The Modular Home Builders Association (MHBA) has filed formal comments with HUD’s Manufactured Housing Consensus Committee opposing a proposal to eliminate the steel chassis requirement for second-story HUD-code manufactured homes. In a letter authored by Executive Director Tom Hardiman, MHBA warns that removing this structural component would blur the line between federally regulated manufactured housing and state-inspected modular homes, undermine consumer confidence, and create an unfair regulatory advantage for HUD-code producers.
Background
Since 1976, HUD’s National Manufactured Housing Construction and Safety Standards Act has ensured that factory-built housing meets rigorous federal safety, quality, and affordability standards. MHBA’s comments emphasize that the steel chassis is integral to protecting homeowners during transportation, installation, and in extreme weather events.
MHBA’s Key Concerns
Consumer Confusion & Market Impact: MHBA highlights the “Cross Mod” marketing tactic—where HUD-code homes are relabeled to appear more “modern”—as evidence that small terminology changes can mislead buyers and negatively affect resale values for existing modular homeowners.
Regulatory Fairness: By removing the chassis requirement, HUD-code manufacturers could bypass the stricter state and local inspections imposed on modular builders, leaving consumers uninformed about differences in build quality and long-term performance.
Safety & Structural Integrity: The steel chassis provides critical support against wind, seismic forces, and load stresses. MHBA argues that removing this component would compromise a home’s ability to withstand natural disasters.
“At a time when severe weather events and natural disasters are on the rise, it makes no sense to remove structural safeguards that protect families and homes,” Hardiman writes. “Modular housing already offers a safer, more durable solution—with consistent state-level oversight—for buyers willing to invest a modest premium.”
MHBA represents over 150 member companies that build to IRC and state-compliant modular standards.