Kudos for Ron D’Ambra’s thoughtful article on the HUD Code and Manufactured Housing Affordability

As a former manager of the HUD Manufactured Housing Program, I was gratified to read Ron D'Ambra’s recent piece titled “Are HUD Practices Making Manufactured Homes Less Affordable?”   While there are always some costs associated with any form of government regulation, Ron clearly appreciates the long term benefits that HUD has brought to an industry that was previously known for building low quality firetraps. 

Though a small clan within the industry reflexively condemns just about everything HUD has done over the years, I’d recommend Ron’s review of HUD’s history and various functions to anyone who wants to understand the enormous strides in quality and safety the industry has made since HUD first set up its program shop back in 1976.

Rather than repeat Ron’s points, let me add one of my own.

When the Act was passed in 1974, its title referred to the products as “Mobile Homes” and the language of the Act often referred to the products as “vehicles”. It has always seemed to me that Congress was thinking of the industry’s products as more like automobiles than houses for regulatory purposes.Thus the “Notification and correction of defects by manufacturer” requirements in 42 U.S.C. 5414 which are implemented in Subpart I of HUD’s regulations.

Compliance with these requirements represents most of the real HUD compliance burden, which requires remedies much like automobile recalls for the life of the home.

Given that the quality and safety of manufactured homes now equals or exceeds that of site built homes in most respects, perhaps the time has come to ask Congress to reconsider replacing the current requirements of 42 U.S.C. 5414 with some sort of warranty.For all I know, this idea has already been discussed, but I left HUD in 2010 and may have missed it.

Anyway, on behalf of the hundreds of people who have staffed the HUD program, served as HUD IPIAs and DAPIAs, as HUD contractors and Consensus Committee Members, thanks very much Ron for your thoughtful piece.##

Bill Matchneer, JD, recently retired from 23 years of federal government service. Most recently he supervised the Dodd-Frank appraisal rules at CFPB, but is better known to our readers for his ten years as manager of the manufactured housing construction and safety standards program at HUD. Bill can be reached at (703) 973-4366 and at bill.matchneer@comcast.net. 

(Editor's Notes: A recent interview with Bill Matchneer is found linked here.

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