Comment Submitted by Anonymous

June 12, 2026 Docket No.: FR-6537-P-01 Title: Proposed Rule Change: Removal of Permanent Chassis Requirement for Upper Stories of Multi-Story Manufactured Homes The proposed rule change to remove the permanent chassis requirement for the upper stories of manufactured homes represents a significant shift in FHA structural standards. As a mortgage compliance professional, I am submitting this public comment to highlight critical operational and risk-management friction points this change introduces under the FHA Single Family Housing Policy Handbook (SF Handbook 4000.1). While this policy modernization encourages architectural innovation and potential cost efficiencies for multi-story manufactured housing, it creates an immediate regulatory gap regarding mandatory property eligibility documentation. Specifically, current FHA guidelines rely heavily on physical certification tags and data plates tied to individual chassis components to verify compliance with Federal Manufactured Home Construction and Safety Standards (HUD Code). Without clear, alternative documentation requirements codified in the final rule, underwriter verification workflows will become severely compromised. This comment outlines specific technical discrepancies and provides actionable language modifications to ensure systemic risk is mitigated prior to final rule implementation. Key Developments • Enhanced Design Flexibility: Eliminating the permanent chassis mandate for upper stories allows manufacturers to utilize lighter, alternative framing systems, fostering higher-density affordable housing designs. • Alleviated Structural Redundancy: Removing steel chassis beams from upper floor sections directly lowers material costs and minimizes dead load constraints on the lower-level structural foundation. Adverse Findings • Documentation Ambiguity for Multi-Story Structural Integrity: The proposed rule fails to identify the specific documentation required to prove that an upper story (lacking a chassis) safely integrates with the HUD-compliant lower chassis, creating an un-underwriteable verification gap under SF Handbook 4000.1. • HUD Certification Tag Conflict: Current FHA guidelines require each transportable section of a manufactured home to feature a permanently affixed certification tag; the rule does not clarify how non-chassis upper modules will be accounted for or validated by field inspectors. • Underwriter Workflow Disruption: Stripping the physical chassis baseline without prescribing a standardized manufacturer certification or specialized engineer’s report will lead to inconsistent risk assessments and widespread loan processing delays. Regulatory / Public Records Findings To maintain regulatory alignment and prevent systemic loan defects, HUD must address how this rule intersects with the existing SF Handbook 4000.1 baseline. Currently, Section II.A.1.b.iv(B)(1) mandates that a manufactured home must be designed and constructed to the HUD Code and remain on a permanent chassis. To reconcile the proposed change, HUD should modify SF Handbook 4000.1 by inserting the following alternative regulatory language: "For multi-story manufactured homes, a permanent chassis is required only for the foundational section in contact with the permanent foundation system. Upper stories constructed without a permanent chassis must be documented via a comprehensive Manufacturer’s Engineering Certification and an independent Professional Engineer’s Report. This documentation must explicitly verify structural load-path continuity, HUD Code compliance, and the structural integration of the chassis-less upper modules to the lower chassis platform, and must be retained in the permanent loan file." Overall Risk Conclusion Risk Level: Moderate Justification: While the structural engineering principles behind chassis-less upper stories are sound, the risk is elevated to moderate purely due to the lack of explicit documentation standards. If HUD finalizes this rule without clearly defining the paperwork required to verify compliance, it will lead to title issues, structural liability disputes, and secondary market liquidity constraints for lenders.