Vermont Legislature SmartTranscripts:

[Rep. Charles Kimbell (Ranking Member, acting at opening)]: Yeah. Good morning. This is House Ways and Means Committee, and it's 03/11/2026. We're gonna start with the absence of chair Kornheiser. And so we're gonna hear on h seven fifty seven, act related to manufactured homes and limited equity cooperatives. Cameron

[Cameron Wood, Office of Legislative Counsel]: Wood. No technical issues to start out this time. Fingers crossed. See what happens. Good morning. For the record, Cameron Wood, office of legislative council. I'm going to walk through a proposed amendment to h seven fifty seven drafted as an amendment from this committee. Give me one second. I'll share my screen, and we'll get going. So what we have here is a draft amendment from this committee regarding seven fifty seven, an act related to manufactured homes and limited equity cooperatives. This is a bill that was in house general, came out of house general with a recommendation from that committee to amend the bill as introduced, came to this committee. So this amendment is drafted as a strike ball because there were a few changes kind of throughout and deletion of one section later on. So it was just easier to draft it as a strike ball as opposed to instances of amendments. So jumping right in, we have under section one, manufactured homes. This is the the same section that was in the the bill and the proposal of amendment coming out of the house general committee. So kind of moving through to h two, the first thing we have here, if you all recall the bill as it was recommended from house general, was making a slight tweak to the definition of permanently cited. This remains the same, so there was no change based on this proposed recommendation here. Permanently cited, the the language there on line five is just intended to clarify that when defining permanently cited, all of these subdivisions are required to be met. So it's one or more of the following. If that, more, you know, kind of clarification language remains the same as as it was proposed by house general. Moving into section two six zero four, real estate deeds. I'm gonna look at page three. It's kind of where I'm going to to start here. What this section does is in a and b, it's saying that current law. It's saying that if you purchase a mobile home from a mobile home dealer, some online 1617 there, if you purchase the mobile home from the mobile home dealer after July 2008 and it's financed as residential real estate, then it shall be conveyed via warranty deed. And if you all recall when we discussed this initially, there's a a separate section that says if the home is going to be permanently sited on land that the individual owns, it shall be financed as real estate. And if it's going on land that the individual does not own, so it could be going into a manufactured home park, for example, then it may be financed as residential real estate. It's not required. It's a permissive. So if it's not financed as real estate, what is it financed as? Generally speaking, it could be financed as just a, you know, kind of a personal property loan, could be financed under some sort of retail installment contract if you're purchasing it from the dealer, etcetera. So more personal property loan versus a a residential loan. So what this section says is if you're buying it from the dealer and you're financing it as residential real estate, it has to be conveyed via deed, and that's been the case since 2008. The subsection b is saying that if the owner is financing it or refinancing it as real estate or if the purchaser is financing the mobile home as real estate, then it shall be conveyed via deed. So if I own the mobile home or manufactured home that, you know, I bought many years ago via a bill of sale, and then I'm going to sell it to someone else, Maybe I'm selling it with the property. Maybe they're going to move it to their property in another town. If the purchaser is financing it as real estate, I have to convert that bill of sale that I have into a deed in order to convey it to that individual. So the reason I'm just kinda pausing here is because the the kinda current statutory structure is really going to the transfer how you transfer the manufactured home is really dependent on how it's being financed by the person purchasing that. If it's being financed as real estate, the statute is saying it has to be conveyed via a deed. And so the the proposal here is to keep that current statutory structure in place, where if it's being transferred or financed via real estate, it has to be transferred via a deed.

[Rep. Carolyn Branagan (Member)]: Mister chairman, mister Vice, can I ask a question?

[Rep. James Masland (Member)]: Representative Branagan. Cameron,

[Rep. Carolyn Branagan (Member)]: I don't understand why why the difference. Why what is the difference between these two titles of finance, these two Right. You know, kinds of finance, and why why are they important in this case? Right.

[Cameron Wood, Office of Legislative Counsel]: Probably a historical question that I may not be best to answer. At the end of the day, a manufactured home, they're previously mobile homes. Now they really are manufactured homes. I mean, that's what the federal term is used. And and as we've talked about later on in this in the bill as it came out of the house general committee and it's kept in here, there's some direction to our office to change throughout from mobile home to manufactured home. But, you know, initially called mobile home because they are mobile. You can move them. And so, you know, historically, they weren't financed in the same way that a stick built home is as a real estate mortgage because, you know, there's more risk to the financing lender because it's mobile and can be moved. And so that's my best articulation of why. Why are you treating them differently? Why have they been treated differently previously? Because that aspect. Because, historically, if you purchase it not as a real estate, you're not getting a d. You know, d, you know, historically is about transfer of land itself. And so if you're not purchasing it via a mortgage or real estate transaction, you're purchasing it via some sort of, you know, personal chattel property transaction. And because of that, it's not gonna come with a deed. It comes with a bill of sale, just like, you know, if you, you know, purchase your car, for example.

[Rep. Woodman Page (Member)]: We're gonna hear from

[Cameron Wood, Office of Legislative Counsel]: the Vermont Bankers Association a little bit about Okay. The options there. Yeah. And so and so the the the challenge that you're running into and, you know, my understanding, the challenge that the house general committee is trying to address and you all are are looking at is, you know, because of the nature of of this type of housing, you have historically you have these manufactured homes that don't have deeds. They have bills of sale. The owner may not be able to find that bill of sale, you know. And then now, as I see the statutory, you know, framework has been trying to shift in a direction of treating them more like, you know, stick build housing. And you all have determined in the past, if certain conditions are met, then we want to treat them that way, and we want to transfer them that way via deeds. And so that's where you've seen the statute say, you know, if it's going to be permanently sited on land that you own, we're not gonna treat it as if it's this, you know, movable property anymore. We're gonna treat it up as if it's as if it's a stick built home, and we're gonna require financial institutions to provide mortgages for that. And if we're going to do that, then we're gonna move more into the universe of stick built property, real estate, and we're gonna require transfers of those via deed. So you've kind of seen the statute gravitating in that direction over time.

[Rep. Carolyn Branagan (Member)]: I think there are a lot of these things used in so we're talking about what we call double wide phones. Right?

[Cameron Wood, Office of Legislative Counsel]: That is a a version of them. Yes, ma'am.

[Rep. Carolyn Branagan (Member)]: I think we use a lot of them on the Franklin County farm farm housing, inexpensive housing. Thank you. That's helpful.

[Rep. Charles Kimbell (Ranking Member, acting at opening)]: Representative Page.

[Rep. Woodman Page (Member)]: So if we're treating it as a regular home, a stick built home, and even though it's mobile, there would be certain requirements just like buying a house. You would do a title search, I would assume, to see whether you would have clear, you know, title to to this mobile structure if you purchased it.

[Cameron Wood, Office of Legislative Counsel]: Right. I believe so. A question probably best for your financial institutions and and others that are in the room.

[Rep. Woodman Page (Member)]: Yeah. If it wasn't permanently placed, I mean, it would be difficult, I would think, to to perhaps do a kind of search.

[Cameron Wood, Office of Legislative Counsel]: And and and I don't you know, I I I wanna be careful. I don't wanna give the wrong impression. I don't think that I am, but just in case, you know, most of these are permanently cited. I mean, they're not they're not moving, you know, once they've been purchased, once they've been, you know, placed. Just keep in mind, you know, practically and legally, they can move. So, you know, as as, again, as I've seen kind of the the current statutory framework, there is this shift of if they're being permanently cited, if they're being financed as real estate, then let's treat them as we do all other homes in Vermont, and let's transfer them via and move in that direction. I just the the questions of, well, why do some of them have bills of sale? Why do we not require every financing via real estate? Why are we allowing there to be financing under kind of a personal property or a chattel property financing structure? It's because some of them do move. You know? Someone could come into the state of Vermont, purchase a mobile home from a manufactured home from a manufactured home dealer, and then move it out of state. And so you don't wanna treat that as the same way you're treating other, you know, landed property in the state. So there are unique circumstances that kind of dictate or should have a separate type of treatment. If it's on leased land, it's sometimes different, but they may own the structure but not own the land underneath even though it's permanently fixed, and that's a different structure that has to be financed. Yeah. I think that's Again, that doesn't mean it Oh, sorry. Sorry. That doesn't mean it can't be financed real It's just not mandated by statute that it'd be financed as real estate. Representative Masland.

[Rep. James Masland (Member)]: Yeah. Thank you, mister chair. When the bill was presented, I can't remember who was, or someone else from that committee. It was pointed out that that in the bill, you could, it seems unusual to me. You could sell one of these things with real estate. You could then transfer back to a public certain provisions as a, double sale. You could you could go back and forth. And I it wasn't I asked the question, but I was asking it to the wrong person in this committee room. Why why go back and forth? And I sat with rep Mahali in the cafeteria a day or two after, and he he acknowledged that it was unusual. But what was always pointing out was that the the committee was trying to do two things simultaneously, I think, successfully. One is to provide as much flexibility as possible for owners, transferees, you know, da da, but also create a statutory framework with which I would describe as clean. We can understand that it makes sense. Is that I convey what I'm trying to say? So so yeah. Okay. Fine. Initially, I was hesitant, but I'd say, okay. Good to go. This makes sense.

[Cameron Wood, Office of Legislative Counsel]: Yes. Yes, sir. Okay. Jumping back in. As I mentioned in this section so there there are there are separate sections that are not in the bill because there's no there's no amendments, and and this is the same coming out of the the house general committee. When you look at the chapter that governs the transfer of ownership of manufactured homes, there is a section that talks about the bill of sale, what the bill of sale needs to include if you're transferring it via bill of sale. As I mentioned, there's a separate section that talks about if you're purchasing it and it's going on land that you own, shall we finance as real estate. If it's not on land you own, maybe finance as real estate, like I said. Just kinda context to bringing you back to this amendment on page two. Because as I said, the a and the b here, the current statutory framework is if it's being financed as real estate, it has to be conveyed via deed. And so the rest of this section identifies what those deeds are. And so one of the amendments here on line one was a clarifying amendment that was in the house general recommendation as being kept here. So it's owner of a manufactured home shall upon financing or refinancing or selling that has been financed as real estate or will be so financed by the grantee. So just kind of, some recommended, you know, statutory clarification there. Has to issue to the grantee either a warranty deed or a quick claim deed drafted and substantially the form provided in subsection c or d. The amendments in these, subsections are really just some very minor statutory cleanup. C is the warranty deed. D is the quick claim deed. So they're adding language in there. This is keeping these kind of some of these cleanup language, that was being proposed by the the house general committee. One thing that is a little different in this amendment versus what was proposed by the house general committee is you are requiring in this amendment that the deeds themselves, if they're in substantially the form that's outlined in the section, then these legal consequences occur. And if you all recall, we had that conversation when I was initially doing the walk through of the bill. It doesn't require that the deed be in that form. It's just saying if it's substantially in that form, then here are the legal consequences that occur because of that.

[Rep. Rebecca Holcombe (Member)]: Thank you. I really appreciate the work on this, and I'm a little thick. So I'm hoping you can take me through one more time. I think what I'm confused by is that we're calling these mobile phones. And to me, what they are is off-site construction. And I don't know why we're calling this a mobile home warranty deed, not a manufactured home or an off-site construction home deed. Because my favorite thing I actually think the reason we don't give them deeds is kind of maybe historical discrimination against more affordable housing. And if these are homes, what unites them is the home. And it's the mobility. I mean, we all, in all of our towns, I'm sure, have homes that were stick built that were moved. I know I do. So I'm not sure. Yeah. I and I know it's easier

[Rep. Carolyn Branagan (Member)]: to move a home that

[Rep. Rebecca Holcombe (Member)]: is built off-site and designed to be moved, but it seems like it's a home. Right. So why are we calling it a mobile home? Because the primary intent isn't to be mobile. The primary intent is to provide a home. It just happens to be more affordable than something built with bricks for two hundred years ago when we didn't have manufacturing off-site construction, which I think is gonna be our future.

[Cameron Wood, Office of Legislative Counsel]: A 100% agreed. And I think it was mentioned, I don't remember, who it may have been the chair mentioned specifically that. You you can take a stick built home, and you can move them. So 100% agreed. The there is a section later on, and let me just jump to it. It was a proposal from the house general committee, and it remains here Okay. Giving our office the ability to replace mobile home with manufactured home. They were initially called mobile, but in the seventies, you know, the federal government took a lot of regulation and oversight over the the the manufacturing process of these, and they're referred to as manufactured homes at the federal level. And so they really should be referred to as manufactured here. One thing that's, in discussion with my legislative council counterparts, we felt that it was best to just continue to use mobile home currently in the language in the amendments because we have this conforming revision authority. We want to make those changes throughout at once as opposed to making some of them piecemeal. I've been trying to do my best to use the the correct terminology of manufactured homes. Sometimes I'd say mobile home just because that's what the language on the page says. But

[Rep. Rebecca Holcombe (Member)]: So but here, we're passing a warranty deed that we know is gonna have to be revised within a year, I guess, is my the language of it is, I guess, in my question. So if we already know this, where we're headed, why would we make those, and then just let the rest of the conforming changes catch up? Yeah.

[Cameron Wood, Office of Legislative Counsel]: In oh, we can if that's what you all would like to do. My my feedback to the sponsors of the bill and to the the previous committee was there would be a lot of administrative and technical amendments if we did that. It's going to make your bill extensively longer, and then you run into a situation where for a period of time, at least, you could have even in the same section, you could have manufactured home in this location and mobile home in the next section. And so our recommendation as an office was just leave it as it is for now. That way, when we go in and do those statutory revisions, we can do, a thorough top to bottom. Can

[Rep. Rebecca Holcombe (Member)]: I ask one follow-up question? Because I and I I don't know. This is not an area of my expertise. But my understanding, part of the challenge is ownership, and part of it is insurance. And is the mobile is having that sort of residually there? Is that gonna impair the ability of these folks to get appropriate insurance for their homes?

[Cameron Wood, Office of Legislative Counsel]: That is a great question that I do not I do not know the answer to either. And it it

[Rep. Rebecca Holcombe (Member)]: well, it's him now.

[Cameron Wood, Office of Legislative Counsel]: It needs and I was gonna say, may be best you know, I know you have some financial institutions coming in. They may be able to answer that as part of their their process. That's that's lending. Thank you.

[Rep. James Masland (Member)]: Okay. Yep.

[Cameron Wood, Office of Legislative Counsel]: Okay. So back to these deeds. Again, this amendment is keeping the current structure, which is more, designed to default to how is the individual who's purchasing the home, what is their financing mechanism of doing so. If it's going to be via deed, it has to be via a warranty or a quick claim deed. And this amendment is keeping the requirement that it'd be in substantially the form that's provided. So we have the form here. One, small change that was pointed out, by the committee was this technical, change here. The forms currently say wife husbands. We've changed that to to spouse. That was one of the recommendations. And so then we get to the bottom of this section, and here's where I will pause and jump back to, Rutland, your your point that you were bringing up. There was a provision that did allow an individual to sell a manufactured home via a bill of sale or a deed regardless of how it had been financed previously. So a little bit to the flexibility conversation that you were having with chair Mahoney. Current statute says if it's transferred via a deed, you can't go back and transfer it via bill of sale. If it if it gets transferred or is given a deed, then that's how it needs to be transferred moving forward. And so this is really a policy decision about how you want to treat these types of homes and whether you want that type of flexibility to allow people to go back and forth via deeds or bill of sale. You know, I would comment just, you know, kind of from a statutory construction and from, you know, my perspective. I can understand that flexibility may be helpful, but it comes with its own challenges. If you're wanting to have kind of a consistent documentation of transfer of ownership, I could see it becoming very challenging if you're going back and forth via deeds versus bill of sale, and and it kind of goes a little bit against the grain of the current statutory framework in the direction the current statute is going. So there was a lot of testimony in the house general committee, though, about the confusing nature of this. When do you transfer it via bill of sale? When do you transfer it via deed? But it's a it's a policy decision for you all. This amendment would keep the current structure in place, which is more of a default for deeds if it's being financed as a real estate mortgage. Then we get into the section two around limited equity cooperatives. Yeah. Oh, yes, sir. Can you just speak to checking the pension wife to spouse and if they're a legal just mentioned spouse as opposed to partner or etcetera, etcetera. I I asked one of my my counterparts if spouse was the the correct term. I said it's it's a model form, so I didn't I didn't I was concerned about, you know, listing out, you know, spouse, civil union partner, you know, and and getting potentially lengthy just because it's a model form in the statute. The the form doesn't have to say spouse, for example, and, she recommended that spouse legally would be kind of all encompassing of the the legal partnerships that we have in the state. So, okay. Section two, limited equity cooperatives, moving to the top of page seven and actually, excuse me, moving to to page eight. There was minimal change in this amendment to to this piece. If you all remember when we did the initial conversation about this, you have, in the corporation's title, you have a a corporation type for cooperative housing. Within that, you have limited equity cooperatives, which are a housing corporation designed to be affordable to individuals of low and moderate income. And there are certain limitations on those limited equity cooperatives. And what this language here in sub eight is about for a limited equity manufactured home community, about making a change regarding the leasing of those units. There's no change in that language from what was proposed by the house general committee. So I'm gonna move us to the sub v here, bottom of page eight. This b one has not changed. This is adding in language to say that for a manufactured home community that's organized as a limited equity cooperative for state funding and grants purposes. It should be treated as if it were a state nonprofit corporation for a public purpose. This was intended to allow those entities easier access to state funds and and grants more for you know, think about, like, infrastructure, you know, projects, etcetera. And what the addition so the change is just adding this subdivision two on the top of page nine to state that nothing in the subsection shall be interpreted to impact or alter the tax treatment of a manufactured home community organized in as an LEC. But there was just discussion, if you remember, about, well, state funding, does that somehow impact the tax treatment of these entities? And you wanted to clarify, no. No changes there. So that's why we have the substitute.

[Rep. William Canfield (Vice Chair, Acting Chair)]: At a risk of calling out the tax department, I know that you asked them about this language. I don't know if you heard back yet or if we should check back.

[Rep. James Masland (Member)]: I have not. Okay. Thanks. Okay. But

[Rep. William Canfield (Vice Chair, Acting Chair)]: there's a lot of email that they have. Okay. Great. I will check-in with them about that.

[Rep. Woodman Page (Member)]: Thank you.

[Cameron Wood, Office of Legislative Counsel]: As I sat in the chair, I had not I did send it to them yesterday. So no no yeah.

[Rep. William Canfield (Vice Chair, Acting Chair)]: I I really don't like I'm not trying to call up the. I was just wondering if we I need to check-in. Okay.

[Cameron Wood, Office of Legislative Counsel]: Okay. So moving to page nine, I will say that there's there's no other amendments to the remaining sections of the bill. I'll just mention in section four, if you all recall, this is about municipal zoning, and there was just some clarification language being added to the subdivision b to say that, you know, municipal bylaws cannot exclude these homes, manufactured homes, modular homes, off-site construction homes, etcetera, from and just clarifying that it's any districts that allow year round residential development in the municipality, so that hasn't changed as it was proposed by the house general committee. And then when we get to page 10, it really transitions the bill over into the the sales tax versus property transfer tax, which is more John's area. So it may be I'll pause there in case you have any questions on the sections that I've walked through. And, madam chair, if you'd like, I can turn it over to John if that if that makes sense.

[Rep. Rebecca Holcombe (Member)]: Representative, can you just go back one more time on page eight

[Cameron Wood, Office of Legislative Counsel]: Yes, ma'am.

[Rep. Rebecca Holcombe (Member)]: To the mobile home park organizes a limited equity cooperative being eligible for the purposes of state funding grants as if it were incorporated as a nonprofit? Yes, ma'am. Does that extend is that to parallel other, I mean, for example, a state funded permanently affordable village that has shared land, is this designed to bring those communities in line by other existing communities? Current is this what is the standard of care for BHCb funded projects?

[Cameron Wood, Office of Legislative Counsel]: To to the second point, not to my knowledge, The the committee discussed if you all remember back when we had our initial conversation, you have these cooperative housing arrangements. And the they're not, by nature, automatically registered as a nonprofit with the secretary of state's office because it's just a business organization type. And when you look at the limited equity cooperative and when you look at the current statutory structure of it, there are limitations like this Subdivision C here or excuse me, Subdivision 6 that limits what the kind of what the the equity in the corporation can be used for if it ever dissolves. So this sub six is if the limited equity cooperative dissolves any assets that remain after paying off its debts and paying the distribution to its members that's required can only be transferred to another nonprofit. So there's limitations on its use or its its the value of what it owns, but they're not, by default, treated as nonprofits. And there's some historical issue at the secretary of state's office where some of them are listed as nonprofits, and that appears to, from the the testimony from the secretary of state's office, be more of just a a historical organization issue with their how they, you know, organize these business entities when they register. So some of them are designated as nonprofits in the secretary of state, some are not. And there was conversation about if the design, the statutory design of them is to serve low and moderate income individuals, And if you have these sort of statutory limitations on, you know, what the the the the property that the entities own, what they're able to do with it afterwards, similar to what you have with nonprofits. So we're kind of treating them as nonprofits. We're treating them as designed to serve low and moderate income people. It can be very difficult for some of them to access certain state grants and funds because because they're not registered as nonprofits, all of them. They're not, by default, treated that way. So the committee asked, and we worked with the I worked with the committee to try to come up with this language to signal for these entities, the manufactured home communities that are limited equity block groups when they're going to access certain state funds or state grant opportunities that they can point to this to say, hey. We are really designed like a nonprofit with a public purpose to try to alleviate them having them, the entity, from having to jump through additional hoops or different burdens to access those funds. So that's the intent behind the or the design behind the language.

[Rep. Rebecca Holcombe (Member)]: So I I 100% support that intent, just to be really clear. My question is a little bit different. I mean, I keep and it has to do with this cascading revision of language, because we're not actually talking about mobile phones. We're talking about off-site development, manufactured homes that are people's homes. Right? Right. And we may see more communities or villages organized with manufactured homes or off-site buildings do, because it is more affordable. But there are also many communities that are currently supposed to be permanently affordable homes. The value or the resale value of their properties is similarly capped, but they aren't considered mobile parks. You know, I'm I'm just I'm wondering why we aren't comprehensive. If the intent

[Cameron Wood, Office of Legislative Counsel]: Yes, ma'am.

[Rep. Rebecca Holcombe (Member)]: Is low and moderate income households, why isn't that the criteria as opposed to a manufactured

[Cameron Wood, Office of Legislative Counsel]: Yes, ma'am. Is it I

[Rep. William Canfield (Vice Chair, Acting Chair)]: mean, you're welcome to answer, Cam, but I feel like that might be a better question for the house general committee.

[Cameron Wood, Office of Legislative Counsel]: I I was just gonna answer a very small piece of it and then echo that. Yes, ma'am. Exactly. I just wanted to agree with how you're reviewing the distinction. It this only would apply it it doesn't even apply to all limited equity cooperatives. It's just the limited equity cooperatives that are manufactured home communities. And so, yeah, I think if you were wanting to have more of a comprehensive approach for these types of entities, that is a policy decision for you all. I'm just acknowledging your your analysis of it. It is limited in that sense. And as to why not be broader, that's a question that I would defer to the the committee itself. I will I will follow-up. I just feel like this is really important work, and I think it's setting up a framework that is going to become used more broadly, probably. And so I guess I'll I'll follow-up with the community.

[Rep. William Canfield (Vice Chair, Acting Chair)]: Yeah. I really appreciate that, and I agree. I think it's moving we're making so like, a decent number of amendments to this based on tax stuff. And this is and so if it was a friendly amendment with that general committee, I'm happy to work on it. Yeah.

[Rep. Rebecca Holcombe (Member)]: I know who to talk to.

[Rep. William Canfield (Vice Chair, Acting Chair)]: Yeah. Suzanne Branagan.

[Rep. Carolyn Branagan (Member)]: And then back to you up a little bit, I just wanna clarify my my own mind. We do have some homes that are built they call them manufactured housing, but the frame of the house is built away at a factory. And they come in on a big 18 wheeler and it's really impressive because they're assembled in, like, one day. Right. And but I think most of them are built on property owned by who is still living in

[Cameron Wood, Office of Legislative Counsel]: that house for

[Chris D’Elia, President, Vermont Bankers Association]: the person.

[Rep. Carolyn Branagan (Member)]: So are we saying earlier in the bill here, because that's land owned by the resident of the house, that they're they're treated like that, like like a stick built home. And then the other double blind that I referred to a while ago that are, you know, who are moved in one piece, they're different, and that's what we are addressing in the bill mainly, but not the first kind of housing I talked about. But some of those houses are beautiful. I mean, four or five bedrooms, several bathrooms. I mean, they're huge. Okay.

[Rep. Rebecca Holcombe (Member)]: Yeah. That's actually probably why I

[Rep. Carolyn Branagan (Member)]: was asking the questions here because these could be very high end communities. Yes. They could. Yeah.

[Cameron Wood, Office of Legislative Counsel]: It is But not what we're seeing from

[Rep. Rebecca Holcombe (Member)]: the land that

[Rep. Carolyn Branagan (Member)]: makes a difference.

[Cameron Wood, Office of Legislative Counsel]: It's a question really about just terminology. And and so, you know, you have manufactured home, modular home, prefabbed home, off-site constructed home. You know, I've heard all of these different, you know, kind of words thrown around. I don't know that there is a universal I don't even know that there is a specific statutory definition of what an off-site constructed home is because an off-site constructed home could be what is historically a mobile home. It is built off-site, but it could also be these more, you know, modular homes that I think you're referring to, as you mentioned, kind of brought in the 18 wheeler, and then the pieces are constructed on-site. This bill is only impacting what has historically been a mobile home. And so that's why I've just pulled up this definition because both the the initial section about the transfer of the ownership via bill of sale, via deed, is it financed via real estate, etcetera, all of that is tied back to this definition of a mobile home, which, as I mentioned, is at the federal level, they're now called manufactured homes, which is why we've asked for that revision of I shouldn't say we've asked. You've included that revision authority to have us transfer the name of mobile home to manufactured homes. When I'm legally referring to a manufactured home, it is the historical built on a chassis meeting certain definitions under Fed regulations. So the more mobile home historically, that's what I'm referring to about manufacture. And it may be worth the conversation, you know, for you all as a legislative body to begin to distinguish those things in statute so we all know what we're talking about when we say manufactured. Are we just talking about the historical mobile homes? Are we talking about all off-site constructed housing? So so, anyway, I'm just saying that I know there's a a difference in terminology that's kinda used, you know, somewhat casually. This bill is only dealing with historically mobile homes.

[Rep. William Canfield (Vice Chair, Acting Chair)]: Yeah. And then I want us to make sure we have time for our I

[Chris D’Elia, President, Vermont Bankers Association]: mean, this may not be for you again, but I I'll go back to you know, as a lister in our Microsoft program, we actually have a mobile home category. Right. That's, you know, length, width, with skirting, you name it. Is is there any implications for for that process or that category to

[Cameron Wood, Office of Legislative Counsel]: be concerned about? Or I don't think so. Not in the bill. No, sir. No. No. No. It you know, what it would do is if this were to pass in the amendment that's proposed in its current form, it gives us the statutory revision to change it. So in statute, you might see changes from mobile to manufactured, in which case, you know, it it may be appropriate for that software to be updated to reflect that change, but the statute wouldn't mandate it in that sense.

[Rep. Mark Higley (Member)]: K. Thanks. Yes.

[Rep. James Masland (Member)]: I guess, Chris.

[Rep. William Canfield (Vice Chair, Acting Chair)]: He didn't make any changes to John's section, so he's just gonna stay there in case we have questions.

[Cameron Wood, Office of Legislative Counsel]: Except the last session. Oh.

[Rep. Woodman Page (Member)]: There's 12. Yeah.

[Cameron Wood, Office of Legislative Counsel]: Yeah. Do you

[Rep. James Masland (Member)]: want me to

[Rep. Carolyn Branagan (Member)]: Is that the study?

[Cameron Wood, Office of Legislative Counsel]: Yes, ma'am.

[Rep. William Canfield (Vice Chair, Acting Chair)]: Alright. Will you just Yeah. Do. Feel like I could explain that.

[Rep. James Masland (Member)]: Alright. Okay. You can explain it. I don't know

[Rep. William Canfield (Vice Chair, Acting Chair)]: if people change chairs for that. Give me one second. While you're pulling it up, I'll just say so there was a study in here about how the these cooperatives are appraised. And since we have a whole other bill that's focused on consistent appraisal, working on language to move that to move a sort of more directed portion of that into the regional assessment district bill instead of having it here. So we're not creating a whole new project for property evaluation or review, but in fact, asking them to do this as part of all the other work they're doing.

[Cameron Wood, Office of Legislative Counsel]: I think that's a a great summation as opposed to me waiting to kinda kinda pull it up. There was so what I will say is, you know, in this amendment, you do add that b two that I mentioned where it's saying that by treating manufactured home community limited equity cooperatives as if they're a nonprofit for a public purpose, you're not, you know, you're not intending to alter the tax treatments. There was concern in the house general committee about how limited equity cooperative manufactured communities are being appraised and concerned about the consistency of their appraisal throughout the state. So there was a report from the tax department to investigate that and come back with you come back to you all with with information. And as the the chair mentioned, that report itself has been removed from the the amendment with intention of moving some pieces of that elsewhere.

[Rep. Charles Kimbell (Ranking Member, acting at opening)]: Where does that show up here, Kim?

[Cameron Wood, Office of Legislative Counsel]: It is it's not in the amendment because it's the the section was struck. I was trying to am trying to, pull up the bill that came out of house general so I could reflect that quickly. Give me one second, and I will be able to pull it up. Well, we'll live in a different vehicle. A mobile vehicle.

[Rep. William Canfield (Vice Chair, Acting Chair)]: There are so many opportunities.

[Chris D’Elia, President, Vermont Bankers Association]: Oh, I think. Apologize for opening.

[Rep. James Masland (Member)]: Okay. Yeah.

[Cameron Wood, Office of Legislative Counsel]: This is the report that was in the recommended amendment from the house general and housing committee. So on or before November 15, tax department shall submit the report looking at the one two three. They're on lines through thirteen. Different appraisal methods across the state, if there are any, an examination of any jurisdictions for differences in approach. And then I think the the key piece is the sub three recommendations for ensuring consistent and appropriate appraisal, taking into consideration the limitations under 11 VSA fifteen ninety eight. So what the fifteen ninety eight is, that's the limitation I mentioned earlier in the section where the limited equity cooperative, if it dissolves, it can't you know, it has to transfer any of its remaining assets to another nonprofit or to another limited equity cooperative. So kind of, you know, limiting the value of the entity if it ever were to transfer ownership. And so there was concern and discussion in the committee about these entities being somewhat appraised and treated differently throughout the state based on those limitations. And so that's where the the information here came from to have this information come back to you all to make a better informed decision about whether there needs to be changes in statute regarding that. And so this is the piece that was just mister vice chair, to your question, it was just removed, and so with intention of of having it live elsewhere.

[Rep. James Masland (Member)]: Thanks. You're welcome. So

[Rep. William Canfield (Vice Chair, Acting Chair)]: I know that one of the real sort of core focuses of Charles General Committee was to make sure that there's enough that they are enabling the purchase of these phones as much as like, to the greatest extent possible. And since we made some changes, we're making some changes for the tax treatment, wanted to make sure that we are not making it harder to finance any of this. So we ask two folks from lending institutions to come join us. Rachel McLeod? Did I get that? Yes. Great. Thanks for joining us.

[Cameron Wood, Office of Legislative Counsel]: Everyone.

[Rachel McLeod]: I'm Rachel McLeod. I work with East Drives Credit Union. I'm in the mortgage department. I've been there for over twenty years. And gosh, where to begin? We finance manufactured homes on owned land, also on leased land and, you know, parks cooperatives. We financed them all as real estate. When With deeds. Yeah. Yes. With deeds. Probably maybe a little backstory in terms of why we landed on real estate for well, and actually, when I think of this bill, I think of the ones in parks and co ops, right, because those seem to be the most challenging to finance. We kind of went through a journey the last couple of years in that. I worked for New England Federal Credit Union that recently merged with Vermont State Employees Credit Union. And Vermont State Employees Credit Union has been financing manufactured homes and parks and co ops for quite some time. When we merged, we wanted to continue that. And in looking at the existing process, they were financing them as personal property. Our mortgage department, we're used to doing mortgages, right, for the most part, and we have processes in place regardless of the type of home or product. And so we started digging into how could we also treat these as real estate. And there's a variety of reasons why that felt like a goal for us. You know, our individual journey was just, you know, for instance, personal property loans. We had a mortgage loan origination software and document provider that didn't really support personal property loans. There's TLA RESPA guidelines, federal guidelines we have to abide by. And they kind of speak to I don't know. You probably you may or may not be familiar, but there's a loan estimate. There's a closing disclosure. There's these important disclosures that a mortgage lender has to disclose that TILIRESPA more or less says are not appropriate for chattel loans. And so it was going back to using disclosures pre-twenty fifteen called the GFE or the good faith estimate, the HUD, the Till, the truth in lending disclosure, that I personally knew how to do because I've been in mortgages for years, but most of our staff had never touched those. So just between those considerations, we started looking toward a way that we could do them as real estate. You know, many challenges, including we found a lot of these homebuyers were coming in the door with their purchase and sales agreement and a bill of sale, and we were saying we'd have to redirect and say, actually, we need a warranty deed. And so if I go back to the February 5 version of this proposed bill, we were happy with it in that it makes it it would have made it possible to finance them, whether they were conveyed via bill of sale or warranty deed. Before this proposed bill even came about, the current statute says if you're financing them as real estate, you have to have the warranty deed. And, again, a lot of these sellers were offering up a bill of sale. So that's that's been tricky. And, you know, on the buyer side, as a mortgage lender, we're not talking to the seller. Right? There has to be that space in between. So redirecting, it's, you know, getting your realtors and your attorneys together to have that discussion of Eastrise only finances fees as warrant or as real estate. And then I guess the other thing is, you know, we found that a lot of our attorneys didn't know the the warranty deed, the mobile home warranty deed model form existed. Nobody's really using it in my experience. And so while, you know, it's not bad to have it out there, I liked how we made the or they made the change to make it a may use. Most sellers, sellers' attorneys, stakeholders in the transaction are just using a standard warranty deed, the same warranty deed you would for any transaction. I think another caveat of that mobile home warranty deed is that it has a place for the landlord to sign off on it. And chasing down a landlord just before closing is difficult and can delay closings. And if you think about leased land, there is usually a lease in place. So and that landlord's not usually signing the lease until closer to closing anyway. That's almost like their approval of of that borrower, that that that renter. And then just we as a lender, and I think a lot of lenders, are having landlord earlier in the loan process sign kind of like a park approval form. So they're they're signing off and giving approval anyway for this transaction to happen. And then kind of fast forward. So the bill of sale conversion, you know, when we started doing these as real estate, we would have a refinance come in the door. And, technically, if they financed with a bill of sale, we had to convert it to a warranty to be able to go forward with the refinance. Right? And it's just that was an interesting journey in that we had we have legal counsel that's helped us all the way through all of this, and town clerks had no idea what a bill of sale conversion was. Like, many of them had never even dealt with it before. So then I guess the other thing is is when we were working on this process and rolling it out, we have about 45 attorneys statewide that we work with on our approved attorney list. And a lot of them didn't weren't aware of the bill of sale conversion either. So I guess we're just you know, if nobody's doing it I know that's not the right answer to stop doing it just because nobody's doing it. But You're not. Yeah. You know, if we were hoping there could be a way to to allow it to be interchangeable, that you can use a bill of sale or a warranty deed to finance these as real estate or personal property and then not have to worry about the bill of sale conversion requirement. I think the other concern with that too is if East France finances them as real estate, down the road, they want to refinance with another lender who might have better terms, whatever, and that lender only does them as personal property, you can't convert back can't go backwards to a bill of sale. So that could be a negative impact on that borrower as well.

[Rep. James Masland (Member)]: Can I

[Rep. William Canfield (Vice Chair, Acting Chair)]: ask your question about that? Yeah. So, basically, like, everything we've been doing in the tax code around property the last few years has been to create consistency when possible because there is so much inconsistency. And a lot of folks at the municipal level don't know necessarily, like, aren't speaking the same language as someone at the next town over. Yeah. And that creates a lot of unfairness, right, from like, for Vermonters who are paying their taxes. And when we look at favorable like, we wanna create a favorable sales tax or property transfer tax. Right? In order to do that, we wanna have consistent taxation of all of these properties. It's very weird, my technical term, to apply a property transfer tax to something that is not real property. Right? Mhmm. And so, like, if we're going to put exceptions in this, we wanna find as narrow a path to those exceptions as possible while still not interfering in financing. Right? Like, the reason that we're not just entirely moving to deeds is because of financing.

[Rachel McLeod]: Could your definition, though, be the fact that they're permanently cited? Like, could that be where the focus is? So, I mean, we, as a lender, are making sure they're permanently cited because we also have to if we're treating it as real estate, we're trying to meet the guidelines that say it only applies to you to permanently cite it. That's where we kind of picked apart that definition of the permanently cited. We were like, alright. One or all of these can apply. Mhmm. And that makes us able to finance as real estate as well. That was another consideration.

[Rep. James Masland (Member)]: Mhmm. That's helpful.

[Rep. Rebecca Holcombe (Member)]: It's a thought. No.

[Rep. William Canfield (Vice Chair, Acting Chair)]: No. No. It's a really helpful thought. And we're, like, trying to find a path forward on this to, like, create both consistency and opportunity, and that's really that's really hard. That's why the build Yeah. Was created. Right? Yeah.

[Rachel McLeod]: And I think just from my perspective, while we do we treat them as real estate, we also know there's many lenders out there doing them as personal property. And so where I get a little concerned is just we don't wanna close the options by any means. You know, for us, it's a personal or a portfolio product. We keep these in house, and we have a balance sheet to uphold. So while if you ask me, I would do these loans all day every day. We don't wanna say no to anyone, but, you know, it's a popular loan product. And so that you know, we can only finance so many of them in a year. We have to budget. So that's a thought too.

[Cameron Wood, Office of Legislative Counsel]: Yep.

[Rep. James Masland (Member)]: Thank you. Could you say a little bit more about a portfolio product? I mean, I understand what you meant, but I'd like to hear you in your language. What why So way you do that.

[Rachel McLeod]: We sell loans on the secondary market. So to Freddie Mac, Fannie Mae. There's Federal Home Loan Bank of Boston. So we have different investors that we sell to. At this point, we are unable to sell them to any of them. The the ones in parks are cooperatives.

[Rep. James Masland (Member)]: Right.

[Rachel McLeod]: There is a pilot program out there with Fannie Mae, where they're trying to work with states to finance them only in cooperatives, there are a lot of challenges to work through there, and we haven't been able to get through those challenges.

[Rep. James Masland (Member)]: So Follow-up question.

[Cameron Wood, Office of Legislative Counsel]: That's why I'm going

[Rep. James Masland (Member)]: too far.

[Rep. Carolyn Branagan (Member)]: We can just back up. No.

[Rep. William Canfield (Vice Chair, Acting Chair)]: This is this is

[Rep. James Masland (Member)]: Oh, and this makes sense. It opens a different window into your how you you guys work. And I appreciate your efforts to trying to, I guess, could say thread a needle or something to that effect to make more options available for people with such drawings, should we say. And I don't know if this is a question or what, but I'm I'm just making a statement. I appreciate that this is a new window for us, at least for me anyway, trying to figure out how you guys work. And what you're saying is consistent with the conversation that I had with with a colleague several days ago on trying to create flexibility for for sell owners of sellers. And I appreciate understanding a little more of that. That's all. Thank you.

[Rep. William Canfield (Vice Chair, Acting Chair)]: No problem. I I might have interrupted your testimony. I don't know if there's more you wanted to say.

[Rachel McLeod]: I don't think so. Happy to answer questions.

[Rep. Carolyn Branagan (Member)]: And that's all the questions.

[Cameron Wood, Office of Legislative Counsel]: Yeah. We do have a section on the bill. There was a section on the bill about describing this person permanently cited.

[Chris D’Elia, President, Vermont Bankers Association]: Mhmm. One or more used to

[Cameron Wood, Office of Legislative Counsel]: say just include, but stress trying to be more, I guess, expressive as saying one or more of the following. It's been set up on blocks or otherwise stabilized. Mobile homes have been connecting utilities. Skirting's been installed. Wheeler axle's been removed, and the mobile hole's been situated in a place that makes removal unlikely. So think about that. Is that fulfilling your need for what permanently sited means, or are you saying that permanently sited should be the determinant for a warranty deed for the sale?

[Rachel McLeod]: We so I guess there's there's even many considerations surrounding that. We very much wanted to finance these as real estate for some of the challenges for the reasons I mentioned before. And so in picking apart that section, we also knew that a lot of times in parks and cooperatives I think the newer homes you tend to see placed on a concrete pad and all the tie downs and the wheels and hitch might be removed, things like that. But our experience had been a lot of them don't have wheels hitch removed, the tie downs, that sort of thing. And so we decided going into it, it was one of those things where we're like, are we gonna finance these? Are we gonna finance these? Right? We don't wanna deny everyone that comes through because of that. So we looked at that that requirement and said, what's the minimum we can accept to still consider these personal personal or real estate Yep. Permanently sited and took it from there. Now this only applies to our portfolio product. Right? So if it's a manufactured home on owned land, in a perfect world, we're selling those on the secondary market, and they have much stricter guidelines. But typically, on owned land, they do kind of have all those parameters in place, you know, the wheels and hitch remove, that sort of thing. So

[Rep. William Canfield (Vice Chair, Acting Chair)]: I heard your answer, and I heard your question. And I'm I answer it. Language that we have works for you if you're asking for a change in it.

[Rachel McLeod]: No. I'm I'm good with it. Okay. Great. Yeah. Yeah. Okay. The fact that it says one or more of the following.

[Rep. William Canfield (Vice Chair, Acting Chair)]: Okay. Thank you. Great. Okay. Great.

[Rep. James Masland (Member)]: Okay. Sorry.

[Rep. William Canfield (Vice Chair, Acting Chair)]: You probably did understand. Okay. Thank you so much. I really appreciate it. Yeah. No problem. And

[Cameron Wood, Office of Legislative Counsel]: I have to say I love a Regency truth and lending disclosure. Those are awesome. Are

[Rachel McLeod]: you an expert in those?

[Cameron Wood, Office of Legislative Counsel]: Oh, just a covering banker.

[Rep. Rebecca Holcombe (Member)]: Okay. I appreciate that.

[Rep. William Canfield (Vice Chair, Acting Chair)]: Chris, do you wanna join us, or will you join us, whether you want to or not? Thank you.

[Rep. James Masland (Member)]: Happy to enjoy.

[Rep. William Canfield (Vice Chair, Acting Chair)]: Thank you.

[Chris D’Elia, President, Vermont Bankers Association]: Good morning. For the record, Christelia, president for Mount Bankers Association. Thank you for the opportunity to come in and testify. So I'll give you a broader perspective than just the financing into real estate. So I'll kinda put it into three different categories if you if you will. Person owns the land, buys the mobile unit. It's wheeled up. It's permanently fixed to the land, etcetera, etcetera. That is treated as real estate. In a cooperative park, where there is an ownership stake that the individuals have within that park, I have some that will treat it as real estate, and I have others that will treat it as personal property. Those are business model decisions that they've made. And then the final one is when you've got a leasehold park, and there is no ownership stake. Those will be, for the majority of my lenders, treated as personal property. So you'll get a bill of sale. You'll get a UCC filing in the land records and in the secretary of state's office. When we met with representative Peso and in the fall, our goal was to maintain as much flexibility as possible for the borrowers in the marketplace. Because as soon as you say, we're gonna treat it as real estate and everyone treat it as real estate, you will have the lenders vacate the market because that's not their business model. And I don't think that's what you wanna have happen because you want those lenders in the market because this is very viable housing for a lot of people out there. So it's it's ownership structure that matters. It's citing on the property permanently fixed, etcetera, that matters in the decision making. You heard a little bit about portfolio or selling in the secondary market. But from our perspective, we wanted to make sure there was as much flexibility as possible for the borrowers that are out there in the marketplace.

[Rep. William Canfield (Vice Chair, Acting Chair)]: And just to put a fine point on it, you're saying that if we move entirely to a deed system, there would be folks who could not borrow or borrowing.

[Chris D’Elia, President, Vermont Bankers Association]: Your pool of lenders will shrink. You'll have fewer lenders in the marketplace because that is not their business model.

[Rep. William Canfield (Vice Chair, Acting Chair)]: Do we have fewer lenders in the marketplace and still the same loans going out?

[Chris D’Elia, President, Vermont Bankers Association]: That all depends on their appetite. I would doubt it.

[Rep. William Canfield (Vice Chair, Acting Chair)]: K. Thank you. Any other questions for Chris?

[Cameron Wood, Office of Legislative Counsel]: So in the example of someone purchasing an existing manufactured home from someone else from property sorry. This is maybe too complicated. You own a permanently sited manufactured home on your land, and you wanna sell it because you're gonna bring in a new unit or you're gonna build something, whatever. Sure. I buy it from you. Sure. So do I get a warranty deed from you for that, or do I get a bill of sale if I take it from you and then put it on land that I'm gonna rent?

[Chris D’Elia, President, Vermont Bankers Association]: Land that you're gonna rent. I do not have the information to answer that question. I don't have that, but that's a great question.

[Rep. William Canfield (Vice Chair, Acting Chair)]: Will you get the information for that?

[Chris D’Elia, President, Vermont Bankers Association]: Try and do that unless your counsel has that information.

[Rep. William Canfield (Vice Chair, Acting Chair)]: She has the book. It's a different book. Different book. Okay.

[Cameron Wood, Office of Legislative Counsel]: The way I would answer it is it's going to depend on how you as the purchaser are financing it. It's going to depend on whether it has previously been financed as real estate because there's a statutory section that says if it has been if it has a deed so in this instance, it had it was originally financed as real estate, so there's a deed for it. Now it has to remain a deed. So even if you're putting it on land that you lease, you're getting the deed. You're not going backwards to bill of sale. If it is originally financed as a bill of sale and you're purchasing it and you are going to put it on land that you lease, but you've gone to East Rise and you've got a mortgage for it, it has to be converted to a deed and then transferred to you. So it's really dependent on has it been given a d previously? Because if so, it doesn't go backwards. And then how do I view as the purchaser of financing? Is that is how the statutory structure is currently framed in in law.

[Chris D’Elia, President, Vermont Bankers Association]: So then your challenge is to find a lender who's going to finance it under that scenario. Thank you.

[Cameron Wood, Office of Legislative Counsel]: To do on lease property.

[Rep. Charles Kimbell (Ranking Member, acting at opening)]: Can you give us a ballpark estimate? How much is that gonna cost the purchaser to transfer to a team?

[Chris D’Elia, President, Vermont Bankers Association]: Well, you're getting in the closing cost on legal fees, etcetera. Yeah. $2,000, perhaps.

[Rep. Carolyn Branagan (Member)]: Any other questions for Chris?

[Chris D’Elia, President, Vermont Bankers Association]: Oh, and good luck on the tax policy implications if there are any for you here. Thanks, Chris. Because that is a challenge.

[Rep. Carolyn Branagan (Member)]: Yeah. Thank you. Appreciate that.

[Rep. Rebecca Holcombe (Member)]: Oh, you know.

[Chris D’Elia, President, Vermont Bankers Association]: I'm sure you'll come up with the right answers.

[Rep. Woodman Page (Member)]: Yes. I'm I'm just curious. I mean, Vermont is not unique. I mean, there are other states that,

[Rep. James Masland (Member)]: you know, have manufactured homes.

[Rep. Woodman Page (Member)]: How do they do

[Cameron Wood, Office of Legislative Counsel]: it? I mean

[Chris D’Elia, President, Vermont Bankers Association]: Well, I don't know what their statutory structures are, but I can envision where you have models that are similar to ours models from a bank from a lending perspective that are similar to ours where you would treat it as real estate or you're gonna treat it as personal property. And then, again, you're gonna be looking at if you're doing it in portfolio, and I'm following one set of guidelines over here. If I'm gonna be selling in the secondary market, then I'm gonna be underwriting it to those guidelines with regard to the real estate transaction or financing aspect of it. So, yeah, we're not unique. And I think what you're trying to do here is to create, again, some greater flexibility and looking at this as a public policy goal that these are viable housing units that many Vermonters can look to today. The units that are being sold on the market today are vastly different than what they were ten, fifteen, twenty years ago. They are much better units that are being manufactured today. So

[Rep. William Canfield (Vice Chair, Acting Chair)]: as we're sort of moving to units that depreciate much slower, are the lending do you see the lending opportunities opening up and shifting? Well, I think the lenders Sorry. I'm gonna sorry. I'm gonna add a second part to my question.

[Rep. James Masland (Member)]: Okay. So go ahead. Yeah.

[Rep. William Canfield (Vice Chair, Acting Chair)]: The or is sort of the essential, like, where it sits at the end of the day, the deciding factor for lenders? Like, first, you know, private land, etcetera.

[Chris D’Elia, President, Vermont Bankers Association]: K. I would say that it's both. The units that are being built today, again, are much better in quality than what we had years ago. So there's a more like to like comparison to the stick built home, in my opinion. The units that were built many years ago would not be at that level for many different reasons. So I think you're seeing a better quality product that you're able to finance in the marketplace. So there's less risk, if you will, from the lender's perspective. And then what's the risk associated with it? Well, if it's permanently fixed on a piece of property tied down, etcetera, there's, say, less risk for some of our lenders. Do we see a lot of mobile homes being moved in the middle of the night on our highways in Vermont? No. But there is the notion that if it's in a leasehold park, I can slap the wheels back on, pull the skirting off, disconnect it, and I can move it somewhere else. Are there risks associated with that? Some lenders say, yes. The risks are a little bit higher. So that's the way they look at those types of situations, each circumstance you need to the borrower. But the quality, again, is much better, so the risk of deterioration is less than what we had for homes that were in the seventies or eighties, perhaps. Right.

[Cameron Wood, Office of Legislative Counsel]: Chris, does the current version of the bill give you the flexibility for your lenders that you need? Yes.

[Rep. Rebecca Holcombe (Member)]: Thank you.

[Rep. James Masland (Member)]: Thank you.

[Rep. William Canfield (Vice Chair, Acting Chair)]: Do folks need more time on this bill? Represent us. I do not.

[Rep. James Masland (Member)]: I think we've got through it fairly carefully. I don't have unanswered question at this time, and and we'll complement the drafters and the questions around the room too.

[Rep. William Canfield (Vice Chair, Acting Chair)]: And, representative Holcombe, you wanna work on some language? Could you I I can I'm gonna speak that stuff. Okay. So we can't read first. Okay. So if you could let me know this afternoon, and we could maybe find time tomorrow for it. Right. Okay. Great. Okay. Is anyone else gonna need anything before we would move to a vote?

[Rep. Carolyn Branagan (Member)]: I'm all set.

[Rep. William Canfield (Vice Chair, Acting Chair)]: Okay. Great. Thank you, everyone. Did you Oh, okay. Great. So we are gonna take a break until 10:30. Is it too late for me to tell

[Rep. Carolyn Branagan (Member)]: you that? It's not too late.

[Rep. William Canfield (Vice Chair, Acting Chair)]: Okay. Great. Great. We're gonna take a break until 10:30, at which point, we're gonna are we doing 05:58 or 05:49 at 10:30?

[Rep. Woodman Page (Member)]: I'm working for a time.

[Rep. William Canfield (Vice Chair, Acting Chair)]: We're great. When we get back at 10:30, we're gonna do something.