, Oh, well, the roads aren't regulation size, so we don't wanna plow and maintain the road. And then we're like, Well, how about give you How about you maintain the sewer and water mains underneath, but the co op will still deal with the roads and they'll still have reservations about that due to funding, they're already maxed out with their own budget, etcetera, etcetera.

[Marc Mihaly (Chair)]: Another question, go ahead.

[Emilie Krasnow (Ranking Member)]: Sorry, I'm struggling with my question because in almost every conversation I've had, specifically last year and this year, it's this concern about municipal cape capacity, not capability, excuse me. And I'm thinking of like some of our smaller towns, like what incentive would a municipality have to take over this huge undertaking of infrastructure? And absolutely this is an issue for these low income households, but as a legislator, how can we go to a municipality and try, like, you have any recommendations there? Because I don't think there are any incentives for a municipality to say, Hey, yeah, you know, I want to take on the liability of this sewer or wastewater.

[Jeremiah Ward (Cooperative Development Institute)]: That's a good question. I think, yeah, devil's always in the details about, and we have approached municipalities to sponsor loan applications and grant applications, and some have been forthcoming on that front. But actually taking ownership of infrastructure that's being built at the end of the project, they have their concerns and reservations, yeah, some sort of incentive to It just makes sense rather than having all these little mini water and sewer districts, which is essentially what these MHCs are, having them rolled into their municipality, there's economies of scale and efficiencies there, but it's just, it's a hard thing to do on a case by case, town by town basis. It helps having a program like Mine There to help with some of that discussion of the project and how to set up operations post project, but it's still difficult working on a town by town, water district by water district approach.

[Emilie Krasnow (Ranking Member)]: Sorry, I'm almost done. So I'm looking at your last bullet, the North Abs project is $7,000,000 to upgrade the infrastructure for 120 homes.

[Jeremiah Ward (Cooperative Development Institute)]: Yep.

[Emilie Krasnow (Ranking Member)]: Continuing kind of with this realm of thinking, say a municipality decides to say, yes, we're going to take over that, who then pays for that? Is it the entire town's Would tax that then be put on a ballot for a town or is that just a municipality's choice? I

[Marc Mihaly (Chair)]: think unless a municipality decides it wants to put on the ballot, I think it would just be a choice. It would be in the budget, probably. Well, would be in the budget.

[Emilie Krasnow (Ranking Member)]: And then 10 votes I on the

[Marc Mihaly (Chair)]: mean, I really wonder whether any of, to your knowledge, has any manufactured home said to a town, well, you pay x percent of your budget on infrastructure and we don't get the value of it, so you have to reduce our property taxes. Right. Yeah. That's

[Jeremiah Ward (Cooperative Development Institute)]: yeah. That's kind of that's where I'm I'm getting with this

[Marc Mihaly (Chair)]: Okay. Well, let's keep going.

[Jeremiah Ward (Cooperative Development Institute)]: Presentation. Yeah. But I mean, North Avenue is actually an example of

[Marc Mihaly (Chair)]: The community.

[Jeremiah Ward (Cooperative Development Institute)]: The city has provided some grant funding for the project and has been supportive all along, But at one point we asked them to take ownership of the completed infrastructure. They aren't willing to do that, but they are willing to take on billing for the water and sewer to individual households rather than the co op having one big bill and taking care of that. So they have been a partner, but not to the extent of what that comparison graphic was getting at. But yeah, getting back to the presentation, it's very expensive, and North Avenue's project is completely replacing the drinking water system, wastewater system, storm water system, and roads, so it doesn't even include their electric, And it's $7,000,000 it's about 57,000 per home and it's been a lot to cobble together all the different funding sources to try to make it work. The point I was making was towns and utilities can spread their capital needs among a greater customer base, and they also have access to better funding programs, low interest loans, grants, etcetera, that co op MHCs don't have. Some strategies to try to remedy this inequity, Like we were saying, have towns and utilities take ownership of roads and utilities and roadways and co ops, very limited willingness or examples of that happening in our experience, provide grant funding for co op infrastructure, and we're now in a post ARPA COVID era where that's less available than it was a couple years ago. And I'll just stress the importance of grant funding because there are still clean water state revolving fund, drinking water state revolving fund, there are still programs that pay for infrastructure upgrades that co ops can use, but it often requires debt service, which would require rent increases beyond the current levels. And when you're talking about these big project price tags of 4,000,000, 5,000,000, $7,000,000 and even a low interest debt service payment to finance that means a rent increase threatens affordability. And then revisit co op taxation. MHC co ops are taxed in two layers, the value of the home and the home site that each household pays, and then the value of the MHC land that the co op pays and collects funds for out of the lot rent it charges to households. And in my experience, what I've seen is the land tax for the co ops in our portfolio are often the valuation set using an income approach, which is treating them, the co ops like they're a for profit manufactured housing community, which they're not because they, as I mentioned on an earlier slide, they operate it on a not for profit basis and they're incorporated in a part of the Title XI Chapter 14 statute that says they have a public benefit. So I think there are, especially when assessments are based on the income approach, have the potential to be overtaxed just based on how they're analyzed financially. And then I would make the point that towns and utilities provide less services to co ops and MHCs more broadly than typical residential neighborhoods. And in my opinion, the land tax payable by co ops should be adjusted to account for this. Any reduction in land tax payables of the co ops would instantly free up purchasing power of the co op that could pay for that infrastructure debt service from those infrastructure financing programs I mentioned. None of this is to say that, this is talking just about the land tax portion, the households residing in coops would continue to be taxed on the value of their home and homesites in this scenario. And at the end of the day, if this inequity goes unaddressed, coops have this choice of either dealing with failing substandard infrastructure and trying to band aid things together, or they'll become unaffordable in the process of replacing it. And last point I'll make and then I'll stop the slide is that in my experience, the for profit manufactured home community owners have been treated differently than when co ops form and then take ownership of their communities. All of a sudden it seems like all the regulators are like, Oh, there's a co op now. Regulate we them and insist upon the highest standard of construction and upgrades, whereas certain things have gone unaddressed under private ownership, and now the co op has to pay the bill for that when they form. So I'll stop there.

[Marc Mihaly (Chair)]: She's coming. Questions for Jeremiah.

[Emilie Krasnow (Ranking Member)]: The last, hi Jeremiah. Just a question on the slide where you indicated, this last slide, that sometimes the co op is taxed on an income approach. What income, like they're treated like an individual resident and any of the, what, rent payments are considered income or what's So the

[Jeremiah Ward (Cooperative Development Institute)]: it's a little tough to explain, but basically an assessor, so an assessor will send out a form that I will help a co op fill out, which asks to list the total rents collected in the year for the co op and then list just the operating expenses that the co op pays during the year. So tax bill, plowing, water sewer, etcetera, not the debt service. So it's it's looking at the park, assuming a for profit buyer with tons of cash came in, doesn't have a mortgage, and you take the total income from lot rents minus just the operating expenses and there's this huge net operating income number because if you're a for profit investor and you have a lot of cash and you could just buy a park with cash, you're doing it because you want to make a ton of money and they can make a ton of money. So you take that annual net operating income that I described and then you apply a capitalization rate to it, which is based on the market, and it calculates for you what the marketplace values these for profit perks.

[Marc Mihaly (Chair)]: Jeremiah, isn't it the The NOI for a co op is going to be lower than the NOI for a privately held operation, because a privately held operation has to have a profit. Why isn't the NOI close to zero for the park and therefore the cap rate is applied to a lower number?

[Emilie Krasnow (Ranking Member)]: Yeah.

[Jeremiah Ward (Cooperative Development Institute)]: All I know is I fill out these assessment forms every year and I always put, you can't not account for the massive debt service that the co ops are also paying.

[Marc Mihaly (Chair)]: Right.

[Jeremiah Ward (Cooperative Development Institute)]: And that's part of the reserve contributions.

[Marc Mihaly (Chair)]: Oh, in other words, they have to look at NOI after debt service and they don't always do it.

[Jeremiah Ward (Cooperative Development Institute)]: Yeah. I don't I don't believe so. No.

[Marc Mihaly (Chair)]: We have our next two witnesses waiting. Gayle, did you wanna ask a question now or wait? Wait. Okay. Jeremiah, thank you so much. Really appreciate it.

[Jeremiah Ward (Cooperative Development Institute)]: Thanks,

[Marc Mihaly (Chair)]: Tom. Our next witnesses are Rachel McLeod. Hi, Rachel. Good to see you again. From East Rise Credit and Ed Fitzpatrick from Burger and Paradise and Fitzpatrick, who is a lawyer who's worked a long time in this area and works with Rachel. You should know I've met both of them in the past. I want to tell you before you start that we heard testimony from Rachel Siegel from Pew Trust. It's the first chance the committee got to ask questions, and the kinds of questions that came up, which she couldn't necessarily answer, were questions like, and they've come up before when we had a walk through, like, what is the titling difference? How do you title? What do you think other banks do? Are these limited? Are the LEC's non profits, for profits? What are they really? Is there a separate co op categorization? Does it affect your loans? Stuff like that. But take it away and tell it, let us know your names for the record and give us your testimony.

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: Thank you, Marc. This is Ed Fitzpatrick. I'm an attorney with Bergeron Paris and Fitzpatrick. I've worked with a credit union for a few years now on manufactured housing and collectively we've had our head explode a few times. So I'm going to avoid any discussion of cooperatives because we haven't had any involvement in that just yet. But as it happens, titling is kind of important when it comes to manufactured housing. So by way of background, a couple of years ago the credit union decided that they wanted to expand into this market to make it, know, to expand the housing because they knew there was a market for people who wanted housing and who might not be able to afford what are ever increasingly expensive stick bills. And they reached out to me to help them prepare a protocol that we could share with all of their approved attorneys. And it took us over a year primarily because the then existing statutory scheme in Title IX Chapter 72 was just clunky to put it mildly. Not to mention the fact that very few people involved in manufactured housing transactions were aware of that statute and I think fewer, a lesser number actually applied it. You got rid of the conversionpurging part, section 2,605 I think, and that was wonderful to see that because in my limited experience since I was doing this with Rachel, I don't think any town clerk was aware of that process. I also think that there are a lot of existing transactions out there where somebody acquired a mobile home with a mobile home bill of sale, a manufactured home by a bill of sale and secured their financing with a residential real estate mortgage because I don't think a lot of people were aware that that was supposed to be a deed. One So of the other things the credit union wanted to do was try to keep the cost down for the borrower to make this as affordable as possible. So one of the things the credit union did was they opted to treat all of these loans as in house loans, portfolio loans, thereby eliminating a number of specific regulations the secondary market has. And they also made a business decision to tweak some of the buyer's attorney's responsibilities to help keep that cost down. So that led us to our meeting with Marc, which was very productive and much appreciated. And I guess, pending any of your questions, we can tell you that we like what you did in this proposed bill with one possible comment we'd like to make. I don't understand why a borrower or a buyer can't have the option of getting titled with a bill of sale, why it's mandatory that they have to do a warranty deed or a quick claim deed. By way of the To treat

[Rachel McLeod (Eastrise Credit Union)]: it as real estate.

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: Yeah, mean, you can still treat it as real estate, that should be an option we think.

[Marc Mihaly (Chair)]: We left it that, I thought the bill leaves it that way. In other words, we had the option, remember there's a section, I don't remember which section it is, that says that if you own the property, the existing law says if you own the property, then it shall be treated as real estate, but that if you don't own the law it may be treated as real estate and we didn't change that.

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: No, you didn't, but if it's treated as real estate you have to do a deed.

[Emilie Krasnow (Ranking Member)]: Right.

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: Okay, so what we're saying is, I'll give you an example, the credit union had a borrower that acquired a mobile home in a park with a bill of sale and he wanted it refinanced so he applied for a refinance with the credit union, he was told he had to deed the manufactured home to himself in order to comply with the statute. That's an extra cost.

[Marc Mihaly (Chair)]: But isn't that just because the credit union, I don't know Rachel, isn't that just because the credit union has made an internal decision that it only wants to loan on a real estate basis, It doesn't want to do Do you do personal loans?

[Rachel McLeod (Eastrise Credit Union)]: We do, but we, for a lot of reasons, originate manufactured homes in a park or cooperative in our mortgage department. And therefore we follow all the mortgage guidelines from beginning to end and regulations and whatnot. So that was kind of a business decision we made, but also if you think about those home buyers, they're going to get the best service in our mortgage department versus our consumer loan department, right? Because we're used to working with homeowners and home buyers.

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: And they typically mark a residential real estate mortgage loan comes with a lower interest rate than the personal property. So what everybody's trying to do what's best for these to accommodate the housing need and while the credit union decided that they were going to handle all this through the mortgage department and therefore they asked me to tell them what they had to do, I don't personally understand why you need, why it's mandatory that you have a deed when you're doing a real estate loan financing. I understand there are times when you need to have a deed, if the lender is going to sell their mortgage on the secondary market, it's likely that there has to be a deed, but the credit union has opted to keep these in house and I think if go ahead. No, I was going to

[Rachel McLeod (Eastrise Credit Union)]: say we have to keep them in house. If

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: they were to get somebody who was to acquire a mobile home, a used mobile home as it was most often, with a bill of sale, they ought to be able to get financing secured by a residential mortgage. I'm not sure why you have to do a deed.

[Marc Mihaly (Chair)]: Okay. You know, would like to, I understand, you're now I understand you're asking a question I've never heard before, which is, even if it's a real estate loan, why do we need a deed? And I'm not in a position to answer that other than I think there's terrific value when you go to sell things and inherit them, etcetera, if you have a recorded deed. But put that aside for a minute, can we go back? One of the questions that I think is in the minds of a number of us has to do with this conversion. At your request, I'm confessing here, at your request, at only your request, we eliminated the conversion sections in this bill because you told us that nobody follows them or understands them, and we're trying to simplify. But the question is, and people here are not that familiar with this whole world, I'm assuming you feel that one can go through the normal process of buying a mobile home with a bill of sale, going to a lender like Eastrise and getting a real estate loan is what happens, as I understand it, and you don't need conversion, is that true?

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: Yes, a couple of things, Marc. In these transactions, the buyer's attorney is always noting the liens on the mobile home and those are all taken care of at the closing. So that satisfies the purging aspect of that. The other, I reached out to two town clerks that have mobile home parks in their towns. Neither of them had ever heard of this. One of them said it to their town's attorney and the town's attorney cited that statute, but prior to that, that town clerk had not heard of that process. One of the town clerks got back to me a couple of weeks later to tell me that on the, for lack of a better phrase, the town clerk listserv, a town clerk from the southern part of the state reached out to everybody and said we just got this letter from an attorney asking us to purge, has anybody ever done that? So you had a statute that no one was following and that was designed to, I think, make sure previous financing had been paid off and taken care of and that's all happening during the process.

[Marc Mihaly (Chair)]: Anyway.

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: Anyway, so you know, if you don't need the statute and no one's using it, you should take it out and I applaud you for doing so.

[Marc Mihaly (Chair)]: Is, Rachel, maybe it would help if you could just describe to the committee what happens when, just walk us through the process of buying a, let's do start with a new one, going to a dealer and buying a new, you know, manufactured home and wanting to finance it with you, could you just walk us through the steps, what happens?

[Rachel McLeod (Eastrise Credit Union)]: Well, a lot of times, either that the sales contract with that dealer comes through to us, along with a bill of sale, and at that point, that's when we have a discussion of, we treat these as real estate, so we're going need a warranty deed.

[Emilie Krasnow (Ranking Member)]: How is that,

[Marc Mihaly (Chair)]: who issues the warranty deed? Does the dealer issue a warranty deed or does the buyer have to deed it to themselves?

[Rachel McLeod (Eastrise Credit Union)]: We've kind of got two scenarios right, so if you're in a park for instance, I think now I'm going to speak for Fecto who I saw your meeting with tomorrow, I think Fecto has been known to have their attorney draw up a warranty deed for a home that will be placed in a park. When there's a seller who's not a dealer, so for an existing home then that seller needs to get an attorney to draw up the warranty deed, which again sometimes those sellers come you know they provide us with, or they're a buyer with the purchase and sales and a bill of sale, and that's when we kind of have to work backwards and say, you're gonna need a seller's attorney to draw up a warranty deed.

[Marc Mihaly (Chair)]: So, somebody draws up a warranty deed, somebody. It could be the original dealer, it could be if they didn't do it, it could be seller, if it's a private individual, and, but one way or another, you guys, you do a loan, require a warranty deed, right? Which is, by the way everybody, a real property deed. Okay, then what happens? Then take us a little further.

[Rachel McLeod (Eastrise Credit Union)]: So, let's say by now the loan is approved, we know it's going forward, and we send a title work request. Well, the borrower chooses their own attorney. We have our own, sometimes they're the same attorney because that's allowed in Vermont, dual representation they call it. We send a title work request to the attorney who's either representing buyer and lender or both. And so we give them our instructions for what we need and then they take it through, they search the well, in a park, it's a very different process than owned land. I should say on leased land is very different than owned land. And so the biggest pain points are when they're on leased land. So in parks, cooperatives, that sort of thing. We're having the attorney do a search of the park, we'll say, ten year search. And then we're having them do a search, a UCC search for the home.

[Marc Mihaly (Chair)]: A UCC search is relating to the bill of sale. Right?

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: If you represent Joe Blow who was getting a home, a mobile manufactured home in Colchester, you go to the Colchester land records and search everything that Joe Blowes had done which you're going to find a bill of sale, you're going to find a UCC financing statement, you may very well find a mortgage or you may very well find just UCC financing statement is indicative of a personal property loan pretty much. So at that point in time when the closing occurs, the credit union is going to demand the payoff and that payoff is going to be made so that lien gets taken care of.

[Marc Mihaly (Chair)]: So then they own it and they have a mortgage with you, what currently do you, what mortgages do you offer in terms of duration, interest rates, and down payment?

[Rachel McLeod (Eastrise Credit Union)]: So we have for a brand new manufactured home, well okay, again we have to, there's disparity, there's differences between unowned land and leased land, okay? So on owned land, a lot of what you can get for a stick built home is available to those homeowners and home buyers on owned land. But when it's in a park or cooperative, the same mortgage programs are not available. They don't really have, there's no saleable loan programs unfortunately. Fannie Mae is working through trying to be able to provide those mortgages. And Gayle, I know you've talked to New Hampshire Community Loan Fund quite a bit. They're doing them in New Hampshire with Fannie Mae, but I don't really know, I don't think there's any Vermont lenders. Anyway, I just digressed.

[Marc Mihaly (Chair)]: We'll get back to that, that's important, but go ahead.

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: Is there a difference between the interest rates?

[Rachel McLeod (Eastrise Credit Union)]: Yes, so if it's in a park, what we're offering is for brand new, twenty year fixed rate, If it's new or used, can do a fifteen year, but the max is a twenty year for a new whereas if it were on old land, can go up to a thirty year for instance. And then yes, the interest rates are higher for our twenty year and our fifteen year in a park product versus saleable unowned land. It's thought to be higher risk.

[Marc Mihaly (Chair)]: What else? Can you just give us an idea of the differential? Just about. It's more like

[Rachel McLeod (Eastrise Credit Union)]: 7.875, where I think we're at just below six on a thirty year fixed.

[Marc Mihaly (Chair)]: Sorry, I didn't hear you. Just below six on a thirty year And for a new twenty year lease. I couldn't hear.

[Rachel McLeod (Eastrise Credit Union)]: I think it's like 7.875.

[Marc Mihaly (Chair)]: Yeah, okay.

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: Changes periodically.

[Emilie Krasnow (Ranking Member)]: So,

[Marc Mihaly (Chair)]: when I talked to you, we just heard that Fannie Mae is extending its pilot program from New Hampshire into Vermont, but as I remember you said part of the problem with Fannie Mae is that they have requirements which add to the cost of closing. You want to say anything about that? The

[Rachel McLeod (Eastrise Credit Union)]: list is so long of hurdles. So, has to be real estate, Treat it as real estate, it's got to be a warranty deed. If there's any structural modifications to the home, it can be as little as a porch stoop put on there. You need a structural inspector to come out and inspect the home and make sure the integrity hasn't been compromised. Wheels, hitch, everything needs to be removed. Has to have tie downs. It's got to be on a permanent foundation. Know, got to be careful with those piers, for instance. And then, so Gayle can attest maybe, well, I don't know if Gayle's seen it as much, on the New Hampshire side where they are doing those Fannie Mae loans, the hurdles are there's this monumental amount of paperwork that a board member of a cooperative would have to complete that even I don't understand and I'm in the mortgage business. I don't know that they have the time or the resources to understand it, let alone complete it And that's just to get your cooperative approved. They don't do parks, they only do cooperatives. And that approval is only good for two years, and then it has to be done all over again. And by the way, there's a cost to the lender for seeking that approval in that cooperative. So every two years we would be paying a fee, with the co op to get that approval reapproved and at a cost. Cost is not as much the worry, it's more the work and the resources. And then I'm going to add more to that. Appraisals. So they have specific requirements for those appraisals for those manufactured home units. None of our appraisers in Vermont are trained to do that level of appraisal and the guidelines that they abide by use PAP. They're required to be confident and they're not going to call themselves competent unless there's training out there that they can take. So it's quite a, there's a lot of hurdles there to make manufactured homes in cooperative saleable to Fannie Mae.

[Marc Mihaly (Chair)]: If they were, would it reduce the interest rate?

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: Yes. So

[Rachel McLeod (Eastrise Credit Union)]: we try to sell a lot of our loans, we still service almost all of them, but the goal is to kind of have a balance. I think we sell 50% of our loans on the secondary market.

[Marc Mihaly (Chair)]: Do you sell the mobile home loans on the market?

[Rachel McLeod (Eastrise Credit Union)]: We land but not we can't in a park or co op.

[Marc Mihaly (Chair)]: Right, yeah. Okay. What about the rate of mortgage, people who don't default on the loans. Have you had many defaults?

[Rachel McLeod (Eastrise Credit Union)]: There is a higher delinquency rate for the ones in parks and cooperatives. However, when I looked back at those, a lot of them were originated many years ago, so we don't really, we had one current one in default. So I think that's a good sign, including that, you know, we did a revamp of this whole process and our underwriting and whatnot, and that seems

[Marc Mihaly (Chair)]: to bode well. If I just to clarify, if I come in and I do not have the cash one way or another, even with state assistance or something, I don't have the cash for a mortgage, 20%.

[Rachel McLeod (Eastrise Credit Union)]: Yeah, that's what we require, 20% down on April. Will

[Marc Mihaly (Chair)]: East Rise outside of your mortgage department rate me a personal loan, or do I have to go somewhere else?

[Rachel McLeod (Eastrise Credit Union)]: You'd have to go somewhere else.

[Marc Mihaly (Chair)]: I don't want to preclude others from asking questions.

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: You can see,

[Rachel McLeod (Eastrise Credit Union)]: this is

[Marc Mihaly (Chair)]: a I mean, they're inventing the wheel.

[Emilie Krasnow (Ranking Member)]: Well, this is exactly, yeah, my question was simply, you're representing how EastRise deals with manufactured home loans, but are you representative of the rest of either credit unions or regular banking institutions in our state?

[Rachel McLeod (Eastrise Credit Union)]: Yeah, so far as I know of one other credit union who does manufactured home financing and parks and cooperatives, I don't know if I should share their name or not, and they'll go up to 90%. So we can't get private mortgage insurance on these loans. They have kind of weighed their risks and so they'll go up to 90% without private mortgage insurance. I believe they have higher interest rates and shorter terms like we do. I think the biggest risk is the home itself. And then there is one local bank as well. They do business in Vermont and New Hampshire. I don't think they do all that many, though. I could be wrong.

[Emilie Krasnow (Ranking Member)]: And so but is is what you're saying that your your willingness to to deal to to give a mortgage credit rather than personal property credit loan, is that because I feel like we just heard testimony saying that that's not what's been happening and that people are saddled with limited financing options.

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: I think

[Marc Mihaly (Chair)]: that's true in other states. What you're hearing is that as of recently, at least, the mortgage lenders in Vermont are using mortgages, real estate mortgages, correct me if I'm wrong guys, they're treating it as real property. So the banks here, what we don't know is what banks might be doing in Vermont that they don't know about that are writing personal loans. So what they know, this bank knows about is the universe of people who come to them and want a real estate loan. So in some ways, this probably isn't representative of what might be going on in a lot of other states where a credit union like Eastrise doesn't write real estate loans or writes for co ops or for manufactured home communities. I just, do you go to conferences with others like you in other states? Do you know, do you hear that we're unusual?

[Rachel McLeod (Eastrise Credit Union)]: Well, we might not be unusual in that, I know New Hampshire is one of the few states who titles them all as real estate. Fannie Mae was doing engagement sessions over the years with stakeholders across the country, and it seems like a lot of states deal with them, handle them as personal property instead of real estate, and yet Fannie Mae and Freddie Mac want everyone to handle them as real estate. So it's interesting, right? Because they do mortgages, they don't do personal loans. And then I guess I'll just add, when we have a borrower, we can't help, we're referring them to another lender. So I don't really know of many options in Vermont quite frankly. And that was part of the low hanging fruit of this bill. Like how can we make it so more lenders are lending on these? Because it doesn't seem like there's enough.

[Marc Mihaly (Chair)]: Gayle, do you have a question? And then we're gonna move on here. Our next witness is here. Gayle?

[Gayle Pezzo (Member)]: Any

[Marc Mihaly (Chair)]: questions by the committee besides me who was just blithering on here? Any questions before we move on to our next witness? I have one more question. How long have you been ruining this? How long have you been writing these real estate loans for? Are they still with us? Yes, we're here. How long have you guys been at this now?

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: So

[Rachel McLeod (Eastrise Credit Union)]: East Rise Credit Union is a merger of Vermont State Employees Credit Union and New England Federal Credit Union. Vermont State Employees Credit Union was originating manufactured homes in a park before our merger. When we emerged, we decided we wanted to keep that program and we basically revisited it and revamped it so that we could make it as streamlined as possible. So they've been doing it right along. New England Federal Credit Union did it up until 2013. We got out of it and then back in, so here we are.

[Marc Mihaly (Chair)]: It was Vermont state employees and who?

[Rachel McLeod (Eastrise Credit Union)]: New England Federal

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: Was state employees doing mostly personal loans?

[Rachel McLeod (Eastrise Credit Union)]: They had a bit of a hybrid too, but they were forcing their loan origination system to do something that it wasn't doing well and that's where we really were struggling to cut. It was like, that's why we revamped it to some degree. I guess the only thing I would add Marc is when you guys go to Facto tomorrow, they also refer buyers, right? To lenders. And so it'd be good to ask them like, who do they tend to see their buyers go to, especially in a partner cooperative.

[Marc Mihaly (Chair)]: Okay, well thank you so much for your time and your work.

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: Marc, when you talk to your manufactured home vendors, you might want to find out if their purchase paperwork has the sales tax as a line item or if they just lump it in together with the cost of the home.

[Gayle Pezzo (Member)]: Oh, I did have a question.

[Marc Mihaly (Chair)]: Yes, go ahead.

[Gayle Pezzo (Member)]: Rachel, you had told me at one time that the sales tax couldn't be rolled in into a mortgage. Can the PTT?

[Rachel McLeod (Eastrise Credit Union)]: No, I mean, typically your closing costs are handled separately. I mean, the exception to the rule might be, so we do some 100% financing loans, for instance, where if the borrower already put a deposit down, then some of that loan could be applied toward down payment and closing costs, for instance. Examples of that might be like a VHFA assistance loan or we have what we call a home DPA loan where they get a silent second mortgage. So yeah, there can be ways, but it's usually with 100% financing.

[Gayle Pezzo (Member)]: Thank you.

[Marc Mihaly (Chair)]: Thank you very much. I really appreciate your time guys. Thank you. We appreciate what

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: you're doing.

[Rachel McLeod (Eastrise Credit Union)]: Yes. Okay.

[Marc Mihaly (Chair)]: Be well. Alright. Our final witness today is Alexander Schreiber, who's a partner in a law firm. Alexander, are you with us?

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: I am. I go by the nickname Sandy. My formal name is Alexander, which is what the confusion is.

[Marc Mihaly (Chair)]: Sandy, tell us give give us your full name for the record and then your nickname too, and then tell us about your testimony.

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: Yeah. So I am Alexander Schreiber. I'm a partner in the law firm of Phillips, Dunn, Schreiber and Carroll down in Brattleboro. I go by the nickname Sandy, so feel free to call me that. And my testimony is about Tri Park Cooperative Housing Corporation down here in Brattleboro. I'm appearing in my capacity as a private lawyer. I have not been authorized by Tri Park to testify today. I haven't had a chance to talk to them about it. But my firm has been the long term attorneys for Tri Park, at least going back to the 1990s. Tri Park is a cooperative housing corporation, three thirty ish housing units in three different parks in Brattleboro. It's been in existence since 1989, and it was behind, one of its members, Tom May, was behind the adoption of eleven sixteen ten, which is the separate taxation of mobile home statutes that you guys are working on in reference. When that statute was adopted, the town of Brattleboro saw that statute and changed the way Tri Park, which is a limited equity cooperative, is taxed by the town, and they do not tax the entity Tri Park on any of its common land. They instead only tax the individual mobile homes owned by the members of Tri Park. Am surprised to hear that that is not the way it's done everywhere else because I think it should be done that way.

[Marc Mihaly (Chair)]: So you weren't aware that in fact in other areas the common land is taxed?

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: I'm surprised to hear that, yes. I did not know that.

[Marc Mihaly (Chair)]: What is the thinking behind, to the extent you can summarize it, behind the decision to not tax or value the property at zero for taxation purposes? We're talking about the co op's property, we're not talking about the individual properties, right? They're taxed, right? Correct. We're talking about property taxes, yeah.

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: Right, the town of Brattleboro taxes the coop's general property, and it's two three large parcels, one of which is 105 acres, the other two are less than 10 acres. Those are taxed at zero. Each individual mobile home is taxed at whatever its fair market value is. An additional amount is added to the fair market value to represent the leasehold interest in it. And in response to your question, the thinking is that that is the way condominiums are taxed. So it's similar to a condominium in that you own where you live, you pay a little extra for being a member of this common area, but the common area doesn't get taxed.

[Marc Mihaly (Chair)]: Is the theory or do you know that the net operating income is zero or something like that?

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: I would assume that the theory is that the whole purpose of the limited equity cooperative is to provide affordable housing, benefit lower income Vermonters, and is designed to not have huge rents and therefore a net operating balance of zero. Yes, As you say.

[Marc Mihaly (Chair)]: So the the individual lots are taxed on the value I mean, the individual houses, manufactured homes

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: taxed on their value.

[Marc Mihaly (Chair)]: Including the including their value the value of their the present value of their lease?

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: I believe that is what the town does. I've never really talked to them to the listers, but I believe that's the case. The individual homes do have a slightly higher tax than what I would think they would be worth if they were just considered as stand alone homes.

[Marc Mihaly (Chair)]: Are the do you you represent the coop. Right?

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: I do. Yes.

[Marc Mihaly (Chair)]: Is the coop at 501 C 3?

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: It is not. So Tri Park got founded back in 1989, and that was before my time. But my understanding is that the only business entity that was in existence that could be founded under was a Vermont for profit corporation. So it is a for profit corporation. It files its annual tax returns with the federal government under the five zero one(eight) or nine, the one that applies for homeowners associations. So it files its federal taxes as a homeowners association. And there are certain limits based on its income that it meets to be allowed to do that.

[Marc Mihaly (Chair)]: As opposed to?

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: As opposed to a regular for profit corporation.

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: Got it.

[Marc Mihaly (Chair)]: Is do you happen to know how Tri Park is listed with the secretary of state?

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: I believe you'd find it as a a regular for profit corporation. And, again, that's because it was formed so long ago. My understanding is that was the only choice it had.

[Marc Mihaly (Chair)]: Have you to your knowledge, have there been any grant application or any desire to seek grants that are not that it's not eligible for because it's not a nonprofit.

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: Yes. I think Dan Riddlehoover is on your witness list, would be able to testify to that more particularly, but there were grants that we were we were not able to receive because it was a for profit. Instead, other parties were set up, other nonprofits were set up, the grants were given to those other nonprofits, and then that money is basically being used by Tri Park for improvement projects that are pending.

[Marc Mihaly (Chair)]: Is the Tri Park infrastructure in need of rehabilitation placement?

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: Probably the roads are. The water and sewer system was re largely rebuilt in 2007, And the town has taken those over. My guess is that a lot that there are infrastructure needs. There's a bridge that is it crosses two streams. I think there's bridge work that needs to be done, and certainly the roads could be rebuilt.

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: Marc? Yes.

[Gayle Pezzo (Member)]: So my understanding also as far as the grants for Tri Park is because of the flooding.

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: Yes.

[Gayle Pezzo (Member)]: And one of Dan's issues was whatever grant money you were able to receive that that it became taxable. I think that's part of what Dan wants to speak about. Yeah. Another thing with the secretary of state's list. That's why in my bill, it talks about making everything, because they're all the same exact models, and they should be all considered nonprofit. The Secretary of State, when CDI and Rock tried to have it changed, they just said that's the way that it is. But we're talking about same exact models, and more than half of them are nonprofit, and then the others are for profit, which doesn't make any sense because you can get the grants. You just have to jump through a lot of hoops and explain exactly what the model is as a LEC manufactured home nonprofit for low to moderate income. So they're able to get the grants after they jump through a bunch of hoops. Now, when it has to do with grants, sometimes there's a timeframe. So taking up this time, you may lose the opportunity to you can be eligible and fill out all the grant forms and then you may lose it because of all the hoops you had to jump through. You didn't get to that deadline.

[Marc Mihaly (Chair)]: Sandy, any further any questions of Sandy or Sandy, anything any last remarks? Any questions of Sandy? Well, thank you, Sandy. We really appreciate your taking time for us Thank

[Gayle Pezzo (Member)]: you, Sandy. Thank you. Enjoy Florida.

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: Please move this bill through. It looks like it'll be very helpful for low income Vermonters. And I can tell you, I haven't worked with Tripar for years and years, anything can help this group that is on the edge, but yet is still proud and works hard for their community in the state of Vermont.

[Marc Mihaly (Chair)]: Thank you.

[Gayle Pezzo (Member)]: Thank you. So,

[Marc Mihaly (Chair)]: yes. Scaled birds.

[Emilie Krasnow (Ranking Member)]: They're like, Frapp! Manufacturers giving witness testimony. The

[Gayle Pezzo (Member)]: birds say they're coming now to give them their treat, they know they just sent it.

[Emilie Krasnow (Ranking Member)]: Oh, we're on the same schedule you've heard from that guy.

[Rachel McLeod (Eastrise Credit Union)]: Right. Alright,

[Marc Mihaly (Chair)]: so let's talk about tomorrow. Tomorrow at 09:30, we are supposed to be at Facto Home at 09:30. Facto Home's, unless you're in a car, for those of you who don't know, is about ten minutes from here, maybe fifteen at most. So the question is, who is willing to drive to provide car fullings? I can take three people. I know that Joe has offered to take three people in his truck, and I'm just wondering who else might be willing to drive.

[Joseph Parsons (Member)]: You don't wanna get in my truck if you're dressed well.

[Emilie Krasnow (Ranking Member)]: Oh. I

[Rachel McLeod (Eastrise Credit Union)]: can drive four people.

[Marc Mihaly (Chair)]: I just want to put it out there that I'm not going to go on the field trip.

[Emilie Krasnow (Ranking Member)]: I feel that's understandable.

[Marc Mihaly (Chair)]: Okay. What?

[Emilie Krasnow (Ranking Member)]: That's FaceTiming. Yes.

[Marc Mihaly (Chair)]: So we have three. Okay. Four is seven. Three is

[Emilie Krasnow (Ranking Member)]: 10. You can drive only two people? Three.

[Rachel McLeod (Eastrise Credit Union)]: What's three plus you?

[Marc Mihaly (Chair)]: Oh, plus me. That's four. Five.

[Emilie Krasnow (Ranking Member)]: That's nine. Two people are not going, that's all our committee.

[Marc Mihaly (Chair)]: Yeah.

[Rachel McLeod (Eastrise Credit Union)]: What's the accessible life with my leg?

[Marc Mihaly (Chair)]: It's just steps. Gayle said it's like

[Emilie Krasnow (Ranking Member)]: two, three steps up into Imagine

[Marc Mihaly (Chair)]: they're this high off the ground, so it's a couple of steps.

[Emilie Krasnow (Ranking Member)]: Alright, I'll make a game day decision.

[Gayle Pezzo (Member)]: It might be four steps, he may have the newer version

[Emilie Krasnow (Ranking Member)]: of Oh, it. It might might be

[Marc Mihaly (Chair)]: or four.

[Emilie Krasnow (Ranking Member)]: I might bring my cane. Bring your cane. We can all carry Emilie.

[Rachel McLeod (Eastrise Credit Union)]: My friends don't You're welcome

[Emilie Krasnow (Ranking Member)]: to come.

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: Thanks. I go there

[Jeremiah Ward (Cooperative Development Institute)]: once a

[Rachel McLeod (Eastrise Credit Union)]: week. How many steps?

[Marc Mihaly (Chair)]: Four. Oh, okay.

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: You don't have to go on any steps. More.

[Emilie Krasnow (Ranking Member)]: Do we need one more car? Because we only because now we're would we how many?

[Rachel McLeod (Eastrise Credit Union)]: Are Saudi and Elizabeth going?

[Emilie Krasnow (Ranking Member)]: Four. Eight. Oh, so now we have Yeah. We have more than enough. Okay. Perfect.

[Marc Mihaly (Chair)]: So why don't we really try to meet here around nine, and then we'll get to our cars or pull up our cars Okay. And then get there. They're expecting us at 09:30?

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: So we're

[Emilie Krasnow (Ranking Member)]: leaving at 09:15?

[Rachel McLeod (Eastrise Credit Union)]: Is that

[Marc Mihaly (Chair)]: work? We leave here at 09:15.

[Emilie Krasnow (Ranking Member)]: Fine for each one of them.

[Marc Mihaly (Chair)]: Yeah. It won't be it won't take long. I mean

[Emilie Krasnow (Ranking Member)]: Then, I guess, can we just be here at 09:30 and maybe No. 09:25. 09:15.

[Marc Mihaly (Chair)]: 09:15.

[Emilie Krasnow (Ranking Member)]: 09:15. I missed you. Did you

[Alexander “Sandy” Schreiber (Attorney, Phillips, Dunn, Schreiber & Carroll)]: wanna out the door.

[Emilie Krasnow (Ranking Member)]: You wanna meet here or in the coat room?

[Marc Mihaly (Chair)]: I think why don't we just all come here? Okay. And then can you email everybody and let them know we're gonna meet here? Send me

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: a meeting.

[Marc Mihaly (Chair)]: At at around nine. We're going to leave here at 09:15 and be there at 09:30. I think it'll take an hour there to walk through two or three, you know, a single wide, a double wide, etcetera. Won't take long. I went there and did it in fifteen minutes.

[Emilie Krasnow (Ranking Member)]: Oh, but this will be more expensive.

[Marc Mihaly (Chair)]: Or 20, and that even included shaking hands with one of the Facto brothers.

[Emilie Krasnow (Ranking Member)]: Wow.

[Marc Mihaly (Chair)]: Yeah. So then what we're gonna do is then we'll have lunch, and then they're gonna come back and testify along with Samantha Sheehan, who is, as you know, from the Vermont League of Cities and Towns. She'll testify about her view that's with the bill. We've also asked the secretary of state to come, and I'm not sure exactly how how elucidating that will be, but we'll find out. And we may want Cameron back here to ask him a question or two, but we'll see.

[Gayle Pezzo (Member)]: Marc, I have a question about

[Marc Mihaly (Chair)]: That's Samantha and the morning. The afternoon, and I'll get to your question, the afternoon is a series of introductions. Yes, Gayle.

[Gayle Pezzo (Member)]: Being that most of the manufactured home parks cooperatives, they're not, I mean, they're part of the town, but they don't receive any municipal services, and they pay taxes just like anybody else. What would be the value of Samantha?

[Marc Mihaly (Chair)]: The value of Samantha is to there is the zoning part of our bill, and, you know, if you want to cross examine her, feel free.

[Gayle Pezzo (Member)]: No. I don't wanna cross examine her. I just wanted to know what she would have to add.

[Emilie Krasnow (Ranking Member)]: Right. I I think we should maybe adjourn Yes. For the Well, Helen, and we should finish this.

[Marc Mihaly (Chair)]: So we're set. Anything any last thing that we should say while we're on the record? Great. Okay. So we will actually be at Facto Homes at 09:30 and anyone from the public who is watching this and wishes to be there is welcome because we have a quorum of the committee and it's a public meeting. Also so that that's our situation for tomorrow, and then we'll come back and have a bunch of bill introductions after lunch. So we

[Ed Fitzpatrick (Attorney, Bergeron, Paris & Fitzpatrick)]: can

[Marc Mihaly (Chair)]: go