FHA SFH HANDBOOK 4000.1 MANUFACTURED HOMES · II.D.4 REV. 03/2024 SCAPULAR ENGINEERING, P.E. · MO · (573) 275-7647
HUD 4000.1 II.D.4.bSIX REQUIREMENTS

Six requirements /
six findings.

FHA underwriters operate from the HUD 4000.1 II.D.4.b checklist. Every report we deliver addresses each requirement in the order the handbook expects, with the matching reference code, the determination, and the supporting photo evidence indexed by finding number. This page is the long form of that checklist — what we verify, what we find, and how it gets documented.

REQ 01 OF 06 / PERMANENT FOUNDATION REF · HUD 4000.1 II.D.4.b.i · PFGMH § 3

Permanent foundation.

The foundation system meets HUD's Permanent Foundations Guide for Manufactured Housing, § 3 — pier specifications, footings, soil bearing, frost depth, and anchoring. This is the engineering core of the entire FHA structural inspection.

What we verify

Six structural elements

  • Foundation type — pier & beam, perimeter wall, slab-on-grade, or basement, photo-confirmed
  • Pier specifications — quantity, dimensions, materials, installed spacing measured against HUD anchor pattern
  • Footing dimensions — width, length, depth, reinforcement verified to local frost-depth requirements
  • Soil bearing capacity — measured PSF rating, bearing assumption documented
  • Anchoring system — vertical and lateral anchorage, including straps, ground anchors, connection points
  • Permanent utilities & skirting — mechanical services permanently connected, perimeter fully enclosed per § 3
PFGMH § 3.1–3.6996 / 996
Common findings

What goes wrong

About 8% of 2025 foundations needed remediation before certifying. Most common deficiencies:

  • Pier footings undersized for the load on bearing soil — typically resolved by additional footings or larger footing pads
  • Anchor straps undercounted for wind zone — resolved by adding strap connections to manufacturer spec
  • Frost depth insufficient — footings poured shallower than the local frost line, requires re-pour
  • Skirting non-continuous or non-permanent material — replaced with code-compliant skirting

All 33 remediation cases in 2025 ultimately certified after corrections.

~8% need remediationRemediable
Hard stop

Pre-1976 manufactured homes can rarely satisfy PFGMH § 3. Homes built before HUD code took effect on June 15, 1976 typically can't be brought into compliance through remediation — the foundation can't carry the chassis design to spec. We flag pre-1976 on Day 1 (intake) before the field visit, so the file doesn't burn five days waiting on an inspection that can't certify.

REQ 02 OF 06 / PERMANENT UTILITIES REF · HUD 4000.1 II.D.4.b.ii

Permanent utilities.

Electrical, water, sewer, and HVAC must be permanently connected to local utility infrastructure. No temporary or seasonal connections. No extension cords, no garden-hose water supply, no portable propane tanks as the primary fuel source.

What we verify

Four utility systems

  • Electrical service — permanent meter, code-compliant service entrance, panel grounded and bonded to building
  • Water supply — permanent municipal connection OR permitted private well with potability test
  • Sewer / waste — permanent municipal connection OR permitted septic system with current pumping record
  • HVAC — permanent heat source (gas, electric, propane with permanent tank) sized to the home's load
II.D.4.b.ii996 / 996
What disqualifies

Hard non-compliance

  • Temporary electrical — jumper cables, extension cords, undersized service drop
  • Hauled water — cisterns without permitted refill source, garden hose connection from neighbor
  • Composting toilet or unpermitted septic — both fail FHA without remediation to permitted system
  • Wood stove as sole heat source — primary heat must be permanent gas/electric/propane; wood stove may supplement
Documented on-siteRemediable
REQ 03 OF 06 / HUD DATA PLATE REF · HUD 4000.1 II.D.4.b.iii

HUD data plate.

The HUD data plate is the manufacturer's identification placard, typically affixed inside a kitchen cabinet or near the electrical panel. It must be present, legible, and match the manufacturer's certificate of origin or title. Photo verification is in the report's appendix.

What's verified
Manufacturer name, plant location, model designation, serial number, HUD label number, manufacture date, wind zone rating, thermal zone rating, roof load rating. All values matched against the certificate of origin or title.
Photo evidence
One legible close-up photograph of the data plate in the photo appendix (Photo Set 03), with all values readable at print resolution. Plate is photographed in situ — not removed.
Conditional finding
Data plate missing or illegible is a conditional finding — not an outright fail. Replacement labels can be ordered from IBTS with proof of ownership and serial number. We document the absence and flag for the underwriter.
Hard non-compliance
Data plate values mismatch the certificate of origin (different manufacturer, different serial number, different HUD label) — indicates the home isn't the home identified on title. This is a stop-and-call to the LO, not a remediable finding.
REQ 04 OF 06 / HUD CERTIFICATION LABEL REF · HUD 4000.1 II.D.4.b.iv

HUD certification label.

The red metal HUD certification label is affixed to the exterior of each home section (single-wide: one label; double-wide: two labels; triple-wide: three labels). Each label carries a unique HUD label number that matches the certificate of origin.

What we verify

Red metal label, exterior

Each section of the home has its own HUD certification label affixed to the rear exterior wall (typically the tow-away end). The label is:

  • Red metal — not a sticker, not a plastic plaque
  • Affixed to the exterior — not inside
  • Unique label number — e.g., MIS 0481027
  • Photographed and recorded in the report's narrative findings (Finding 04) and photo appendix (Photo Set 04)
II.D.4.b.iv994 / 996
When labels are missing

Label replacement protocol

Two 2025 files had missing HUD certification labels — both resolved through the IBTS label replacement program:

  • Proof of ownership required (title, MSO, or certificate of origin)
  • Manufacturer serial & HUD label number from the data plate (REQ 03)
  • IBTS application filed by the borrower or LO; replacement label ships in 4–6 weeks
  • Our report flags the missing label as a conditional finding pending IBTS replacement
2 of 996 in 2025IBTS pathway
!

Why this matters at underwriting

The HUD certification label is the FHA underwriter's primary proof that the home was built to HUD code (post-June 1976). Without it, the file can't certify FHA. Photo documentation of the label number is non-negotiable for first-submission approval.

REQ 05 OF 06 / PERMANENT SITE WORK REF · HUD 4000.1 II.D.4.b.v

Permanent site work.

Skirting, grading, drainage, driveway, and walkway must all be permanent materials. Continuous skirting, drainage away from the foundation, permanent driveway surface. This is the requirement that catches the most conditional findings in 2025 — usually skirting damage.

Skirting
Continuous, permanent material covering the entire perimeter foundation. Vinyl, metal, brick, block, or stucco accepted. Open perimeter, partial skirting, and lattice fail. Damaged skirting is a conditional finding pending repair.
Site grading
Site graded so surface water drains away from the foundation. No water ponding within 10 feet of perimeter. Measured slope of at least 6″ over the first 10 ft per HUD guidance.
Drainage
Gutters, downspouts, splash blocks, or French drains directing roof runoff away from foundation. Visible erosion or staining on skirting indicating poor drainage is a finding.
Driveway & walkway
Permanent materials — concrete, asphalt, brick, paver, or compacted gravel. Dirt or grass paths to the home don't satisfy. Driveway must reach the home (no last-50-feet-of-mud).
Steps & landings
All exterior doors must have a permanent landing, with handrails on stairs of 4 or more risers. Code-compliant per local jurisdiction.
Common finding

Skirting damage is the single most common Finding 05 issue — lawn equipment, animals, weather, or simple aging. Replacement skirting installs same-day from local supply; the finding becomes Compliant after re-inspection (no second field visit needed, photo verification by LO or borrower is accepted).

REQ 06 OF 06 / TOWING EQUIPMENT REMOVED REF · HUD 4000.1 II.D.4.b.vi

Towing equipment removed.

Hitch, running gear, and tongue removed at minimum. Axles and wheels removed in most jurisdictions — though state-specific guidance varies. The intent is to demonstrate the home is no longer transportable, which is part of how the home converts from chattel to real property.

Minimum required

Hitch removed

The towing hitch / tongue — the metal A-frame at the front of the chassis used to attach to a truck — must be removed. Verified visually under the home or at the front skirting access panel.

All jurisdictionsVerified
Strongly recommended

Axles & wheels removed

The axles, springs, and wheels are typically removed during permanent installation. Some jurisdictions accept axles in place if the home is otherwise immobilized; most require full removal.

Most jurisdictionsVerified
Verification

Photographic proof

Under-home photography documenting absence of hitch, axles, and wheels — or, if axles remain, the immobilization mechanism. Photo Set 06 in every report.

Photo Set 06996 / 996
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Engineer of recordScapular Engineering, P.E.
Reciprocal activeAR · IL · KS
CoverageHUD V · VII
Insurance$2M E&O · A+
Direct line(573) 275-7647