Manufactured Housing Is a Good Source of Unsubsidized Affordable Housing -  Except When It’s Not: High-Level and Specific Policy Recommendations (Part 3)

Introduction

The United States is in the midst of a severe shortage of affordable housing for low-and-middle-income (LMI) families as both home prices and rents have climbed faster than household income for many years, particularly during the pandemic. Recently, there has been a renewed focus on expanding the supply of manufactured housing (MH), known for being low cost, as one key method to help reduce that shortage.  This reflects the belief by its supporters that MH, being produced in an efficient factory environment, can provide low-cost housing without the need for government subsidy, whereas other sources of low-cost housing usually do require such support in one form or another.  More recently, the Biden administration has joined the call to expand MH’s role for just this reason. 

MH currently provides approximately six percent of the total owner¹ and renter-occupied housing in the U.S., with a much higher market share of 14 percent in rural geographies.  It also accounts for about 10 percent of all new residential structures built each year, a percentage that has not changed in over two decades.²

As a generalization, MH supporters view its expansion to increase the supply of lower price point homes as requiring two specific actions.  First, the four government mortgage agencies,³ and in particular the two government-sponsored enterprises (GSEs) of Freddie Mac and Fannie Mae, should lower the cost of financing “chattel loans” (i.e., loans secured only by an MH structure, excluding the underlying land, and which I will sometimes refer to as structure-only loans) by making them eligible for routine purchase.⁴  Second, states should override local zoning and other land use restrictions against MH structures generally and MH communities (MHCs) specifically, which MH supporters believe to be unjustified and unfair.  Additionally, to reduce the potential of housing-related family instability for many MHC residents (up to and including the extreme case of forced removal of the MH structure from the underlying land), some housing policy specialists also call for actions specifically designed to reduce the instances of institutional investors – and maybe even all for-profit entities – being MHC owners.

In Parts 1 and 2, I showed that MH often does not easily fit into the traditional categories of rental or owned housing, particularly due to the significant market share of MH where the structure is owned by its resident but the underlying land is rented from someone else.  The complicating challenge in such cases is that the MH resident does not get to enjoy the two significant policy benefits of homeownership that have long been used to justify government intervention to subsidize and support it: (1) the economic benefit of building family net worth to support retirement and possibly the next generation via long-term appreciation in the value of the home; and (2) the household stability benefit of avoiding landlord actions that would require relocation, such as excessive rent increases or lease non-renewal. 

In this Part 3, after briefly reviewing the analytical framework and policy underpinnings developed in Parts 1 and 2, I lay out recommendations designed to fit the complex economics of the MH marketplace.  Some are high-level in nature, but most are more specific.  Given my conclusion that there are no quick-fix or silver bullet solutions to significantly increase MH’s market share, my recommendations are focused on changing certain long-term fundamentals about MH that should result in (1) some increase in MH’s share of housing above its current six percent level; and (2) a significant improvement in the economic and household stability benefits generally associated with residing in MH housing, bringing them closer to what site-built housing already offers. 

The Analytical Framework

Parts 1 and 2 describe and analyze the complexity of the MH market due to the separation between the structure, which is produced in a factory, and the underlying land. Each initially represents a separate economic entity that may or may not be joined together in various ways.  By comparison, a conventional site-built home (including modular housing) almost always consists of a plot of residential land that is physically and legally joined together with a structure through the construction process into a single “real property” home. 

Fundamental to understanding MH vs. site-built housing are the following:

Land vs. structure. 

• Residential land is, on average, a generally long-term (GLT) appreciating asset.
• A residential structure (whether MH or any other type) is a GLT depreciating asset, after adjusting for inflation and before considering the impact of expenditures to maintain or improve it.
• The average typical land-plus-structure home also has a track record of net appreciation in value (i.e., the land’s appreciation is greater than the structure’s depreciation).

Single-family MH vs. MH in MHCs⁵ 

• Single-family MH is where an MH structure, by itself, sits on a conventional residential lot, just like most detached site-built single-family homes.
• MHCs are, in physical appearance, the rough equivalent of garden apartments or townhome communities, in that each structure sits on a very small lot (aiding affordability), with either a landlord or a homeowners’ association (HOA) maintaining the common property (e.g., the roads) and any provided amenities.⁶  (Legally, garden apartments usually connote pure rentals, while townhome communities can be either pure rentals or condominiums; in the latter case, the resident owns both the structure and land.)

MH ownership configurations.  There are three primary types of MH ownership configurations, with variations within each.

• “Rent-rent” MH, where both the structure and the land are owned either by one or two third parties and rented to the structure’s resident.
• “Own-own” MH, where the resident owns both the structure and land. An important sub-category is where the two are joined together legally and physically on a permanent foundation so that they qualify to be a single unit of “real property,” which in turn qualifies it for a conventional mortgage.
• “Own-rent” MH, where the resident owns the structure but rents the underlying lot upon which it sits, i.e., a hybrid between full ownership and full rental.  This category has many variations, especially regarding the ownership of the underlying land.⁷ 

Policy Underpinnings

In Parts 1 and 2 of this series, I reached seven conclusions that form the underpinnings that I believe policy recommendations regarding MHs must reflect to be effective and efficient and to minimize unintended consequences. They are:

1. MH is a very complex field.  All policy recommendations must be carefully targeted to ensure effectiveness and avoid unintended consequences.
2. The own-rent form of MH is only marginally equivalent to conventional homeownership.  It is questionable whether it is deserving of government help designed to support such homeownership, as it does not deliver the usual two major benefits – wealth building and housing stability.  An exception should be resident-owned MHCs, which have economic attributes for residents closer to own-own MH than own-rent. 
3. MH is not a universal solution for more affordable housing across all geographies.  Single-family MH seems most appropriate for low-density geographies, whereas MHCs potentially have broader applicability.
4. MH is indeed a source of low-cost housing, but not solely or overwhelmingly due to the efficiency of factory production.   When addressing the affordability of MH housing versus site-built, several factors must be considered.  First, the average MH unit is considerably smaller than the typical site-built home, producing a lower price point to help affordability.⁸  Second, the cost efficiency of factory production, in my estimate, results in roughly a 20 to 25 percent per square foot advantage versus a site-built home of comparable quality.⁹  Third, MH comes in a range of quality, with the lower end of the range using somewhat lower-cost materials and production methods,¹⁰ further reducing the price for such units.¹¹  And fourth, the cost of the underlying land (whether purchased or rented via monthly payments¹²) is of course independent of all this and is the same whether it supports MH or site-built structures.  To sum up, MH is more affordable than site-built homes only partially because of factory production efficiency, while other factors – such as smaller size or somewhat lower quality – are also very important.  In more colloquial terms, the former is often seen as a legitimate "free lunch" to aid affordability, the latter factors reflect the conventional economics that “you get what you pay for.”¹³ 
5. Real property MH, which represents about one-fifth of all MH units, has benefits similar to site-built housing.  This importantly includes being eligible for a low-cost, 30-year fixed-rate conventional mortgage and benefitting from the underlying land's price appreciation, all while being somewhat less costly to build due to the abovementioned reasons.¹⁴
6. The potential benefit from the GSEs or other government agencies providing structure-only (i.e., chattel) loans to own-rent MH unit residents is likely to be modest at best.  This is because such loans would not benefit from the materially lower interest costs of the “to-be-announced” (TBA)¹⁵ market while their credit risk is demonstrably higher.  There may be a modest benefit via custom agency securitizations, although ensuring the resulting savings accrue to the actual borrower, rather than primary market lenders, is a significant challenge.
7. Rent-rent MH, which comprises about five percent of the rental market, offers a genuine possibility for the low cost of MH structures to create very affordable housing that meets all government standards for safety and energy efficiency. Unfortunately, I have not seen any particular Washington housing policy focus on this opportunity which, even without subsidy, could help address the housing needs of some of the lowest-income families in the country.

High-Level Recommendations and Reasoning

1. Drive sustained policy change through an interagency committee.  In my experience, housing is a very hard-to-change sector of the economy,¹⁶ and MH fits into this mold as well.  Thus, instead of traditional housing policy recommendations that consist of specific and often narrow proposed changes to legislation, regulation, or government mortgage lending criteria (often along with proposed outright or indirect subsidies), a leadership organization is needed to consistently “work the problem” for as long as it takes, which is likely to be many years. My recommendation is that the leadership group be a committee consisting of representatives from HUD; the Federal Housing Finance Agency (FHFA), with the resources of the two GSEs behind it; the U.S. Department of Veterans Affairs, and the U.S. Department of Agriculture (which finances rural housing). I will refer to this group as the Interagency Committee (IAC).  This team could address many potential “angles of attack” to find what is implementable, practical, and impactful.  In other words, I do not believe quick fixes are readily available. 
2. Change the mix of ownership configurations.  Across all the recommended efforts to expand MH should be a strong policy bias to increase or decrease various specific ownership configurations. Specifically, I recommend:

a. Less own-rent MH.  The currently high market share of the own-rent ownership configuration should be reduced in favor of either own-own¹⁷ or rent-rent. The simple fact is that own-rent MH, as stated several times, is not complete homeownership, for without the resident family owning the underlying land, it does not enjoy the two main benefits of homeownership (increasing net worth and reduced exposure to housing instability due to landlord actions).  Thus, there is no reason for it to benefit from the low-cost financing available from government mortgage agencies (which, in turn, benefit from hard-to-value government support).  Several of the specific proposals below address this issue. 

b. More real property MH.  The one-fifth share of MH that qualifies as real property should ideally increase, with two different target situations: (1) newly-produced MH units, and (2) existing own-own non-real property MH units where the physical challenge to install a traditional foundation must be addressed (see below).  Real property MH provides all the benefits of full homeownership, representing an affordable home that happens to have an MH-produced structure.  It also can already be financed by a conventional mortgage loan, which further improves its affordability versus the noticeably higher cost of structure-only lending.

c. More resident-owned MHCs. Residents in such MHCs can arguably enjoy more favorable financing costs and also the potential for net-worth-increasing capital appreciation by owning both the structure and their share of the underlying land.¹⁸  An increase in the share of MHCs that are fully resident-owned would benefit the tenants/occupants.

3. Enable single-family zoning reform.  Zoning reform to allow more MH (including MHCs) in suburbs typically zoned almost exclusively for single-family housing is one possible path to creating more affordable housing.  History suggests that any proposed changes to single-family zoning, whether related to MH or not, will be hard-fought, both at the local level and also at the state level when legislation is proposed to override local zoning. This effort will also require effective targeting to attract the necessary legislative support for new zoning to be adopted.¹⁹

Specific Recommendations

A number of recommendations follow from my analysis.  The nine listed below vary in their potential impact, with almost all falling into the purview of the IAC “working the problem” to produce significant and lasting change.  This list offers no silver bullets, as I believe there are none.

1. The IAC should develop a comprehensive policy database of information.  It is axiomatic that developing good policy first requires good data.  This is a challenge for MH, as so much housing-related data is tied to real property records (covering only about 20 percent of MH structures) or to MH dealer sales (which do not reflect how the purchased units are used).  Better data is needed, for example, on all the different types of MHC configurations; on the costs of MH vs. both site-built and modular construction – all on an apples-to-apples basis, including land, transportation costs, etc. Data on the expected life span of MH vs. site-built homes, on the specifics of own-own non-real property MH residences, and on how all types of MH are used in different types of geographies, would also be helpful.  And there should absolutely be an increased focus on rent-rent MH, which already comprises five percent of all rental units.
2. The IAC should sponsor a high-profile competition (with a large enough monetary prize to attract attention) among industry and academic engineers to develop one or more practical and low-cost ways to retrofit many of the 80 percent of existing MH structures currently not considered real property.  The objective would be to have them become physically, and then legally, joined to the underlying land enough to qualify as real property.  Such a solution is foundational to potentially unlocking several opportunities, some of which are described below, for the residents to become fully conventional homeowners with all the improved economic and social benefits that come with that status.  This may require the IAC to delve into revising the legal requirements (currently set at the state level) that are needed for a foundation to qualify as a component of a real property home, and especially to be acceptable to the lenders who will be taking the related risk.²⁰ 
3. The IAC should lead efforts to develop an ability to legally reconfigure resident-owned MHCs to become condominiums, which will deliver lower financing costs and better homeownership benefits to residents.  Resident-owned MHCs generally have a legal format that has each resident household owning the MH structure, and thus only qualifying to finance it with an expensive structure-only loan.  Separately, the underlying land for all the units plus all common areas and amenities is owned by a company (which can only finance on commercial terms, like any landlord) that is, in turn, owned by the residents.  But with an ability to retrofit each structure to have it become physically joined to the land, as described above, it becomes possible to develop a standardized legal restructuring of an entire resident-owned community to become condominiums (with their usual HOA), where each resident owns their structure-plus-underlying-land as real property and has shared ownership in all common areas.²¹ This is the exact definition of a condominium, as found in apartment houses or townhome communities.  This would allow each resident to qualify for a conventional 30-year, fixed-rate mortgage, with each such mortgage based upon the value of both the individually-owned real property home and a pro rata share of the common areas (thus obviating the need for the more expensive structure-only loan and also the landlord-style commercial loan), at potentially great savings in the monthly payment.  It would also arguably allow each resident’s homeowner’s equity to fully reflect the value of the land, including the common areas, increasing over time.  It’s potentially a significant win-win all around, making resident-owned MHCs fully the equal of conventional homeownership.²² 
4. The IAC should work the problem of incenting existing own-own non-real property single-family MH residents to retrofit the structure’s physical attachment to the land and thus enable their homes to become real property upon the consummation of specific additional legal steps, in turn enabling them to qualify for conventional mortgages with lower rates and longer maturities.  Even with the ability to retrofit existing own-own non-real property MH, it is unclear what would generate enough incentive for the owners to undertake such a process.  There is no definitive data on how many such situations there are, but it is generally believed to be significant.  There is a real possibility that the lower financing cost from the change could be great enough to allow the government mortgage agencies to include in their loans the amount needed to repay the full retrofit cost, again making it all very win-win.  I note that reaching such a disparate and widely-dispersed set of residents, with little information as to who they are, will be a true challenge; it will probably require the aid of conventional mortgage primary lenders (of which there are well over a thousand) to reach this audience. 
5. The IAC should similarly work on the problem of getting a greater share of newly-purchased MH structures to be real property financed with conventional mortgages.  The data is uncertain, but it seems that a material share of newly-purchased MH structures placed on owned land nevertheless are not sited on a more expensive traditional foundation and are financed with structure-only loans.  Anecdotal evidence of why this happens focuses separately on the MH dealer and the buyer. Also, it is based on the intimidating additional amount of time and expense it takes to pursue the real property/conventional mortgage route.  Basically, a structure-only loan can be approved and arranged at the time of sale, or perhaps within just a few days, with little or no need to pay high closing costs.  By comparison, a conventional real property mortgage likely requires a month or more, as well as thousands of dollars of expense (including legal fees) to arrange.  Similarly, a conventional foundation takes longer and is more expensive than the typical way to site an MH structure.  Thus, the immediate economic incentives for both the MH dealer and the purchaser are very slanted towards the quicker and cheaper alternative of a structure-only loan without a full foundation.  It is important, then, right at the point of purchase, for there to be education about the options available, and how the real property alternative, even if more complicated initially, can be more attractive over the long term.   After all, 20 percent of all MH owners go this route, so the right educational approach could well increase this.  There is no obvious silver bullet here, but the IAC beginning to do homework on ways to reduce the upfront fee costs and time required to do MH real property financing (possibly via standardization) would be a good place to begin increasing the 20 percent.
6. The IAC should use its convening power to develop specific targeting that would make it more likely that state legislatures (and possibly some localities) would include MH and MHCs in their efforts at single-family zoning reform.  It is noteworthy that to date MH has not been included in such reform efforts, despite its low price points, which is indicative of both its poor reputation and the fact that “MH” or “MHCs” are very broad designations that cover too wide range of residences.  Thus, in my view, there will need to be thoughtful targeting of exactly what type and configuration of MH makes sense to include in zoning reform proposals in order to make such reform politically acceptable.  The IAC can, for example, hold local listening sessions around the country to determine what targeting specifics could garner broad political appeal.  Examples of such targeting might include:

a. Requiring that MHCs be resident-owned. 

b. Requiring a “strong HOA”²³ to help assure the proper maintenance and appearance of MHC common areas. 

c. That each MH structure be a cross-mod,²⁴ with at least a certain percentage of the value coming from the additional site-built features rather than the core MH unit.

The result ideally would be specific proposals (to be well-circulated within housing policy circles) that include inputs from MH proponents and also reflect the concerns about disruption in existing single-family-zoned suburbs.  This would make it more likely that single-family zoning reform would include MH.

7. The government mortgage lending agencies should support MHCs, when coming up for sale, being bought by their residents.  When own-rent MHCs, the most common type, come up for sale – regardless of whether the current or proposed community owner is a mom-and-pop or an institutional investor – there is a current policy movement for state-level legislation to require a period to allow residents to develop the financing to purchase the property themselves.  As this would turn an own-rent configuration into what is, in essence, an own-own one, it makes much sense for the government mortgage lending agencies to support it to create a more advantageous form of homeownership for residents.²⁵ This should consist of the multifamily operations of those lenders (which handle loans to community owners) working with non-profits and others to develop a standard offering to help residents who might lack a great deal of financial capacity to purchase the property.  This effort would likely take the form of the government agency making a senior secured loan, along with either or both government and non-profits providing some sort of subsidy to allow the lower-income tenants typically living in an MHC to be able to afford the purchase.

Such initiatives are already underway at the two GSEs, as part of their Congressionally-mandated “duty to serve” plans, as implemented by the FHFA.  The nature of such one-off transactions (and the general need for government or non-profit subsidy) means this has not had a significant volume to date; perhaps the IAC gathering the additional resources of HUD and the Department of Agriculture to support it could increase its track record of successful transactions. 

8. The IAC should challenge the chattel lending industry to develop a mechanism to ensure that, should the government mortgage lending agencies (primarily the two GSEs) fully enter the chattel market as the industry desires, any benefit of lower financing costs will accrue to the borrower rather than have too much of it go instead to enhancing primary market lender profit margins.  As already described, the GSEs entering chattel lending will not, as claimed by some MH supporters, deliver a major reduction in rates or vastly improved terms, largely because the loans will not qualify for the TBA market.  But a modest benefit is possible, and given the low incomes of many MH residents, they are certainly a reasonable group to target to enjoy this benefit.  The challenge then is to ensure that the benefit reaches those residents, rather than being heavily absorbed by increased lender profit margins.  The burden of developing such an enforceable mechanism should be placed squarely on the chattel lending industry by the IAC.  If the industry can create it, then the GSEs adding chattel lending to its product line seems reasonable; if it cannot be developed, the GSEs should maintain the status quo of only doing real property MH lending. 
9. The IAC should focus on rent-rent MHCs as a way to increase the stock of very affordable housing in less-dense geographies.  The IAC should do this because it has the potential to significantly expand housing affordable to the lowest-income families without using government subsidy dollars.  Given that such rent-rent MH has not been an area of policy emphasis, the IAC will likely have to start from such fundamentals as developing the necessary data for policymaking and engaging with the MH industry, current landlords, and non-profits to understand the barriers to expansion.  It can then develop a strategy to increase MH’s current five percent share of the rental market.  Such a strategy could include developing a specialized financing product from the government mortgage agencies and sponsoring competitions for new designs of rent-rent MHCs, among others.

Conclusion 

This three-part series has shown that MH is already a good source of affordable housing for those who are real property owners or pure renters (i.e., rent-rent residents), and therefore looks to expand those ownership configurations.  It has also shown that the other ownership configurations – in particular any form of own-rent residency, currently the most common – are problematic, and so looks to implement policies that will, on average, more effectively deliver the social and economic benefits of conventional homeownership to such residents, i.e., less exposure to landlord-generated housing instability (due to excessive rent increases or lease non-renewal), and greater family net worth (through likely eventual capital appreciation on the value of the property).  However, the analysis has also clarified that MH is much more complex than traditional rental or owned housing, and so solutions must be very highly researched and targeted, with the full recognition that any changes will be challenging and take time.

This Part 3 largely calls for a leadership group to “work the problem” from multiple angles over an extended period of time to better bring the benefits of MH to the low- and middle-income families who are most pressed by the lack of affordable housing.  It specifies nine targeted recommendations that range from addressing physical challenges (e.g., how to get more real-property foundations in place under existing MH units), to redefining legal structures (e.g., turning resident-owned MHCs into condominiums), to changing consumer behavior (e.g., new MH purchasers seeing more clearly why it makes sense to go through the expense and trouble of making their MH a real property one).   I also turn the chattel lending industry’s push for the GSEs to purchase their loans back to the industry itself to develop some enforceable mechanism so that any benefit accrues to actual residents, rather than mainly increasing lender profit margins.  For the lowest-income families, I look to expanding rent-rent MH as a way to meet their more significant affordability needs. 

The result is anything but a silver bullet or quick fix.  But faithful execution of improving MH in the ways suggested herein could really better the lives of many of the lowest-income families in America on an efficient and long-term basis. 

Footnotes

[1] “Owner” in this case includes both own-own and own-rent MH, as described in Part 2, where the latter is really a hybrid, combining ownership of the structure with rental of the underlying land. 

[2] The long-term data on the market share of MH production shows that it is significantly volatile and that its share previously was significantly higher.  For more background, see https://www.urban.org/sites/default/files/2022-07/The%20Role%20of%20Manufactured%20Housing%20in%20Increasing%20the%20Supply%20of%20Affordable%20Housing.pdf. 

[3] Freddie Mac, Fannie Mae, the Federal Housing Administration (FHA), and the U.S. Department of Veterans Affairs (VA).

[4] The price at which loans are purchased by the four government mortgage agencies do reflect taxpayer subsidies, but which are hard to value as they are indirect.  

[5] Some MH configurations fit neither of these categories – for example, additional residences provided by MH structures sited on a family farm.

[6] For example, some retirement-oriented MHCs are known for their amenities, which can include a community pool, tennis courts, or even a clubhouse for social activities. 

[7] Some of the MHC variations are:  (1) the structure is owned by the resident, but the land is rented from a commercial, for-profit landlord; (2) the structure is owned by the resident, but the land is rented from a non-profit landlord, such as a community land trust; (3) the structure is owned by the resident, but the land is rented from a company that is in turn owned by all the residents (a “resident-owned community,” or ROC);  and (4) the structure is owned by the resident, but the land is rented from a company that is in turn owned by only a portion of the residents (also considered a type of ROC).

[8] As reported in “2022 Manufactured Housing Facts” by the Manufactured Housing Institute, the average MH unit is 1,497 sq. ft., 41 percent smaller than the average for a site-built home of 2,544 sq. ft.  (see https://www.manufacturedhousing.org/wp-content/uploads/2022/04/2022-MHI-Quick-Facts-updated-05-2022-2.pdf), and calculated from the average cost and average cost per square foot statistics cited.

[9] The transportation and installation costs for MH structures must be included in this calculation for any specific MH unit, as they can vary tremendously given travel distance from the factory.  

[10] However, the quality of materials and construction techniques currently used for MH units in the higher half of the MH price range are roughly equal to that of the lower range of site-built, limiting the savings in costs over site-built housing. 

[11] This can also reduce the expected lifespan of the unit. 

[12] To a family with limited income, an MH purchase combined with rental of the underlying land is particularly “affordable” simply because the land does not have to be purchased and, instead, includes a monthly rental requirement.  Thus, the purchase price for the structure is not a complete picture of affordability, as the burden of the monthly rental payment must be considered as well. 

[13] This is totally conventional and common.  For example, in the purchase of a car (the second largest expenditure a typical family makes), lower price point cars have seating covered in fabric rather than the leather found in more expensive models, and interior surfaces made of plastic rather than the wood of more expensive cars.  “You get what you pay for” is the norm; free lunches are unusual. 

[14] The industry belief is that real property MH today is at the high end of MH in terms of price and quality.  So, such a structure-plus-land MH unit will still have a lower price point than site-built homes due to factory production efficiency and very possibly smaller square footage, but the total cost savings would be higher for the average quality MH home, which has the added cost advantage by using somewhat less expensive materials.

[15] For an explanation of the TBA market, see Part 2. 

[16] For example, an increase in the overall homeownership rate – which has been the object of policymakers for many decades, backed by many programs and billions of dollars of annual subsidies and spending – has hardly changed in the last 50 years. (Specifically, the homeownership rate was 64.4 percent in Q4/1972 and 65.9 percent in Q4/2022.)  https://fred.stlouisfed.org/series/RHORUSQ156N. 

[17] Resident-owned MHCs are appropriately placed in the “own-own” category. 

[18] A resident-owned MHC is in many ways analogous to condominium housing, which has both directly owned assets (e.g., an apartment) mixed with shared ownership of commonly-used assets (hallways, amenities, parking structure, etc.).  This is further discussed below.

[19] See a recent summary of such efforts, which demonstrates both its hard-fought nature and its careful targeting, in “A State-by-State Guide to Zoning Reform,” from Anthony Flint at the Lincoln Institute of Land Policy, December 23, 2022.  https://www.lincolninst.edu/publications/articles/2022-12-state-by-state-guide-to-zoning-reform.  The absence of MH in the piece is noteworthy.  I also note the recent failure of legislation overriding local zoning in New York State. 

[20] Any change in what type of foundation is considered adequate for a real property designation must be acceptable to lenders who rely on the land and the structure together as collateral.  Simply designating existing MH structures on land owned by the MH resident as real property because MH structures rarely move seems insufficient for lenders to treat them as such. Instead, the foundation must make actually moving the structure just as difficult as it is for a typical site-built structure to be moved (which is extremely difficult to do).

[21] Residential condominiums are characterized as having direct ownership of the individual apartment or townhome but also shared ownership of common areas and amenities, with an HOA to manage it all.  They did not exist until state laws were changed to accommodate them, mainly beginning in the 1960s; federal legislation was later required to make them eligible for government agency mortgage financing just like any individual home.  Prior to that, cooperative apartment houses existed in much smaller numbers, and mainly in a few eastern cities (New York City still has many of them). 

[22] It is unclear if changes in state laws might be required to permit retrofit MH to count as real property condominiums in this manner.  Ditto for federal legislation that permitted the four government agencies to lend against condominiums as collateral.  More research is needed on the topic. 

[23] A “strong HOA” would need a lot of definitional work by the IAC that is beyond the scope of this paper.

[24] “Cross-mod” is a term used in the MH industry to describe a building that includes the factory-produced MH unit plus site-built additional features, such as a garage or a porch, connected to the MH unit to create the appearance of a structure that looks more site-built and less of an MH nature.

[25] As described above, combining this with later converting it into a condominium legal form would be a homeownership home run for the residents.