MH Foundation vs Perimeter Enclosure

[Dale Floyd]

I have a question arising from a recent encounter witnessed between a peer appraiser, a lender, and engineer pertaining to a MH appraisal. This was an FHA appraisal.

The MH had a vinyl skirt, only attached to a J-channel around the perimeter of the double wide with no backing. Appraisal was correctly made subject to the engineer's report pertaining to the foundation being qualified as permanent. The engineer stated the foundation was permanent, while the appraiser noted the lack of proper backing and support of the vinyl skirt as being a defect. Obviously, the engineer's report seems contrary when reading Chapter 5 of the PFG, so a conference call was made between the lender and engineer who stated the foundation inspection and qualification does NOT include the perimeter skirting for purposes of FHA. Engineer stated the foundation report only reflects the anchoring and piers underneath. Lender states the appraiser cannot require the perimeter wall to comply with anything.

I will admit to having a bit of confusion.

At one time, the skirt/perimeter enclosure had to be solid or attached to something solid for the foundation to be considered permanent. I'll admit that was back when I did FHA which was a long time ago. I've read the current PFG and I see nothing to alter my opinion, especially after re-reading Chapter 5. Other appraisers I've spoken with say I'm reading it incorrectly. Perhaps I'm missing something.

Anybody else out here have a coal to throw into the fire of discussion? The 4000.1 certainly lacks clarity about this in my view.

 

[BRCJR]

RSW is best I know for FHA/HUD questions...maybe he will chime in.

 

[Zoe]

That's HUD. You need to call them. I don't know in TN. Weather is cold here sometimes. I don't really know what HUD requires or local code requires. I could see possible pipe freezing issues but I don't know.

 

[Zoe]

In Shelby County, I am not even sure you can do a mobile home or modular home anymore. You may have been grandfathered.

I know middle TN and east TN and some parts of west TN are different.

 

[Zoe]

Call HUD. Don't fork with them. Especially right now.

 

[Lil Rhody]

If the skirting isn't load bearing it needs to be permanently attached to some sort of backing that is either TP wood, concrete or a similar type of backing. If not, it is an MPR deficiency. From what you described; it sounds like this is an issue.

 

[Zoe]

Many places in TN have no zoning whatsoever. If code enforcement is there. Call them too.

 

[Zoe]

If the skirting isn't load bearing it needs to be permanently attached to some sort of backing that is either TP wood, concrete or a similar type of backing. If not, it is an MPR deficiency. From what you described; it sounds like this is an issue

Okay. I can read between the lines. I am not the client or guarantor.

 

[andrew81]

FHA Handbook 4000.1 issued 10/31/2023 and this section was last updated 02/16/2021

II. ORIGINATION THROUGH POST-CLOSING/ENDORSEMENT
D. Appraiser and Property Requirements for Title II Forward and Reverse Mortgages
5. Property Acceptability Criteria for Manufactured Housing for Title II Insured Mortgages
c. Foundation Systems
ii. Existing Construction for Manufactured Housing

(A)Definition
Existing Construction for Manufactured Housing refers to a Manufactured Home that
has been permanently installed on a site for one year or more prior to the case number
assignment date.

(B) Standard
If the perimeter enclosure is non-load bearing skirting comprised of lightweight
material, the entire surface area of the skirting must be permanently attached to
backing made of concrete, masonry, treated wood or a product with similar strength
and durability.

(C)Required Analysis and Reporting
If the Manufactured Home foundation does not meet the requirements for Existing
Construction, the Appraiser must notify the Mortgagee and report the deficiency in
the MPR.

 

[Dale Floyd]

Thank you Andrew. I've also read that section several times, but therein is the rub.

Section (C) says the appraiser must notify the Mortgagee and report deficiency about the foundation. But all FHA appraisals involving MH's must be made subject to an engineer's inspection, not the appraiser's opinion, pertaining to the foundation.

If the engineer states the MH meets HUD requirements for a permanent foundation, but the lightweight material skirting is NOT affixed to concrete, masonry, treated wood, or a product with similar strength and durability, there's apparently going to be a fight if the appraiser points that out. Even some out here might say it doesn't matter if the engineer says it passes. Perhaps that's true today, but it wasn't that way back in the day.

Chapter 5 of the PFG states the structural requirements include the support of the exterior walls if they are load bearing. Support of load bearing walls are part of the foundation. Aren't all exterior walls of a double wide load-bearing?

I think they could have written the rules a little more simplistically. I'm glad I don't mess with these anymore.