The underwriter has two paragraphs of Section 304 confused and jumbled together. In the second paragraph of 304 is the comment: " A manufactured housing unit must be legally classified as real estate, must be permanently affixed to a foundation, and must assume the characteristics of site built housing to be eligible as security for a mortgage that is delivered to Fannie Mae".
Just because it has assumed the characteristices of site built housing (wheels, axles, hitch removed, perimeter enclosure) does not mean it has the same market appeal as site built housing. The marketability and comparability (as pkbarnhardt quoted from the 304) is a separate issue.
I usually have a statement in my reports similar to as follows: "Wheels, axles and tongue have been removed from the unit and it is installed above ground level (or at ground level) per state requirements for a foundation. Footings appear to be below the frost line (frostline is the top of the dirt in my area-otherwise I would not comment on the frostline) and a concrete block (or whatever) perimeter enclosure has been installed. Improvements constructed after the HUD building codes developed. Improvements have the design and characteristics of site built housing due to its hardboard siding, and pitched composition shingled roof." (statement is revised if an older mobile home, not built to HUD code, with aluminum siding and roofing) That covers the paragraph in the 304 quoted above.
Then typically all my comparables are other manufactured homes, also built to HUD code. If one or more of the comparables built prior to June 15, 1976, I comment about that comparable being built prior to the adoption of HUD code--usually have an adjustment also. Once in a great while, the manufactured home will be top of the line with a lot of bells and whistles, 2" x 6" construction exterior, 2" x 4" interior walls, vaulted ceilings, drywall interior throughout, etc, etc, etc so I might also use one site built comparable--which has a downward adjustment in my market and lots of description. This paragraph takes care of the part of 304 that pkbarnhardt quoted.
I did an analysis of my two counties several days ago and realized that approximately 30% of the residential properties in my area are manufactured homes and old mobile homes. My area does not have building codes, I would make a guess that half of the on site built homes in the area would not meet building codes if they were enforced. FHA and VA financing is not too common here. FMHA financing is very common in several of our tract subdivisions (the only tract subdivisions in the area). A lot of site built homes in the area were built by owner or added on by owner without any inspection by any building inspector or advice from a licensed contractor. So quite frequently the manufactured home built to HUD code is superior in construction quality to the site built, but people refuse to live in a "trailer" and buy the homeowner built home with crooked walls, patched together electrical wiring, poor floor plan, etc, and pay more than what the resale manufactured home on site with porches, covered parking, landscaping would have cost them. My area also has a per capita income of less than $25,000 a year and majority of residents can't wait two to three years for a home to be built or afford the construction costs of a new on site built home.