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Disagreement with County and Lender on FHA Assignment

ilikethings

Freshman Member
Joined
Jun 30, 2020
Professional Status
Certified Residential Appraiser
State
Colorado
Hi there!

I’m working on an FHA rural assignment for what I believe is a manufactured home. The county lists the home as modular and has no record of purging, home has been re-sided and remodeled so no HUD tags or Data Plate, but also no Modular Installation cert from the State of Colorado. Additionally it has a basement with obstructed ceilings in a few areas, so searching the framing for HUD data couldn’t be done.

Attached photos are why I’m certain it’s manufactured. Belly wrap and metal framing are visible on the undercarriage, and axle mounts are visible poking through the ceiling material in a lower level bedroom. I’ve been appraising both manufactured and modular homes for about 6 years, and I’ve never seen a modular with axle brackets and metal framing.

8BB75077-EC53-41F9-91C1-C1411B819F92.jpeg
BCFEA5DD-FF0B-4B00-AB6A-B8E9DC33D692.jpeg
Anyone here seeing this and thinking modular? Because I just don’t see it, but the Client and I are at a total stalemate here. They won’t order an IBTS letter given the county stating it’s Modular, but I see zero evidence other than what the county lists. I was also provided a prior FHA appraisal which was a standard 1004 listing the home as a “Ranch”, no mention of even Modular construction, so the Lender is pretty content in thinking I’m a dullard.

Any assistance is appreciated, but I’m having a hard time going against my gut on an FHA assignment to just assume the County and prior report are accurate, given my experience.

Thanks!
 

Terrel L. Shields

Elite Member
Gold Supporting Member
Joined
May 2, 2002
Professional Status
Certified General Appraiser
State
Arkansas
As highly regulated as Colorado is, then the county planning board or whomever, should have the original application to the dwelling and whether is is HUD code or has a local building ordinance Certificate of Occupancy. Are there any counties left in the state that doesn't require approval to build everything. Crap. You can't even change out your own water heater. I knew people in Colorado that would drive to Farmington NM and buy a water heater in Lowes and install themselves saving about $500.
 

RSW

Elite Member
Joined
Feb 18, 2002
Professional Status
Certified Residential Appraiser
State
Tennessee
It could be a modular on frame & not a mfg home. The axle mounts are odd if it is a modular. How old is the dwelling?
 

ilikethings

Freshman Member
Joined
Jun 30, 2020
Professional Status
Certified Residential Appraiser
State
Colorado
It could be a modular on frame & not a mfg home. The axle mounts are odd if it is a modular. How old is the dwelling?
2000 actually, so it doesn’t seem like modular on frame would be the case. And yeah, the axle mounts are normally a dead giveaway.
 

Tom D

Senior Member
Gold Supporting Member
Joined
May 22, 2015
Professional Status
Certified Residential Appraiser
State
Pennsylvania
i go not modular, but i suppose if the lender gives you an email saying it is mod, and the county says it is mod then you could say modular, but comment that it may not be.
how would you get into trouble. you have the lender & county who say it is. ok it is, but there is a possibility that it may not be. there could be a problem if it really is, and you keep saying it's not. that is a consideration you should also think about. and is this a good client you want to keep?
so you go with mod. but, in your addendum state what you exactly saw, and you are unable to determine if it is not. keep that good work file.
here is what FHA now says, they are usually the most strict:
Site Inspection: It should be noted that the term "inspection" as it relates to the services performed by an appraiser, are merely observations. Any time the word inspection is used in this report it generally means "observation". The appraiser's observations should in no way be construed as anything more than a visual impression of the systems performance that can be carried out by any party without the benefit of specific training or knowledge. The appraiser's visit to the site should not be construed as a Home Inspection. As with the purchase of any real property, a complete home inspection by a qualified home inspector is strongly recommended.
 

DWiley

Elite Member
Joined
Apr 4, 2007
Professional Status
Certified Residential Appraiser
State
Tennessee
One must avoid the temptation to make judgements about modular vs manufactured based on the physical characteristics of the improvements. It is the code that the home was certified to that is the key. not the features/characteristics of the home itself.

I once had the opportunity to tour a factory that built such homes. At one point we looked at two units that were almost finished and were virtually identical. One was a manufactured home (because it was certified to the HUD code) and one was a modular (because it was going to be certified to the local code), even though they were virtually identical physically.
 

TerryRohrer

Junior Member
Joined
Aug 13, 2005
Professional Status
Certified General Appraiser
State
Montana
I was thinking on-frame modular too, but here is a crappy photo of the only one I have encountered and it shows the frame within the belly wrap. I would be inclined to stick with your position until someone provides you with documentation. I would not be swayed by lender, county, prior appraisal, or anything you have mentioned so far. Clearly, it is not site built, so at one time there was a way to know what it was. I would hold out for that or walk away as it will be all your baby when the loan goes bad. The lender's response, as you are being hung, will be, "well, we would never have made this loan if the expert appraiser hadn't told us it was a modular home."
 

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glenn walker

Elite Member
Joined
Oct 11, 2006
Professional Status
Certified Residential Appraiser
State
California
I was thinking on-frame modular too, but here is a crappy photo of the only one I have encountered and it shows the frame within the belly wrap. I would be inclined to stick with your position until someone provides you with documentation. I would not be swayed by lender, county, prior appraisal, or anything you have mentioned so far. Clearly, it is not site built, so at one time there was a way to know what it was. I would hold out for that or walk away as it will be all your baby when the loan goes bad. The lender's response, as you are being hung, will be, "well, we would never have made this loan if the expert appraiser hadn't told us it was a modular home."
Question on FHA we always call for an - Engineers inspection and report and he certainly knows a Manufactured from a Modular so four $250--$300 bucks in my area that would kill two birds with one stone- The Underwriter then has an -engineers report and so does the appraiser . As far as County and assessor both often intertwine the two and in my County often a Manufactured with HUD tags will be assessed for tax puposes as a Modular. So I am hesitant to automatically go with the Country designation--BUT - I am thinking making it Subject to an Engineers physical inspection and-report may solve the question ?
 

Jayjay25

Sophomore Member
Joined
Oct 9, 2013
Professional Status
Certified Residential Appraiser
State
Connecticut
It’s should be pretty easy to determine if it’s a modular home. The center wall (marriage wall where the two halves come together) on a modular home will be thicker than the other walls. Check the hallways. The marriage wall will be 2 - 2x3 (2x6+/-) and all doors/openings not in the center/marriage wall will be 2x4. Extra thick center wall = modular.
 

Dublin ohio

Senior Member
Joined
Mar 20, 2008
Professional Status
Licensed Appraiser
State
Ohio
It’s should be pretty easy to determine if it’s a modular home. The center wall (marriage wall where the two halves come together) on a modular home will be thicker than the other walls. Check the hallways. The marriage wall will be 2 - 2x3 (2x6+/-) and all doors/openings not in the center/marriage wall will be 2x4. Extra thick center wall = modular.
Doublewides also have a thick wall where they come together
 
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