Today is the last day to submit a comment to HUD about the nature of manufactured homes that qualify for insurance under FHA Title I and Title II programs.
The proposed new rule would remove the requirement that homes in the program have a permanent foundation. This by itself is a promising and significant development, as it would extend the insurance program to many more homes. However, the new rule adds a stipulation that homes must still be taxed as real property. This limits the scope of the insurance program.
A second aspect of the proposed new rule is also worth challenging. It states that any home that has been moved from its initial setting is automatically excluded from the program. At a time when many land-lease communities are closing, this is a rule that seems unfair.
An example of a model draft of a comment is available here, from CFED. This is a group that has worked for many years to address issues surrounding manufactured housing.
Comments can be submitted online at regulations.gov. It is important to put the Rule Change in the heading -- RE: Doc. No. FR–5075–P–01.