Top Takeaways
Enterprise Community Partners, a major player in the affordable housing world, has a for-profit subsidiary, Bellwether Enterprise, that makes loans to companies purchasing mobile home parks. Some of those loans have been to a company known for raising rents to levels unaffordable to existing tenants.
Neither BWE nor Enterprise will state publicly what their mission-related standards are for mobile home park lending, or if they have any.
Enterprise long claimed that it had no power to influence the lending strategy of its subsidiary, despite having a majority voting stake, though it has recently indicated that it has actually used that power to influence BWE’s standards.
Enterprise Community Partners is one of the most important housing-focused charitable organizations in the country; as a nonprofit intermediary, it has created or preserved approximately 1 million homes in its 40-year history. It’s also one of the nation’s most powerful non-depository community development financial institutions (CDFIs)—only Local Initiatives Support Corporation has a heftier balance sheet.
But for several years, Enterprise has been earning money from a for-profit subsidiary that regularly lends to companies whose business practices contradict Enterprise’s mission of preserving affordable housing. Enterprise’s leaders, along with many others in the affordable housing world, have known about the issue since at least 2019. Yet Enterprise’s leadership until recently claimed the organization had neither the responsibility nor the power to change its subsidiary’s course. Many in the field disagree.
The BWE Connection
The relationship between Enterprise and Bellwether Enterprise (BWE), a lender that specializes in commercial and multifamily transactions, began in 2012. Enterprise purchased a majority ownership stake in Bellwether Real Estate Capital, LLC, then a Midwest-focused market-rate commercial and multifamily lender. After the acquisition, Enterprise remained a nonprofit and retained its original administrative structure and mission. Bellwether Real Estate emerged as BWE, a “mission-driven” for-profit commercial lender. Enterprise at one point held a 55 percent ownership stake in BWE. As of the most recent publicly available audit of the organization, it retained a significant but slightly less than majority ownership stake—but still had a majority of the voting shares.
Becoming a subsidiary of Enterprise and shifting its focus to affordable housing gave BWE access to low-interest, government-backed loans. It also serves as one of just 24 “delegated underwriters” for Fannie Mae, which allows BWE to approve large manufactured housing community loans without prior review from Fannie. BWE advertises on its homepage that it’s created an impact of “4.8B+ Affordable Housing loan volume over the last 5 years.” The for-profit’s post-merger motto is “capital on a mission.” The website also states that “BWE commits 45% of its profits to increasing the number of affordable homes across the United States.”
Specifics, however, are thin: Where does the money go? How does BWE define affordable housing preservation? How is BWE ensuring that its lending creates affordable homes? Shelterforce couldn’t ask those questions or any others directly (though we did in writing) because BWE and Enterprise declined multiple requests for an interview.
What is clear is that since the merger with Enterprise, BWE has become an industry leader in financing very large purchases (as in eight figures or greater) of manufactured housing communities (commonly known as mobile home parks). As has been well publicized over the last decade, manufactured housing parks have become a major target for investment companies , thanks to their stable returns, low overhead, and weak tenant protections. And BWE appears to have few, if any, safeguards in place to ensure that its lending does not support damaging purchases or bad actors. In fact, BWE’s longtime lending relationship with Havenpark Communities, a company infamous among industry insiders, has left many questioning the lender’s commitment to its stated mission of preserving affordable housing—and raising eyebrows at Enterprise’s tacit support.
In early April 2023, after declining an interview request, Enterprise sent Shelterforce the following statement: “While Enterprise took an equity position in the company in 2012, Bellwether has and continues to operate independently and therefore does not consult with Enterprise on its loan-making decisions. Enterprise has no affiliation with Havenpark Communities, and neither Bellwether nor Enterprise sets rents for or controls Havenpark-owned properties.” (Read the full statement here.)
Havenpark’s reputation hasn’t stopped BWE from lending to it. In fact, the “mission-driven” mortgage lender has worked regularly with Havenpark, a capital investment company started by a former multilevel marketing executive. Havenpark is well known among manufactured housing affordability preservation activists for scooping up run-down parks and raising costs for tenants—many of whom are low-income or otherwise vulnerable—until they’re forced to leave, often losing their homes in the process. Havenpark’s business philosophy is to provide park investors with “high-yield returns . . . without the inconvenience of directly owning and operating the property.”
Paul Bradley, founder and former president of ROC USA, LLC, a nonprofit that helps residents buy their parks, has fielded complaints about Havenpark since the company started buying manufactured housing communities in 2017. Havenpark stands out to Bradley because it’s been “one of the most aggressive” private equity investment companies that have been buying parks at astronomical prices (tens or even sometimes hundreds of millions of dollars) then increasing rents on residents. For example, Hickory Village Mobile Home Park, a 204-space park in Fort Collins, Colorado, sold for $2.95 million in 1995. Havenpark, a large company that specializes in manufactured housing community ownership and has a reputation among residents and activists for issuing large rent increases at its parks, shelled out $23.35 million for it in 2021, outbidding residents who were trying to buy it and turn it into a resident-owned cooperative.
From 2016 to 2022 (the latest available data), BWE facilitated 108 Fannie Mae–backed loans to various LLCs registered to the same address as Havenpark’s headquarters, according to U.S. Uniform Commercial Code filings. (Investors often set up a new LLC for each property they buy.) There’s no indication that they have severed their lending relationship. BWE did not respond to emailed questions about whether they were still lending to Havenpark.
And Havenpark isn’t the only controversial manufactured housing park owner BWE has made loans to. It worked with Hometown America Communities, which in 2019 had bought Plaza Del Rey Mobile Home Park in Sunnyvale, California, for $237 million—the most ever paid for a mobile home park in the United States. Hometown America spent that amount to outbid the park residents’ own $224 million offer. BWE wasn’t involved in the Plaza Del Rey deal, but it has facilitated at least one purchase for Hometown America Communities since Plaza Del Rey closed, meaning the mission-driven lender was willing to work with a company that had in the past thwarted residents’ efforts to control their own homes.
Years of Inaction
Enterprise can’t claim ignorance about BWE’s relationship with Havenpark. This relationship is a longstanding open (and uncomfortable) secret in the affordable housing industry. “Folks have been raising these concerns about Havenpark—raising them to Bellwether, to Enterprise Community Partners, to Fannie Mae—for literally years at this point,” says Jim Baker, executive director of the Private Equity Stakeholder Project (PESP), a watchdog group focused on the effects of private equity on people and the planet.
Mobile Home Action (MHAction), a grassroots organization of mobile home park residents fighting to keep their communities affordable, was the first to publicly call out the relationship. Back in 2017, not long after Havenpark started buying parks, MHAction’s then–executive director, Kevin Borden, began getting complaints about large rent increases, added fees, new rules, and other expenses residents hadn’t had to deal with prior to Havenpark buying their communities. So when Borden got a tip in 2019 connecting Havenpark to Enterprise, he was surprised. He and other MHAction organizers thought the relationship must be an oversight, so they requested a meeting with Enterprise’s then–executive director, Priscilla Almodovar, thinking she’d appreciate the insight.
That’s not what happened, Borden says. Enterprise did not respond to MHAction’s meeting request for nearly a year. Finally, in August 2020, Borden and a small group of MHAction representatives were granted a private meeting with Almodovar (who now leads Fannie Mae) and Marion McFadden, then–senior vice president for public policy. (McFadden recently worked at the U.S. Department of Housing and Urban Development and is now employed by the private sector.)
At that point, “a sort of merry-go-round started happening,” Borden recalls. “Where they’re like, ‘Well, we don’t have anything to say in terms of Havenpark’s business model.’”
Almodovar and McFadden told MHAction that Enterprise wouldn’t interfere with BWE’s lending practices, according to activists who were in attendance. Cindy Newman, an MHAction member who was on the call, remembers Almodovar saying that the group “should work on passing legislation.” In an email following the meeting, Almodovar offered that McFadden would work with MHAction to change policies and add protections. A spokesperson for Fannie Mae declined requests for comment. McFadden would not provide a quote, but did not dispute the activists’ account of these meetings.
Candi Evans, a homeowner at Golfview Mobile Home Park in North Liberty, Iowa, has become an outspoken activist since Havenpark took over management there. Evans shared Almodovar’s email with Shelterforce. “It was a shuffle off, in my opinion,” she says. McFadden did take a follow-up call with the MHAction folks that Evans was also on, but no policy changes came of it, Evans says. Enterprise says it “offered to partner with MHAction in our advocacy efforts, but they declined to engage.”
In May 2021, MHAction released “Displacement, Inc.,” a report that recounts resident allegations about harassment—such as false accusations of being late with rent payments—and unfair eviction threats (one resident recalls being served an eviction notice for failure to make a necessary repair less than one week after a derecho storm tore a hole in his roof) and outlines the fight to pass protective legislation in a handful of states. (A Havenpark representative in an email to Shelterforce said the company disputes the claims made in “Displacement, Inc.”)
The report also calls out Enterprise’s indirect business relationship with Havenpark. In September 2021, MHAction activists met virtually with McFadden. They say McFadden reiterated that BWE makes its own business decisions and would continue lending to Havenpark. The people participating in the call were “unbelievably shocked,” Borden remembers. “It was during that call when we realized they are going to do nothing. They’re not going to pay for their sins,” he says. (Enterprise’s spokesperson denied any Enterprise employee ever stating to MHAction that Enterprise wouldn’t intervene in BWE’s lending choices, despite having repeatedly told Shelterforce that Enterprise could not control those same choices. MHAction has not had any additional contact with Enterprise or BWE since these exchanges, according to Yvonne Maldonado, MHAction’s current co-director.)
It was during that call when we realized they are going to do nothing. They’re not going to pay for their sins.”
Kevin Borden, MHAction
Havenpark was also prominently featured in A Decent Home, a powerful 2022 documentary about the effects of economic inequality, political power, and predation in the manufactured housing industry. Filmmaker Sara Terry spent six and a half years filming the documentary, which features dozens of mobile home park residents from several states dealing with corporate park owners’ new rules, rent hikes, and evictions. In it, Evans recounts to Sen. Elizabeth Warren (D-MA), who has advocated for manufactured housing community residents, her financial struggles since Havenpark took over management at Golfview. “These people are coming in to make money off the backs of people that have worked all their lives to have what they do have,” she tells Warren. “They’re the most vulnerable in society, in most cases, and the people that are taking advantage of the situation are some of the richest people.”
BWE has continued to endorse Havenpark as a bastion of affordable housing preservation. For example, in the description to a video posted by BWE in 2022 (that was publicly viewable on YouTube until very recently, but has been made private as of publication) of a conversation between BWE executive vice president M.J. Vukovich and Havenpark Communities CEO Robbie Pratt, BWE wrote that they discuss “how Havenpark is improving their Manufactured Home Communities to provide opportunities for better living environments for the residents.”
PESP’s Baker is incredulous at the affordability preservation claims, but even more so that the lending relationship has continued. “[Enterprise is] completely aware of what Havenpark is doing, and yet they’ve continued to, at least through [2022], channel Fannie Mae–backed mortgages to Havenpark,” he says. “They’ve cited Havenpark as an example of [a company that’s] preserving affordable housing at the very same time that Havenpark is aggressively making housing less affordable.”
Should—And Can—Enterprise Do Anything?
According to BWE’s tally from the 2022 video: “Over the past 5 years, Havenpark has purchased, installed, and occupied over 4,000 new manufactured homes, providing an affordable, energy efficient, and quality housing option to thousands of individuals and families in the markets they serve.”
During that same five-year period—which included record-setting purchases by investor-owners—Enterprise has continued to benefit indirectly from BWE’s transactions with Havenpark. And it has insisted throughout most of that time that it had no power, directly or indirectly, to change the situation or influence BWE’s strategy or lending standards because BWE operates as an “independent subsidiary.” Enterprise’s stance was that BWE’s independent status means its board and leadership make day-to-day operational business and lending decisions without Enterprise’s input.
The details of the partnership structure and profit-sharing agreements between the two organizations are not public, and Enterprise has declined many requests to clarify them, but experts say even if they are operating independently, the idea that Enterprise has no recourse is doubtful.
Enterprise representatives hold four seats on BWE’s seven-member board of directors. That includes one held by Charles Werhane, who in 2012 (during the merger) was Enterprise’s president and CEO. He now works as a consultant for BWE. Enterprise’s heavy presence on BWE’s board means its leadership at minimum can significantly influence BWE’s strategic, long-term guidelines—even if it doesn’t guide the lender’s day-to-day decisions. Having that oversight ability is especially important given Enterprise’s nonprofit status, explains Gene Takagi, a principal at NEO Law Group, a nonprofit- and charitable trust-focused firm based in San Francisco. Takagi says that in arrangements like this there is an expectation that the operating agreement would include provisions to ensure such controls.
“If you’re investing a substantial amount in a joint venture and your joint venture partner is not another charity but a business, you have to control the nonprofit charitable activities of that joint venture and have final say. Otherwise the joint venture might do something a nonprofit can’t do,” he says. “So there would be permission in either the operating agreement of an LLC or a shareholders agreement or bylaws of a corporation that would prevent that from happening.” Enterprise declined to share any specific provisions or detailed information about its operating agreement with Bellwether.
Strategic decisions that are within the purview of a board include high-level decisions about policy and mission alignment. Boards of directors hold varying powers dependent on their associated bylaws, but they’re typically responsible for hiring company leadership, determining and enforcing a mission, and setting long-term goals and strategies, among other responsibilities.
Beyond its board seats and voting majority, Enterprise also held a majority ownership of BWE for several years after buying the company. In 2017, it held just more than 58 percent ownership in BWE, dipping to around 55 percent ownership for several years after that. Enterprise isn’t technically majority owner anymore; today, it holds just under half of the ownership shares in BWE. But it still owns a majority of the voting shares, according to the most recent available audits. Although it’s not unusual for nonprofits to make financial investments—even substantial ones—in companies that don’t support their mission, there’s a distinct difference between investing in a company and being its controlling stakeholder. PESP’s Baker put it this way: “Majority owner is majority owner.”
Does being only majority owner when it comes to voting shares relieve the nonprofit from responsibility? George W. McCarthy, president and CEO of the Lincoln Institute of Land Policy, doesn’t think so.
“They govern it. And as the governors—as the people who set policy for Bellwether—they could very well set a policy that says we don’t broker arrangements for purchasing manufactured housing communities,” he says. “If you govern the organization then you have the right to do whatever the hell you want. So that’s kind of a weak claim.”
If you govern the organization then you have the right to do whatever the hell you want. So that’s kind of a weak claim.”
George W. McCarthy, Lincoln Institute of Land Policy
“The nonprofit can exercise some control in different ways over the joint venture,” Takagi says. “Especially when it has a majority interest, it would be expected to have certain controls in there, particularly over the charitable activities.”
So, if Enterprise determined that lending to Havenpark was contrary to its mission, its controlling voting interest and weighty presence on BWE’s board should give it the power to at least set broad standards for BWE’s investments to ensure they align with Enterprise’s mission.
And if Enterprise wasn’t powerful enough to change BWE’s actions in the short term, it still wouldn’t be helpless, Takagi says. Although unfamiliar with the specifics of this ownership relationship, he says anytime a nonprofit becomes part of a joint venture, a fallback measure usually exists allowing the nonprofit to influence who sits on the board. “If they’ve made a substantial investment,” he says, “then they’re going to want to protect their investment, and I would think they would want the right to appoint and actually control a majority of the board’s composition.”
So it seems likely that Enterprise could guide standards for BWE’s lending practices—or at least ensure some are set. But for a long time, it doesn’t appear to have done so, or even to have tried to do so. Neither Enterprise nor BWE would answer any questions or share any information about what standards BWE uses to determine if the loans it makes are mission related. In fact, BWE would not reply to any of Shelterforce’s requests for comment, including on whether such mission-related standards for their lending exist at all. An Enterprise spokesperson said Enterprise “has precise standards for affordable production” and that BWE “regularly shares data . . . about its affordable production figures,” but declined to identify those standards or the definition of “affordable” being used in them.
PESP’s Baker calls Enterprise’s long-time complacency with BWE’s ongoing lending to Havenpark “shocking.” More than a dozen people in the field whom Shelterforce spoke with for this story universally felt that Enterprise should step in, regardless of BWE’s status as an “independent” subsidiary. (Most stayed off the record, however, citing fear of affecting funding relationships with Enterprise, which is a ubiquitous presence in the field.)
And it seems Enterprise did eventually shift its position on whether it can affect BWE’s lending standards. When Shelterforce first asked in 2023 if Enterprise had ever raised concerns with BWE about its choice to lend to companies that might contradict both organizations’ stated missions of preserving affordable housing, an Enterprise spokesperson highlighted BWE’s operational and decision-making independence. In late 2024, however, after being presented with a final list of specific questions for this story, the Enterprise spokesperson emailed the following response:
Under our current leadership, Enterprise has used its ownership position to review and strengthen Bellwether’s underwriting standards to go above and beyond GSE-mandated tenant site lease protections for manufactured housing communities. We will continue to engage with advocates, investors, and government partners to support this critical part of the affordable housing landscape.
The spokesperson did not specify how those underwriting standards were strengthened, or whether the new standards would affect any of BWE’s preexisting lending relationships with manufactured home park owners.
Enterprise also noted that BWE has distributed “$7.5 billion in capital to support affordable homes over the past decade,” while Enterprise itself has provided $20 million in capital for residents to form co-ops and buy their communities, advocated for increased tenant protections to the Federal Housing Finance Agency (FHFA), and “spearheaded research that will inform the policy recommendations and best practices for the future.”
Part of a Larger System
Though expectations are understandably high for a prominent organization like Enterprise, the question about what “counts” as affordable housing preservation when it comes to lending doesn’t start with Enterprise or BWE. In many ways it starts with Fannie Mae and Freddie Mac, the two government-sponsored enterprises (GSEs) that purchase portfolios of real estate loans, including manufactured housing community purchase loans, on the secondary lending market. Fannie and Freddie consider loans made to capital investment firms, like Havenpark, for buying manufactured housing communities to be “preservation loans.” This means those loans count toward the GSEs’ own goals to support affordable housing preservation under the Duty to Serve Underserved Markets Rule (DTS), which instructed the GSEs to explicitly service three underserved markets, including manufactured housing communities—provided the purchasers commit to retaining their use as housing.
But aside from keeping the parks operational as manufactured housing communities, there aren’t many federal requirements for borrowers taking advantage of the lower interest rates offered by DTS loans. In 2021, Fannie and Freddie adopted a rule that all future GSE-backed purchases of mobile home parks must include some tenant protections, including good cause eviction protections and rent increase notifications. While this change marked a significant improvement, the new requirements don’t include a cap on rent increases, so cash-flush investor-owners like Havenpark can still get low-interest taxpayer-funded loans and be rewarded for “preserving affordable housing” without being held to any standards about what “affordable” means.
“If you are participating in an affordable housing preservation program and the outcome of your program is seeing very high housing cost increases and evictions and displacement, you are not running an affordable housing preservation program—you’re doing something else,” says Caroline Nagy, senior policy council for housing at the Americans for Financial Reform Education Fund. She believes that the first step to remedying the problem is “forcing a reckoning [on the idea] that any capital is good capital, because that’s just not true. You need to place requirements on beneficial financing terms that genuinely value housing affordability.”
And though some protections are better than none, Nagy questions the efficacy of FHFA’s recently adopted lot lease protections. She argues that the fact that the rules have failed to prevent harm on an acutely vulnerable demographic of homeowners indicates how urgent the situation has become—pointing out that residents continue to be priced out even with FHFA’s pad lease protections in place.
“We have to first acknowledge that it is not in the legitimate public interest to provide lower cost financing to private equity firms so that they can displace people, raise costs, and make more money for themselves,” Nagy argues. “The problems with manufactured housing have been so flagrant—abuses, frankly, of the folks who live in these communities. It is shocking that a federal government program would do this to people.”
Affordable housing advocates also take issue with the GSEs’ willingness to back BWE’s loans to capital investment firms under the DTS program when neither Fannie nor Freddie will purchase loans to resident-owned communities (ROCs). This includes loans made by ROC USA, a nonprofit that facilitates transactions for manufactured housing community residents who want to form cooperatives to own and manage their own communities—even though ROC USA has completed nearly 350 transfers to community ownership with no ROC USA–backed borrowers defaulting on their loan and none of ROC USA’s communities ever reverting to private ownership.
FHFA has said it doesn’t have enough data to determine whether ROCs meet their underwriting standards. McCarthy finds this ridiculous. “The fact is that ROC USA could be recognized as a credit enhancement itself,” he says. “You have a flawless lending record and that’s enough data to suggest to me that they have something going there. But it’s never been enough for Fannie and Freddie.”
The GSEs also won’t back manufactured housing community loans to most nonprofit entities, though they say they are gathering data on the feasibility of doing so. (Fannie in 2019 began testing a product specifically tailored to non-traditional ownership, i.e., nonprofits and ROCs; since then, it has “helped finance six loans which provided 906 pads that are either nonprofit or residential owned as of December 31, 2022.”) As of today, both Fannie and Freddie have begun shifting their standards, but neither yet allow loans to nonprofits or ROCs to be packaged and sold on the secondary mortgage market like they do with loans to real estate investment trusts and other corporate entities. (Fannie Mae declined a request for an interview with former Enterprise executive director Priscilla Almodovar in her current capacity as CEO.)
So while the standards ultimately rest with the GSEs, most CDFIs and mission-based lenders set their own standards higher than what Fannie and Freddie require. That means firms like Havenpark can only buy as aggressively as their lenders will allow. And even though Havenpark and other investor-owners bring a hefty amount of their own capital to every mobile home park transaction, these companies often still need many additional millions of dollars in loans to afford such hefty acquisitions and BWE has been one of the major lenders connecting these borrowers to that necessary capital.
“Places like Enterprise and Bellwether right now are supporting the wealthiest of the wealthy, who are making huge amounts of money off the most vulnerable homeowners in America,” Terry says. “It’s an incredible dichotomy, a screaming inconsistency that they’ve yet to grapple with.”
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3 thoughts on “Mission-Driven or Profit-Driven? Enterprise’s Hidden Role in Mobile Home Park Purchases”
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Is there any probability of a class action lawsuit against lenders abd the borrowers? Did ou see any help for those of us who are paying Haven Park for the graft? Who do you think could hold them accountable and who could we write to? Thank you.
Good to raise awareness, not only of these activities, but also Resident Owned Communities. Thanks for this valuable info.
Thanks for exposing manufactured housing park corruption, yet again. The US government’s questionable role in housing injustice is long and torrid.
https://www.newyorker.com/magazine/2025/03/17/what-do-we-buy-into-when-we-buy-a-home?utm_source=firefox-newtab-en-us
As top-down approaches fail, not enough bottom-up is being considered and acted upon. Direct outreach to vulnerable residents of parks is seldom thought about – until it is too late – after the predatory corporation has bought the park and homeowners are suffering. Protective legislation intervention is slow and far behind. Symptomatic treatment is not systemic treatment. Best to actively warn residents in mom-and-pop owned parks BEFORE they are flipped to predators, but that isn’t happening. Pensions funds should divest, and more…
https://mhp411.com/cost-of-living/living-in-a-mobile-home-park-the-hidden-conditions
https://mhphoa.com/