National Initiatives and News

The 21st Century ROAD to Housing Act included important language reaffirming HUD's authority

over manufactured housing construction and energy efficiency standards. However, there still exists

conflicting statutory language from the 2007 Energy Independence and Security Act (EISA)

requiring the Department of Energy to also establish energy efficiency standards.

The Affordable Housing Over Mandating Efficiency Standards Act (H.R. 5184) -Affordable HOMES

Act - would address this latter issue by reforming Section 413 of the EISA so the Department of

Energy may provide technical recommendations on manufactured housing energy standards while

HUD retains final authority through the established HUD Code process.

This is a bipartisan, pro-affordability approach. It preserves a meaningful advisory role for DOE,

supports practical improvements in energy performance, and restores the regulatory clarity needed

to build more attainable homes. The House passed the bill 263-147 on January 9, 2026.

When this legislation was considered in the House, some Members expressed concern that

eliminating DOE's overlapping authority could delay future energy-efficiency improvements.

Congress addressed that concern through the provision in the 21st Century ROAD to Housing Act,

which requires HUD to adopt updated manufactured housing energy standards within one year and

to continue updating those standards at least every three years. In addition, the Manufactured

Housing Consensus Committee has already completed its work and forwarded consensus

recommendations to HUD.

Congress should make a narrow technical correction to the Bankruptcy Code so a loan secured by a manufactured home that is the borrower's principal residence receives the same protection from modification in Chapter 13 as a mortgage secured by a site-built home or a manufactured home titled as real property. 

Manufactured homes may be placed on land owned by the homeowner or on leased land. A home on leased land is commonly financed with a home-only loan secured by the home rather than the underlying land. In 2005, Congress amended the definition of a debtor's principal residence to include a manufactured home regardless of whether it is attached to real property, but it did not make the corresponding conforming change to 11 U.S.C. section 1322(b)(2). Courts have therefore reached outcomes that permit modification of some home-only loan balances even though comparable principal-residence mortgage loans are protected. 

The correction should be limited to principal residences and should preserve all other consumer protections in bankruptcy. Equal treatment would give lenders greater certainty in valuing collateral, reduce pressure on the cost and availability of credit, and prevent the form of title or land tenure from determining whether an affordable homeowner can obtain financing. 

If left unaddressed, these recent court precedents threaten to undermine access to affordable credit for buyers of manufactured homes by making it impossible for lenders to reliably value collateral. The result would be sharply reduced loan availability and increased borrowing costs for future homebuyers. 

Manufactured housing harnesses the efficiencies of factory-building and a federal construction code to create innovative and desirable homes for Americans at attainable prices, in other words, quality homeownership without compromise. 

However, restrictive and discriminatory zoning and land-use laws created from outdated stereotypes and misconceptions about manufactured housing limit where manufactured homes can be placed, lessening attainable homeownership options. 

Recent actions by Congress and the Administration demonstrate a growing attention to the harms discriminatory zoning laws have on housing supply. The 21st Century ROAD to Housing Act contains several provisions that support zoning and land-use modernization and can improve opportunities for manufactured housing. HUD published their State and Local Best Practices for Home Construction which encourage states and localities to remove unnecessary burdens, reduce costs, and accelerate housing construction. 

Manufactured housing is the only major form of single-family housing built to a uniform, preemptive federal construction and safety code. That national framework creates regulatory efficiency and economies of scale, but its housing-supply benefits are lost when local governments repackage construction-based exclusions as placement requirements or apply standards that are not identical to the HUD Code. 

Congress recently reaffirmed manufactured housing as part of the national strategy to expand housing supply. Stronger implementation of existing preemption authority would leverage that intent without displacing legitimate, construction-neutral local land-use rules. 

Federal housing finance programs should reflect today's manufactured housing market and support both land-home mortgages and home-only loans. HUD should promptly implement and build on recent reforms to FHA Title I, update FHA Title II guidelines so HUD Code homes are treated consistently with other eligible single-family housing, and ensure program rules do not unnecessarily restrict manufactured housing. 

Changes that are essential to restore FHA Title I as a viable home-only loan program include: 

• Align FHA manufactured home definitions with HUD Code definitions;
• Allow an adequate loan origination fee;
• Allow financing of closing costs; and 
• Align FHA Title I underwriting standards with Title II standards.

Changes that need to be made to FHA's Title II program to support land-home financing include: 

• Incorporate the HUD Code's model minimum installation standards; 
• Revise the requirements for manufactured homes in flood zones; and 
• Lift the prohibition against financing for relocated homes. 

Congress should also strengthen the Duty to Serve requirement so Fannie Mae and Freddie Mac provide meaningful, measurable support for manufactured housing, including responsible participation in the home-only loan market. Enterprise activity should expand sustainable consumer choice and complement, rather than displace, specialized lenders already serving this market. FHFA should set transparent purchase goals or benchmarks, require useful public reporting, and evaluate performance based on actual market impact. 

Manufactured housing communities are a vital component of the nation's housing infrastructure and one of the most effective pathways to attainable homeownership. These communities provide quality, stable housing for millions of Americans, enabling families to purchase homes at prices far below those of many other housing options while helping address housing supply challenges. Their continued availability depends on private owners, operators, and investors who have developed, maintained, improved, and preserved these communities over time, creating housing opportunities that remain within reach for working families, retirees, and first-time homebuyers. 

Federal efforts to preserve manufactured housing communities and support long-term affordability can be valuable. However, federal preservation resources should not be redirected to promote or favor the conversion of privately owned communities into any particular ownership model. Federal policy should focus on preserving affordable housing opportunities and protecting residents, not privileging one ownership structure over another. 

When public funds, subsidized financing, grants, tax incentives, technical assistance, or other federal support are provided in connection with community conversions, policymakers should ensure that residents receive a direct, legally enforceable, and appreciable economic interest in the land or in the entity that owns it. Policymakers should distinguish between meaningful resident equity and arrangements that provide governance participation but no appreciable ownership interest, and should evaluate programs based on measurable resident outcomes rather than ownership labels alone. 

Policy should also recognize that homeownership and wealth-building can occur in well-operated land-lease communities. Manufactured homes can appreciate in value even when the homeowner leases the homesite, particularly where professional management, stable community operations, maintenance, amenities, and transparent lease practices support demand and healthy resale activity. 

HUD currently charges a $100 certification label fee for each transportable section of a manufactured home. Those industry-paid fees are intended to support administration of the federal manufactured housing program. Yet HUD projects a substantial and growing carryover balance while continuing to receive annual resources for the program. The Office of Manufactured Housing Programs' reserves are projected to reach approximately $34 million in 2027, raising questions about whether current fee levels remain aligned with the program's actual administrative needs. 

Congress should direct HUD to reassess the fee against the program's actual, documented administrative needs and reduce it accordingly, potentially by up to 50 percent. HUD should report annually on fee collections, obligations, expenditures, planned uses, and carryover balances, and should explain how each activity aligns with the statutory mission of administering and updating the HUD Code. 

This review is particularly important given Congress' recent efforts to expand manufactured housing production and remove barriers to housing supply. Congress has directed HUD to update energy standards and implemented reforms intended to support greater manufactured housing production and innovation. As production increases, label fee collections will also rise, creating the risk that HUD's reserves will continue to grow beyond what is necessary to administer the program unless the fee structure is adjusted appropriately. 

A right-sized fee would provide direct savings in the production of affordable homes, prevent the unnecessary accumulation of industry-paid funds, ensure that future increases in manufactured housing production do not result in excessive reserve balances, and keep HUD resources focused on core responsibilities such as code updates, standards development, enforcement, and program administration.