Manufactured housing in the ROAD to Housing Act: the chassis rule and what else changed

What changed: the permanent chassis requirement

Section 301(a) is one line long. It replaces “on a permanent chassis” with “with or without a permanent chassis.”

The National Manufactured Housing Construction and Safety Standards Act of 1974 defines a manufactured home as a structure transportable in one or more sections, at least 8 feet wide or 40 feet long in transit or 320 square feet once set up, designed as a dwelling with or without a permanent foundation. Until July 2026 it also had to be “built on a permanent chassis.” That definition decides which homes are built to the national HUD code, and it is also what many state title, tax and zoning laws point to.

HUD’s rules define the chassis as the whole transportation system: drawbar and coupling, frame, running gear and lights. It counts as permanent when the frame stays under the home after installation, usually as two steel I-beams. The wheels and hitch come off; the steel stays. That is the requirement Section 301 ends. It kept homes low and wide, made two-story designs awkward, and cost thousands of dollars of steel a home.

How many thousands is disputed. The Niskanen Center estimated $5,000 to $10,000 a home. In a June 2026 proposed rule, HUD reported manufacturers’ estimates that a chassis on an upper floor adds $4,776 to $6,672 to what a buyer pays. At HUD’s showcase in September, Cavco’s chief executive, William Boor, told HousingWire the company was “not really viewing it as a big cost savings element” but as a product innovation, since some of the savings go into other materials and installation.

When chassis-free homes can be built: HUD’s standards

The definition changed on July 11, 2026. The construction standards to build to have not been written.

Section 301(b) directs HUD to issue revised standards for homes built without a permanent chassis, through the same process it uses for every change to the HUD code: proposals from the Manufactured Housing Consensus Committee, a public comment period, and a final rule. The standards must give chassis-free homes three things that set them apart from homes on a chassis:

• a distinct HUD label, with the fees going to the Manufactured Housing Fees Trust Fund;
• a distinct data plate, the notice inside the home that records how it was built; and
• a distinguishable notation on the manufacturer’s invoice.

The law sets no deadline for these standards. Other parts of Title III have one-year clocks; this one does not. HousingWire reported that HUD rulemakings typically take 18 to 24 months to finalize, and that after they do, manufacturers still have to get each chassis-free design approved by a HUD-approved inspection agency before production.

HUD had already started on part of this before the Act passed. A proposed rule published June 12, 2026 would let the upper-floor sections of a multistory manufactured home be built and shipped without a permanent chassis, reading the old definition as requiring a chassis for the home, not every section. Comments closed August 11, 2026. As of September 29, 2026, a search of the Federal Register found no final rule, and no proposed standards under Section 301(b).

Cavco displayed what HousingWire described as the first HUD code home without a permanent chassis, the Grande Arbor, at HUD’s Innovative Housing Showcase on the National Mall on September 22 to 24, 2026.

What states must do: certify by July 11, 2027

The federal definition changed. Many states define a manufactured home in their own law, often with the chassis in it.

Section 301(c) requires every state to certify to HUD that its laws and regulations:

• treat any home meeting the federal definition the same as the manufactured homes the state already regulates; and
• subject a home without a permanent chassis to the same laws as one built on a chassis, including financing, title, insurance, manufacture, sale, taxes, transportation and installation.

The first certification is due July 11, 2027. The four states whose legislatures meet every other year, Montana, Nevada, North Dakota and Texas, have until July 11, 2028. After that every state must recertify each year, on a date HUD sets, that no new law has changed the answer. A state can certify in its state plan, if it runs its own manufactured housing program, or through a separate attestation by an official, which may mean amending the state’s definition of a manufactured home and directing agencies to amend theirs. HUD must publish in the Federal Register, and on its website, the list of states that are up to date, and provide model guidance to help them certify.

The consequence of missing it is a ban, not a fine. If a state does not certify on time, it must prohibit the manufacture, installation and sale of any “covered” home: one built after July 11, 2026 that meets the federal definition but that the state does not count as a manufactured home because it has no chassis. In states where HUD runs the installation program, HUD and the state must both enforce the ban. HUD cannot waive it for a late certification unless it approves that certification.

The effect is that chassis-free homes arrive state by state. A state that updates its law can take them; a state that doesn’t must keep them out, rather than let them in under a definition its title and tax offices don’t recognize. Section 301(f) adds that none of this narrows the HUD code’s existing preemption of state and local construction standards.

Energy standards: DOE’s rule is off, HUD’s is due

Section 301(d) gives HUD sole control of energy efficiency standards for manufactured homes.

In 2022 the Department of Energy set energy conservation standards for manufactured homes under the Energy Independence and Security Act of 2007, with compliance dates that were later pushed back. Section 301(d)(2) provides that no federal agency’s energy efficiency standards for manufactured homes have legal effect unless and until HUD adopts them through the consensus committee process.

On September 18, 2026, DOE published a notice that, because HUD had adopted no standards, its May 31, 2022 rule “has no legal effect,” that it will not enforce it, and that it will start a rulemaking to conform its regulations to the Act.

HUD must adopt minimum energy efficiency standards for manufactured homes by July 11, 2027, and update them at least every three years after that. The Act does not say how strict they must be. Until then, the energy provisions already in the HUD code apply. Section 301(d)(1) separately lets HUD work with other agencies so that federal programs using their own definition of a manufactured home treat homes under the new definition the same way.

Section 302: modular homes and FHA construction loans

The Modular Housing Production Act asks HUD to find and fix what keeps modular builders out of FHA construction financing.

HUD must review Federal Housing Administration construction financing programs for barriers to modular building, including construction draw schedules, which release loan money as work on site progresses and fit poorly with homes that are mostly built in a factory before delivery. The report, with recommended changes, is due by July 11, 2027. Within 120 days of publishing it, HUD must start a rulemaking on an alternative draw schedule for modular and manufactured home developers, and then either issue a final rule or explain why not.

HUD may also make a grant to study a standardized uniform code for modular homes, for serializing and securing modules and tying them to financing incentives.

Section 303: new FHA Title I loan limits

The Property Improvement and Manufactured Housing Loan Modernization Act rewrites the dollar limits on FHA Title I loans.

FHA’s Title I program insures loans for home improvements and for buying manufactured homes and lots, including homes placed on leased land in a community. Section 303 writes these limits into 12 U.S.C. 1703:

Some of the old limits show how far behind they had fallen. A lot loan was capped at $23,226; it is now $43,377. Loans for buildings of two or more families rose from $60,000, or $12,000 a unit, to $150,000, or $37,500 a unit, and apartment houses were dropped from that category. Accessory dwelling units are now an eligible purpose, up to an amount HUD sets.

The limits won’t sit still. HUD must set them every year by an index it chooses by July 11, 2027, using its old indexing method in the meantime, and may reset them on a method it publishes in advance by regulation. The maximum term is now whatever HUD sets, up to 30 years. Title I loans are made by FHA-approved lenders, so whether a lender is already offering the new amounts is a question for the lender.

Section 303 also orders a HUD study of factory-built housing, due to Congress by July 11, 2027: cost, quality against site-built homes, maintenance and replacement costs over 40 years, and uses beyond single-family homes, such as accessory units, two- to four-unit buildings and large apartment buildings.

Section 304: the PRICE Act grants for manufactured housing communities

Preservation and Reinvestment for Community Enhancement: seven years of competitive HUD grants, if Congress pays for them.

Section 304 adds Section 123 to the Housing and Community Development Act of 1974, the law behind the Community Development Block Grant. It authorizes a competitive grant program for eligible manufactured housing communities: communities affordable to low- and moderate-income residents, up to 120% of area median income, that are resident-owned or will stay affordable communities for as long as feasible.

Who can apply: the communities themselves, local governments, states, housing authorities, resident-owned communities and cooperatives, nonprofits with housing expertise, community development financial institutions, tribes and tribally designated housing entities, the Department of Hawaiian Home Lands, and owner-operators working with an eligible community.

What grants pay for: infrastructure, utilities and other land improvements; repair or replacement of homes; planning; health, safety, weatherization and accessibility work; land acquisition to expand or build a community; and resident services, including relocation help, eviction prevention and down payment assistance. Homes built before June 15, 1976, when the HUD code took effect, cannot be rehabilitated with the money, only removed and replaced with HUD code housing or another type HUD allows.

HUD must prioritize projects that mainly benefit low- and moderate-income residents and keep communities affordable over the long term. It may waive rules it administers, except those on fair housing, nondiscrimination, labor standards and the environment. The program ends July 11, 2033, and can use only money appropriated after July 11, 2026. The Act names no amount. HUD has run grants under the PRICE name before, from annual appropriations; Section 304 puts the program in permanent law for seven years. As of September 29, 2026, a search of the Federal Register found no notice of funding under it.

Title III deadlines

One deadline is missing from the table because the law doesn’t set it: the HUD standards that chassis-free homes have to be built to.

Where this fits in the ROAD to Housing Act

Title III is one of 12 titles in the 21st Century ROAD to Housing Act. This site’s own work is on a different part of it: Section 210, the RESIDE Act, a grant pilot for converting vacant commercial buildings into housing, which it applies building by building to downtown San Jose, Denver and Philadelphia. The Act’s Innovation Fund also rewards local governments for removing restrictions on manufactured housing.

Questions

Sources

1. U.S. Government Publishing Office, “Public Law 119-101, Title III, Sections 301–304”
2. Legal Information Institute, “42 U.S.C. 5402, definitions (as amended)”
3. Legal Information Institute, “42 U.S.C. 5403, construction and safety standards (as amended)”
4. Legal Information Institute, “12 U.S.C. 1703, FHA Title I insurance (as amended)”
5. Federal Register, “HUD, Revising the Definition of “Manufactured Home” to Lower Housing Costs, proposed rule, June 12, 2026”
6. Federal Register, “DOE, Energy Conservation Standards for Manufactured Housing, notification of legal effect, September 18, 2026”
7. Niskanen Center, “Two big developments in manufactured housing reform: New rules, new bill”
8. HousingWire, “Putting the ROAD Act into action faces a funding and HUD gauntlet”
9. HousingWire, “HUD showcase spotlights Cavco chassis-free manufactured home”
10. Bipartisan Policy Center, “21st Century ROAD to Housing Act Implementation Tracker”

More on the law: The ROAD to Housing Act explained · Environmental review changes · CDBG and HOME changes · Opportunity Zones · The Innovation Fund · The Build Now Act · How RESIDE grants should be sized