2025-04-20-国际清算银行-负担得起的住房_负担不起的信贷_制造业住宅的集中化和高成本贷款（英）_71页_967kb

Affordable Housing Access: Challenges in the Manufactured Home Loan Market

Key Findings

The paper "Affordable housing, unaffordable credit? Concentration and high-cost lending for manufactured homes" finds that:

• Market Concentration Drives High Interest Rates: The $150B manufactured home loan market shows significantly higher concentration (HHI up to 3x that of site-built markets) correlating with higher interest rates (avg. 5% vs 3.6%) and rate spreads (1.9pp vs 0.5pp).

• Regulatory Arbitrage and Bunching Evidence: Analysis of HOEPA's 6.5pp spread threshold reveals downward bunching at the threshold, indicative of market power and rent seeking by lenders.

Main Contributions

1. New Evidence on Market Power: Provides causal evidence linking market concentration to lending costs in a under-studied segment central to affordable housing access.

2. Role of Integrated Lenders: Identifies "integrated" lenders (often captive to manufacturers) charging ~50% higher spreads (4.3pp vs 1.3pp) even after controlling for borrower characteristics.

Policy Implications

• Further relaxing HOEPA thresholds might reduce financing costs
• Strengthening competition policy could lower mortgage costs
• Need deeper assessment of captive finance practices

Note: Summary based on BIS Working Paper Doerr & Fuster (2025, No. 1255).