In a follow-up to October Research’s “Manufactured Housing Supply and Financing – featuring HUD and FHA” webinar, Teresa Payne, administrator for the U.S. Department of Housing and Urban Development’s (HUD) Office of Manufactured Housing Programs (OMHP), answered audience questions related to this type of affordable housing.
Q: What is the difference between a manufactured home and a modular?
Payne: Manufactured homes are built to a nationwide federally preemptive building code, the Manufactured Home Construction and Safety Standards (MHCSS). Manufactured homes are subject to a regulatory oversight system that is administered by HUD. There is a certification label attached to each section of a manufactured home.
Modular homes are designed and built to meet building codes established and enforced by state and/or local government.
Q: What is the median price of the 93K manufactured homes built in FY20 and what is the range, low to high?
Payne: OMHP does not maintain data with respect to pricing. However, publicly available data is available from the U.S. Census Bureau. This data includes average pricing data on a national and regional basis. The data can be found here.
Q: Are these homes with the “label” distinctly different from “mobile homes” with VIN and titles for each side?
Payne: The Department of Housing and Urban Development (HUD) requires a manufacturer place a large information sticker, called a “data plate,” on the interior of every mobile home manufactured since June 15, 1976. There are 3 types of ‘homes’: (1) Manufactured Homes; (2) Modular Homes; (3) Travel Trailers.
With respect to travel trailers, these are considered recreational vehicles (RVs) and are built to industry consensus standards developed by either the National Fire Protection Association or the American National Standards Institute.
Manufactured homes are labeled at the end of production. The application of the label signifies the home manufacturer self-certifies the home complies with federal standards. Each transportable section (i.e. floor) of a manufactured home receives the HUD-required certification label.
Mobile homes are typically those homes built prior to the implementation of the federal program (prior to June 15, 1976). Generally, mobile homes were built to either voluntary standards or to requirements established at the state level.
Q: When I talk with owners of mobile home parks, I’m nearly always told municipalities are the biggest impediment to adding more homes and parks. How can HUD/Federal Housing Administration help overcome this reticence?
Payne: While HUD does not have regulatory oversight authority regarding mobile home parks, HUD is working through its research and working groups to identify and address regulatory barriers to affordable housing, including manufactured housing. In addition, HUD has worked with disparate local governments in addressing discriminatory and exclusionary zoning practices.
Q: We are seeing an increase in problems with homes. Based upon the continued increase in homes being built, is quality being addressed? We have had an increase in disputes between borrowers, dealers, and the manufacturers. This is putting the lender in the middle. Have there been adjustments to inspections, etc., based on increases and these types of issues?
Payne: HUD’s monitoring has not found any significant increase in failures to conform to HUD standards. However, HUD does acknowledge variability in quality both between manufacturers and due to human design and production factors. There are also differences in standards-related issues that have regulatory redress and non-standards related issues, such as contractual matters and cosmetic issues, that do not have regulatory redress through HUD’s regulatory scheme. HUD encourages any informed party to provide all consumer-related complaints to the home manufacturer for redress.
Q: How are tribal nations engaged?
Payne: Manufacturers of manufactured homes are regulated by HUD and as such are expected to comply with HUD’s regulations regardless of the status or location of the end purchaser. Due to various limitations that may exist if a consumer is on tribal lands, HUD may not be able to ensure compliance of corrective actions. However, HUD has cooperated with tribal entities on an ad hoc basis and would continue to cooperate as circumstances dictate and as needs arise.
Q: What are your standards around climate resilience?
Payne: The current manufactured housing construction and safety standards address various aspects of climate resilience, including resistance to wind and other structural loads as well as thermal performance, among other things. Further, specific local considerations may be necessary considerations for the installation and setup of a manufactured home on any given home site.
Standards for design and construction and the minimum installation standards may be found here. The current proposed rule also includes, among other things, proposing a requirement for a water resistive barrier.
Q: Are there solar options?
Payne: Manufacturers are able to install solar options in their manufacturing facilities.
Q. Why 1-3 units and not the conventional 1-4 multi-dwelling units?
Payne: The proposed rule that would allow for multi-unit single family dwellings includes a limit of up to 3 dwelling units. This is the maximum recommended by the Manufactured Home Consensus Committee as was based on a similar provision in effect for the state of Ohio.
Q: Any thought to lower counters in the Americans with Disabilities Act (ADA) reference updates?
Payne: Accessibility options are available for purchasers who wish to have greater ADA access throughout a home.
Q: Are these homes eligible for title insurance?
Payne: Yes, manufactured homes are eligible for title insurance, subject to state and local requirements.
Want to hear more on manufactured housing? Access the complimentary webinar here.