by Kevin A. Park
339
Cityscape: A Journal of Policy Development and Research • Volume 24, Number 32022
U.S. Department of Housing and Urban Development • Office of Policy Development and Research
Cityscape
Real and Personal: The Effect of
Land in Manufactured Housing
Loan Default Risk
Kevin A. Park
U.S. Department of Housing and Urban Development
The views expressed in this article are those of the author and do not represent the official positions or
policies of the Office of Policy Development and Research, the U.S. Department of Housing and Urban
Development, or the U.S. government.
Abstract
Ownership of manufactured housing is complicated by the distinction between homeownership and
landownership. Roughly two of five manufactured homeowners do not own the underlying land.
Traditional mortgage financing is only available for manufactured homes owned with land as real estate.
Personal loans are available for manufactured homes without land or owned as personal property but are
often more expensive.
The Federal Housing Administration (FHA) provides loan insurance for the purchase or refinance of
manufactured homes owned as either real or personal property. This paper provides an overview of the
Title I loan insurance program and compares the default risk of FHA-insured personal property loans for
the purchase of manufactured homes to similar mortgages for manufactured homes. Landownership, even
when the home is titled as personal property, makes an important difference in risk.
Introduction
Manufactured homes provide an important source of affordable housing in the United States.
The price per square foot of a typical new manufactured home is less than one-half that of a new,
traditionally site-built home, excluding land value ($52.80 vs. $109.14).
1
Manufactured homes
account for more than one-half of all owner-occupied housing units less than $50,000 (exhibit
1
Median values for 2019 from the Census Bureau’s Survey of Construction and author tabulations of the Manufactured
Housing Survey.
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340 Policy Briefs
1). According to the 2019 American Housing Survey, nearly 6.4 million households in the United
States (roughly one in 20 households) live in manufactured homes. Most of those households own
their home.
Exhibit 1
Owner-Occupied Property Type by Value, 2019
0
25
50
75
100
$10,000
or Less
$20,000
$30,000
$40,000
$50,000
$60,000
$70,000
$80,000
$90,000
$100,000
More than
$100,000
Property Value
MH House and Land
MH House Only
Other
Share of Owner-Occupied Units (%)
MH = Manufactured Housing.
Note: Value of manufactured homes includes only the value of the housing unit, even if owned with land.
Source: American Housing Survey
However, ownership of manufactured housing is more complicated than ownership of site-built
homes. Nearly one-half of households in manufactured homes own both the housing unit and
the underlying land (exhibit 2). Another 28 percent own the housing unit only and not the lot.
Traditional mortgage financing is only available for real property, meaning the homeowner must
own the land and the home must be fixed to a permanent foundation. Personal loans are available
for households who do not own, or who choose not to encumber, the land but are often more
expensive with shorter terms. According to the 2019 American Housing Survey, only 16 percent
of manufactured-home owners without land report having a loan on the unit, whereas nearly one-
third of manufactured-home-and-landowners and more than 60 percent of site-built single-family-
home owners have loans on their properties.
Real and Personal: The Effect of Land in Manufactured Housing Loan Default Risk
341Cityscape
Exhibit 2
Site-Built and Manufactured Housing Tenure and Mortgage Status, 2019
28.0M Units
2.2M Units
42.7
1.0
1.5
0.3
13.8
1.4
0
25
50
75
100
Site-built
Manufactured
Share of Households (%)
Own Land and House
With Debt
Own House Only
With Debt
Rent
Source: American Housing Survey
For more than five decades, the Federal Housing Administration (FHA) has provided loan
insurance to facilitate the purchase of manufactured homes not only as real property through
its flagship Section 203(b) program but also as personal property under Title I of the National
Housing Act; however, the latter program has declined in recent decades. This paper provides an
overview of FHAs Title I manufactured housing loan program and analyzes the performance of
these loans relative to FHA-insured mortgages for the purchase of manufactured homes held as real
property. Land ownership, even when not used to secure a loan as collateral, substantially reduces
the likelihood of default.
Manufactured Housing
Under the National Manufactured Housing Construction and Safety Standards Act of 1974 (Public
Law 93-383), the U.S. Department of Housing and Urban Development (HUD) issues and enforces
standards for the design, construction, and installation of manufactured housing, preempting
state and local laws. Manufactured housing—as opposed to mobile homes, trailers, and modular
homes—is defined as a prefabricated dwelling built on a permanent chassis after June 15, 1976, in
compliance with this “HUD Code.
Manufactured homes can be owned as either real or personal property. Jointly holding land and
a manufactured home affixed to a permanent foundation makes it nearly indistinguishable from
site-built homes from a legal perspective. Personal or “chattel” property covers only the housing
unit. Most owners of manufactured homes (64 percent) are also landowners. Only 19 percent of
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342 Policy Briefs
new manufactured home shipments, however, were titled as real property in 2019, according to the
Manufactured Housing Survey; by contrast, 76 percent were titled as personal property.
Ownership and title affect financing options. Traditional mortgage financing is available only for
real property. Russell et al. (2021) found that almost one-half of borrowers using personal property
loans to purchase a manufactured home leased the land. Another 24 percent lived rent free on land
owned by others, possibly family members. However, more than one-fourth (27 percent) owned
the land but still used personal property loans rather than mortgage financing.
Russell et al. (2021) also found that applications for personal property loans to purchase
manufactured homes are more likely to be denied than manufactured home mortgage
applications, which are more likely to be denied than mortgage applications for a site-built
home, even controlling for credit score. Similarly, the average annual percentage rate (APR) on
personal property manufactured housing loans is 3.6 percentage points higher than the APR for
manufactured home mortgages, which is 1.2 percentage points higher than the APR for site-built
home mortgages.
2
Chattel financing also is not covered by the same consumer protection laws,
including the Real Estate Settlement Procedures Act (CFPB, 2014).
The Center for Community Capital (CCC, 2020) surveyed borrowers who financed the purchase
of a manufactured home in Texas in 2018. They found that 61 percent of buyers of manufactured
homes owned the underlying land. First-time homebuyers and lower-income, African-American,
and urban homebuyers were less likely to be landowners. Among landowners, 59 percent titled
their home as personal property. Some landowners preferred to avoid encumbering the land, even
if personal loans were associated with higher interest rates. Using a personal property loan was
associated with more knowledge of the loan process and less reliance on lenders and real estate
agents for information but a greater likelihood of applying through or being referred by the seller.
Borrowers using personal loans disproportionately preferred shorter loan terms, whereas borrowers
using mortgage loans preferred lower closing costs and fixed interest rates.
Whether ownership of manufactured homes includes landownership is immensely consequential
for evaluating its effects on wealth. Jewell (2003) and Boehm and Schlottmann (2008) found that
ownership of a manufactured home with landownership is associated with similar average but
more volatile price appreciation compared with site-built homes. Similarly, the Federal Housing
Finance Agency (FHFA, 2018) constructed a repeat-sales index of only manufactured housing
transactions and found price trends similar to those for other forms of housing. Manufactured
housing prices rose 120 percent between 1995 and 2018, compared with 140 percent for other
forms of housing, although manufactured housing prices fell more during the Great Recession.
However, the FHFA index is based on mortgage acquisitions by Fannie Mae and Freddie Mac (i.e.,
manufactured homes owned with land as real property). By contrast, Jewell (2003) and Boehm
and Schlottmann (2008) found that ownership of manufactured homes without landownership is
associated with depreciation relative to house price changes among site-built homes. Manufactured
housing “in which the household does not own the lot is not an investment in any sense. It should
be thought of as a type of consumer durable” (Boehm and Schlottmann, 2008: 200).
2
Russell et al. (2021) also found substantial bunching at APR spreads just below the thresholds under the Home
Ownership and Equity Protection Act that would require additional disclosure requirements.
Real and Personal: The Effect of Land in Manufactured Housing Loan Default Risk
343Cityscape
The effect of title and landownership is further complicated by the correlation with construction
status. The Home Mortgage Disclosure Act does not identify new construction but, since 2018,
has identified whether a manufactured housing loan is for the house and land or the house alone.
Nearly 225,000 loans for the purchase of manufactured homes were reported in 2018 and 2019, of
which the majority (55 percent) are for the housing unit and land. According to the Manufactured
Housing Survey, this number of purchase loans for manufactured homes and land is several times
the number of new manufactured home sales titled as real property, suggesting that most of those
loans are for existing manufactured homes. For comparison, the number of purchase loans for
manufactured homes without land is close to the number of new manufactured home sales titled
as personal property, suggesting that most of those loans are for new housing units. A premium for
new consumer durables has long been discussed in economic theory, particularly for automobiles
(e.g., Akerlof, 1970; Bond, 1982; Cramer, 1958), and has been empirically extended to new homes
(Coulson, Morris, and Neill, 2019). Any price premium for new durables is lost as soon as they are
bought, appearing as excessive depreciation. Therefore, some of the depreciation associated with a
lack of landownership may be the loss of the premium for new manufactured homes.
The difference in appreciation affects loan performance, given the importance of equity as a
key determinant of default, which is well established in the economic literature on mortgages
(e.g., LaCour-Little, 2008; Quercia and Stegman, 1992). There has been a paucity of research
specifically on the loan performance of manufactured homes (Lawrence, Smith, and Rhoades,
1992). Myers and Forgy (1963) demonstrated the value of developing credit risk scoring systems
using discriminant analysis of a sample of conditional sales contracts on mobile homes. Notable
factors include whether the borrower has a bank account, unsatisfactory credit references, history
of repossessions and bankruptcies, the unpaid balance and downpayment, other terms of the sales
contract, the width of the mobile home, and whether it was new or used. Lawrence, Smith, and
Rhoades (1992) used logistic regression to estimate the likelihood that a sample of loans active
in 1988 would default the following year. Borrowers’ current equity is estimated by assuming a
depreciation rate of 10 percent in the first year and 5 percent in subsequent years. Lower equity,
higher initial payment-to-income ratios, a history of missed payments, smaller loans, older
borrowers, and higher statewide unemployment rates are associated with greater risk.
Loans for manufactured homes experienced a wave of reckless lending and subsequent defaults in
the 1990s that presaged the subprime mortgage crisis. More than 75,000 owners had their homes
repossessed in 2000. Manufactured housing lender Conseco, Inc., which accounted for most loan
originations that year, filed for bankruptcy in 2002 (CFPB, 2014).
3
Genz (2001) noted that loans
for manufactured homes default at a rate four times higher than conventional loans, which would
be “unthinkable in the world of ‘real housing’ finance, but somehow tacitly accepted for people
who make their home in a factory-built unit” (Genz, 2001: 403). However, there has not been
an explicit and rigorous comparison of loan performance for manufactured housing as real and
personal property.
3
Conseco was also a major Title I lender in the early 1990s (see exhibit 3).
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344 Policy Briefs
Title I
HUD plays an important role in manufactured housing in the United States. In addition to
regulating the construction and safety standards of manufactured homes, HUD helps finance the
purchase and refinance of manufactured homes through FHA. FHA has always insured loans on
manufactured and mobile homes as real property if they meet its Minimum Property Standards
and local building and land use regulations. However, the Housing and Urban Development Act
of 1969 (Public Law 91-152) also authorizes FHA to insure personal property loans secured by
manufactured housing. Borrowers are not required to own the land but must have a land lease that
does not expire for at least 3 years after origination and afterward is renewable on an annual basis.
Insurance is authorized under Title I of the National Housing Act rather than Section 203(b) and
financed through the General Insurance Fund rather than the Mutual Mortgage Insurance Fund.
CCC (2020) reported that FHA accounted for 14 percent of buyers of manufactured homes in
Texas in 2018 using chattel financing, compared with 22 percent using mortgages. However, Title
I volume is a fraction of what it was three decades ago. FHA-insured chattel loan originations
collapsed from more than 26,000 in 1991 to fewer than 225 in 1999 (exhibit 3). Originations
rebounded to nearly 2,000 a year in the early 2000s. Nevertheless, FHA has insured nearly 30
times more loans for purchase or refinance of manufactured housing titled as real estate through
its main 203(b) mortgage insurance program than titled as personal property through Title I since
1998. Two major reasons for the decline are a limited secondary market and low loan limits.
Exhibit 3
Title I Lenders and Loan Volume, 1985–2020
0
25
50
75
100
0
7,500
15,000
22,500
30,000
1985
1990
1995
2000
2005
2010
2015
2020
Lenders
Loan Originations
Conseco Finance Corp
Vanderbilt Mortgage Finance
Logan Laws Financial Corp
21st Mortgage Corp
All Others
Lenders
Source: Federal Housing Administration administrative data
Real and Personal: The Effect of Land in Manufactured Housing Loan Default Risk
345Cityscape
Ginnie Mae has facilitated securitization of Title I loans since the 1970s but significantly curtailed
operations after suffering losses. Title I insurance covers only 90 percent of the claim amount,
compared with full coverage under 203(b). In addition, FHAs liability had been capped at 10
percent of a lender’s aggregate disbursement, known as the reserve account. Those limits became
binding when manufactured housing suffered waves of defaults in the 1980s and 1990s. Nearly
29 percent of Title I loans originated between 1995 and 2000 terminated with a claim (exhibit 4).
Although co-insurance was meant to align incentives between FHA and lenders, it created a moral
hazard problem: “[A]s lenders’ portfolios experienced losses [beyond the 10-percent aggregate
disbursement cap], they were incented to make more loans in order to increase the amount of
claims payments for which they were eligible” (Frenz, 2006: n.d.).
Exhibit 4
FHA Manufactured Housing Claim Rate by Cohort, 1998–2020
0
10
20
30
40
1985
1990
1995
2000
2005
2010
2015
2020
Claim Rate (%)
Title I
203b
Source: Federal Housing Administration administrative data
Those losses were pushed onto Ginnie Mae, which guarantees an issuer will make payments
on securities backed by Title I loans. Ginnie Mae placed a moratorium on new manufactured
housing securities issuers after 12 issuers defaulted between 1986 and 1988. Another 10 issuers
defaulted in the 1990s, resulting in at least $514 million in losses for Ginnie Mae (Government
Accountability Office, 2007). The FHA Manufactured Housing Loan Modernization Act of 2008
removed the portfolio cap to provide loan-level insurance coverage similar to the 203(b) program.
Nevertheless, Ginnie Mae requires issuers to have a minimum net worth of $10 million plus 10
percent of outstanding obligations to participate in its Manufactured Home Program, compared
with only $2.5 million plus 0.2 percent of outstanding obligations for the Single-Family Program.
The second major reason for declining Title I origination volume is that loan limits failed to keep
pace with the rising costs of manufactured homes (exhibit 5). Before 1983, there were separate
loan limits for one- and two-section manufactured homes. Congress then raised the limit to
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346 Policy Briefs
$40,500 but removed the distinction by number of sections. The Housing and Community
Development Act of 1992 again increased the loan limit for a manufactured home to $48,600,
above the average sales price of two-section homes at the time. However, by 2001 the average
sales price of all new units exceeded the loan limit. The FHA Manufactured Housing Loan
Modernization Act increased the limit to $69,678, roughly the average price of a new unit. The
2008 Act also mandated annual indexing of loan limits. However, the average sales price of new
units fell in the years shortly following the Great Recession. Rather than lower the loan limit in
proportion to the decline in price, FHA kept them unchanged. By 2016, the average sales price had
again risen above the Title I loan limit, but limits were not increased to keep pace.
Exhibit 5
Title I Loan Limit and Manufactured Housing Sales Prices, 1980–2020
$0
$20,000
$40,000
$60,000
$80,000
$100,000
$120,000
1980
1985
1990
1995
2000
2005
2010
2015
2020
Title I Loan Limit or Average Sales Price
All
Single Section
Double Section
Title I Loan Limit
Note: Manufactured housing unit only.
Sources: Public Law 98-181; FHA Title I Letters 424, 480; Manufactured Housing Survey
Title I requires an upfront mortgage insurance premium of 2.25 percent, higher than the 1.75
percent in the 203(b) program, and an annual insurance premium of 1 percent, also generally
higher than the 203(b) program. The maximum loan term for a loan on a manufactured home
is 20 years and 32 days, less than the 30 years common in the 203(b) program. The housing
payment, which includes taxes and lot rent, cannot exceed 33 percent of effective borrower
income, and total debt payments cannot exceed 45 percent.
There is no minimum credit score, but the lender must pull a score if available and examine the
borrower’s overall pattern of credit behavior. In addition, the maximum loan-to-value (LTV) ratio
is lower (90 percent) if the borrower has a credit score lower than 500. Otherwise, the maximum
LTV ratio is 95 percent, less than the 96.5-percent maximum in the 203(b) program. However, the
comparison is not apples to apples. The Title I denominator “value” is the sum of 130 percent of
Real and Personal: The Effect of Land in Manufactured Housing Loan Default Risk
347Cityscape
the wholesale price plus eligible itemized options, sales tax, transportation cost, cost of installing
appurtenance and air conditioning or heat pump, and financeable fees and charges. The upfront
mortgage insurance premium can be financed but counts toward the loan limit, whereas it does not
count in the 203(b) program. Secondary financing is not permitted in Title I.
The Title I program has gradually suffocated from the lack of a secondary market, failure to
increase loan limits with the rising cost of manufactured homes, and antiquated paper-based
program procedures. Fewer than 35 loans were originated under the program in 2020, and roughly
8,000 loans were still active at the end of 2021.
Data
This study used administrative data from FHAs 203(b) and Title I loan insurance programs to
analyze the performance of personal property loans relative to comparable mortgages for the
purchase of manufactured homes originated between 2012 and 2018. Roughly 2.5 percent of
observations were dropped due to incomplete information, mostly credit score. The resulting
sampling frame consists of nearly 127,000 observations, of which roughly 3,900 (3 percent) are
Title I loans. Exhibit 6 provides descriptive statistics of the data.
Exhibit 6
Descriptive Statistics (1 of 2)
Item Title I
203(b)
Matched All
Observations 3,944 9,190 122,831
Weighted 3,944 3,944
Estimated Title I Probability (%) 18.4 15.4 2.6
Loan Status (%)
Active 83.9 77.8 74.6
Default-Claim 7.8 4.6 2.1
Prepaid 8.3 17.7 23.3
Sales Price ($2021) 57,910 144,756 151,129
(14,139) (44,291) (96,124)
New Construction (%) 91.9 91.9 12.6
Loan Amount ($2021) 55,725 133,647 144,938
(13,698) (41,291) (69,797)
LTV Ratio (%) 96.8 92.7 96.5
(9.2) (7.7) (5.2)
Loan Term (Months) 239 359 357
(6) (11) (21)
Interest Rate (%) 7.3 4.5 4.5
(0.5) (0.5) (0.6)
Rate Spread 3.3 0.5 0.3
(0.5) (0.5) (0.5)
Credit Score 660 654 683
(55) (42) (48)
Income ($2021) 3,547 4,255 4,915
(1,568) (1,823) (2,442)
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348 Policy Briefs
Exhibit 6
Descriptive Statistics (2 of 2)
Item Title I
203(b)
Matched All
Housing Ratio (%) 21.7 25.4 24.0
(8.6) (8.0) (8.8)
Debt Ratio (%) 38.3 40.5 39.0
(14.1) (8.7) (9.4)
Coborrower (%) 25.2 31.7 34.0
Age 42.9 43.5 39.9
(17.3) (14.0) (13.8)
First-Time Buyer (%) 60.3 51.6 79.3
Race
White 72.5 67.1 76.9
African-American 9.7 13.3 3.3
Hispanic 4.3 3.4 11.2
Other 2.4 2.8 1.6
Not Available 11.0 13.4 6.9
Rural-Urban (%)
Urban Center 32.5 26.4 33.5
Urban Commuting 28.8 29.3 31.1
Micropolitan Area 19.7 21.5 19.6
Small Town 12.0 14.5 9.1
Rural 7.1 8.2 6.7
Year (%)
2012 14.4 14.4 9.7
2013 11.7 11.7 9.7
2014 10.4 10.4 11.1
2015 16.0 16.0 14.9
2016 20.6 20.6 16.5
2017 16.8 16.8 18.2
2018 10.1 10.1 19.9
State (%)
Other 12.9 12.9 65.6
Alabama 9.2 9.2 1.2
Arkansas 4.4 4.4 0.8
Kentucky 7.2 7.2 2.6
Louisiana 9.9 9.9 2.6
Mississippi 3.7 3.7 0.4
North Carolina 9.7 9.7
6.7
Oklahoma 3.3 3.3 1.6
South Carolina 6.0 6.0 2.6
Tennessee 7.1 7.1 3.6
Texas 17.8 17.8 8.5
Virginia 4.6 4.6 2.7
West Virginia 4.2 4.2 0.9
LTV = loan-to-value.
Note: Standard deviations shown in parentheses.
Source: Federal Housing Administration administrative data
Real and Personal: The Effect of Land in Manufactured Housing Loan Default Risk
349Cityscape
Selection
Before comparing loan performance, this study analyzed differences between manufactured home
mortgages and personal property loans. The results of this analysis were used to reduce differences
that might confound estimating the relative risk of Title I loans.
Methodology
This study used a binomial logistic regression to estimate the likelihood of using Title I as opposed
to 203(b) insurance.
4
Borrower level covariates X used to predict program and property type include:
Credit Score The decision credit score of the borrower (i.e., the median of the scores from the
three credit bureaus, or minimum if fewer than three are available). If multiple
borrowers are present, then the lowest decision score is used.
Income The natural logarithm of the inflation-adjusted monthly income (with
Winsorization
5
to limit the influence of outliers) used in underwriting.
Co-Borrower A binary indicator of whether more than one borrower is on the loan.
Age The age of the primary borrower.
Race Categorical variables reflecting the race and ethnicity of the primary borrower.
First-Time Buyer A binary indicator of whether the borrowers are first-time homebuyers.
Housing market conditions Z at the time of closing include the following:
Unemployment The monthly county unemployment rate reported by the U.S. Bureau of Labor
Statistics.
MH Share The number of manufactured housing units as a share of the total housing stock
estimated in the most recent 5-year American Community Survey before loan
origination.
RUCA The rural-urban commuting area (RUCA) 2010 classification of the property
ZIP Code developed by the U.S. Department of Agriculture. The classification is
condensed into five categories: Urban Center (RUCA code 1), Urban Commuting
Area (2–3), Micropolitan Area (4–6), Small Town (7–9), and Rural (10).
4
Logistic regression estimated using the logit command in Stata/SE 15.0.
5
Winsorization refers to top- and bottom-coding values at given percentiles. In this case, the top and bottom one percent of
income values are replaced with 99
th
and 1
st
percentiles, respectively.
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350 Policy Briefs
Fixed effects are included for the year the loan was closed
θ
and the 12 states with the most Title I
manufactured housing loans
φ
. All other states are grouped in the reference category.
Findings
The first column of exhibit 7 presents the results of the logistic regression estimating the likelihood
of using a Title I personal property loan for the purchase of a manufactured home relative to
a 203(b) mortgage. Borrowers with lower income and lower credit scores were more likely to
use Title I. Older homebuyers were also more likely to use Title I, whereas Hispanic and first-
time buyers were less likely. Buyers in the most urbanized areas were more likely to use Title I,
and 203(b) mortgages were more common within micropolitan areas and commuting zones of
metropolitan areas.
Exhibit 7
Selection Model (1 of 2)
(1) (2) (3)
New Construction 66.390*** 76.810***
(4.5420) (7.3890)
Credit Score 0.988*** 0.993*** 0.993***
(0.0005) (0.0005) (0.0007)
Income (Log) 0.145*** 0.082*** 0.089***
(0.0073) (0.0049) (0.0074)
Co-Borrower 1.017 0.749*** 0.791***
(0.0458) (0.0361) (0.0527)
Age 1.012*** 1.007*** 1.008***
(0.0013) (0.0015) (0.0021)
Race
African-American 1.395*** 0.750*** 0.699**
(0.0900) (0.0557) (0.0766)
Hispanic 0.560*** 0.608*** 0.612***
(0.0470) (0.0557) (0.0720)
Other 2.022*** 1.539** 1.021
(0.2440) (0.2260) (0.2490)
Not Available 1.810*** 1.324*** 1.649***
(0.1060) (0.0893) (0.1430)
First-Time Buyer 0.342*** 0.511*** 0.461***
(0.0130) (0.0236) (0.0294)
Housing Market
Unemployment Rate 1.071*** 1.087*** 1.019
(0.0104) (0.0130) (0.0213)
Real and Personal: The Effect of Land in Manufactured Housing Loan Default Risk
351Cityscape
Exhibit 7
Selection Model (2 of 2)
(1) (2) (3)
MH Share of Stock 1.019*** 1.006* 0.999
(0.0024) (0.0027) (0.0054)
Land Value (Log) 76.810***
(7.3890)
Land Share of Value 1.610***
(0.2320)
Home Sales Rate 0.019***
(0.0174)
Change in House Prices 0.985***
(0.0022)
Mortgage Delinquency Rate 0.989
(0.0097)
RUCA
Urban Commuting 0.592*** 0.549*** 0.548***
(0.0285) (0.0305) (0.0375)
Micropolitan Area 0.824*** 0.692*** 0.651***
(0.0444) (0.0431) (0.0594)
Small Town 0.918 0.714*** 0.650*
(0.0602) (0.0562) (0.1140)
Rural
0.992 0.708*** 0.586*
(0.0781) (0.0659) (0.1250)
Observations 126,775 126,775 82,399
χ² 6793*** 8103*** 4543***
AIC 25,423 17,260 9,136
AIC = Akaike information criterion. MH = manufactured housing. RUCA = rural-urban commuting area codes.
Notes: State and year fixed effects not shown. Statistically significant at the * 0.050 ** 0.010 *** 0.001 level. Robust standard errors shown in parentheses.
Source: Federal Housing Administration administrative data
The second column in exhibit 7 includes a binary indicator of construction status. Most (88
percent) Title I loans were for the purchase of new manufactured homes, whereas most (81
percent) 203(b) mortgages for manufactured homes were for the purchase of existing homes
(exhibit 8). Even controlling for other characteristics, purchasing a new rather than existing
manufactured home increased the odds of using Title I by a factor of 66.
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352 Policy Briefs
Exhibit 8
FHA Manufactured Housing Lending by Construction Status, 1998–2020
123,087 New
19,858 New
527,143 Existing
2,589
Existing
0
25
50
75
100
203(b)
Title I
Share of Loan Originations (%)
Source: Federal Housing Administration administrative data
The unemployment rate and manufactured share of the housing stock were correlated with
increased use of Title I. However, the third column of exhibit 7 adds additional housing market
conditions, which causes both of those variables to lose statistical significance. The additional
factors were not available for more than one-third of observations, reflecting the general lack of
data in many rural areas. For those observations with complete information, higher land values
were associated with increased use of Title I, whereas hot housing markets (home sales and house
price appreciation) were associated with more 203(b) mortgages.
Propensity Score Matching
This study used propensity score matching to control for observable differences in homebuyers
titling their manufactured homes as personal and real property. The propensity score is the log
odds of using a Title I derived from the first logistic regression specification shown in exhibit 7.
This paper stratified the matching process by year, state, and construction status. The analysis
matched each Title I loan for a new manufactured home to five 203(b) mortgages for new
manufactured homes in the same state and year using nearest-neighbor matching with
replacement.
6
In addition, the study matched Title I loans for existing manufactured homes to 10
203(b) mortgages for existing manufactured homes.
Matching reduced the sample size to 13,134 loans but substantially improved the overlap in
borrower characteristics. Exhibit 6 shows how matching and weighting observations reduced
differences in borrower characteristics and location, which allowed any differences in default risk
6
Propensity score matching executed using the psmatch2 command in Stata from Leuven and Sianesi (2003).
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353Cityscape
to be more specifically associated with the type of loan. However, differences remain that may
affect relative loan performance. For example, Title I borrowers continued to be lower income
than 203(b) borrowers. Matching did not meaningfully change the higher interest rate associated
with Title I loans: the raw difference of 2.83 percentage points narrows slightly to 2.76 percentage
points after matching but remains statistically significant.
Default
Default in this analysis is defined as an insurance claim dated to the start of the delinquency
episode. This outcome definition addresses differences in the claim and property disposition
processes between the two programs. Nearly 8 percent of Title I loans originating in the study
period have terminated in a claim, compared with roughly 2 percent of 203(b) manufactured home
mortgages. After propensity score matching, the claim rate of 203(b) mortgages increases to nearly
5 percent, still below the Title I default-claim rate.
Methodology
A Cox proportional hazard model estimates the additional default risk associated with Title I loans as
where λ
0
indicates an unspecified baseline hazard.
7
Loan performance is censored at the end of
2019 to avoid problems arising from the COVID-19 pandemic.
8
Exhibit 9 shows the cumulative
hazard of default by loan type before and after propensity score matching. The results show that
the matching reduces the higher default hazard associated with Title I loans.
The coefficient of interest δ captures the difference in default risk associated with Title I loans
relative to 203(b) mortgages. Borrower covariates X and housing market conditions Z are the
same first specification of the selection model. The study analyzes the effects associated with the
following additional risk factors:
Housing Ratio Total housing payments, including the amount of lot rent for Title I borrowers,
relative to borrower income. Often referred to as the “front-end” debt-to-
income (DTI) ratio.
Debt Ratio Total fixed payments, including housing and all other debt, relative to
borrower income. Often referred to as the “back-end” DTI ratio.
New Construction A binary indicator of whether the housing unit is new construction.
Rent Lot A binary indicator of whether a Title I borrower pays lot rent.
7
Cox hazard is estimated using the stcox command in Stata/SE 15.0.
8
Wong (2021) reports that owners of manufactured homes were more likely to be behind in their housing payments during
the COVID-19 pandemic. Most personal property loans for manufactured homes were not covered by CARES Act relief
provisions.
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354 Policy Briefs
Land Tenure A categorical variable indicating the type of land tenure, including (1)
ownership, (2) leased private property, (3) leased park community, or (4) other.
Housing and debt ratios are also Winsorized to limit the influence of outliers.
Exhibit 9
Cumulative Default Hazard
0.00
0.05
0.10
0.15
0.20
0
12
24
36
48
60
72
84
96
Cumulative Default Hazard
Months Since Origination
Title I
203(b) Matched
203(b)
Source: Federal Housing Administration administrative data
Findings
Exhibit 10 presents the results of the Cox proportional hazard model. The first specification shows
that the baseline difference is default risk before propensity score matching and with no covariates.
Title I loans are associated with a risk of claim-default nearly three times higher than 203(b)
mortgages. That difference narrows after propensity score matching. The second column of exhibit
10 shows that Title I loans are associated with a 56-percent increase in the risk of default relative to
203(b) mortgages with similar borrower characteristics.
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355Cityscape
Exhibit 10
Default Hazard Ratios
(1) (2) (3) (4) (5) (6) (7)
Title I 2.995*** 1.557*** 1.430*** 1.671*** 1.687*** 1.465** 1.172
(0.179) (0.161) (0.146) (0.205) (0.212) (0.203) (0.213)
Credit Score 0.995*** 0.996*** 0.996*** 0.996*** 0.996***
(0.001) (0.001) (0.001) (0.001) (0.001)
Income (Log) 0.772* 1.199 1.232 1.090 1.187
(0.085) (0.213) (0.227) (0.204) (0.224)
Co-Borrower 0.762* 0.680* 0.682* 0.689* 0.692*
(0.101) (0.113) (0.113) (0.114) (0.114)
Age 1.016*** 1.016*** 1.016*** 1.016*** 1.017***
(0.004) (0.004) (0.004) (0.004) (0.004)
Race
African-American 0.683* 0.653** 0.654** 0.662** 0.666*
(0.108) (0.105) (0.105) (0.106) (0.107)
Hispanic 0.482** 0.462** 0.462** 0.457** 0.472**
(0.133) (0.129) (0.129) (0.128) (0.132)
Other 0.444* 0.422* 0.423* 0.438* 0.429*
(0.166) (0.158) (0.158) (0.163) (0.160)
Not Available 0.785 0.782 0.784 0.780 0.786
(0.189) (0.192) (0.192) (0.191) (0.193)
First-Time Buyer 1.536*** 1.524*** 1.521*** 1.491*** 1.456**
(0.183) (0.182) (0.182) (0.178) (0.174)
Housing Ratio 1.024** 1.026** 1.020* 1.023*
(0.009) (0.009) (0.009) (0.009)
Debt Ratio 1.005 1.005 1.005 1.004
(0.005) (0.005) (0.005) (0.005)
New Construction 0.864 0.879 0.860
(0.127) (0.130) (0.128)
Rent Lot 1.309*
(0.162)
Land Tenure
Leased Park
Community
1.794**
(0.336)
Leased Private
Property
1.458*
(0.237)
Other 1.586
(0.916)
Observations 126,775 13,134 13,134 13,134 13,134 13,134 13,134
χ² 338*** 18*** 190*** 204*** 204*** 212*** 228***
AIC 64,812 8,173 8,120 8,113 8,114 8,112 8,110
AIC = Akaike information criterion.
Note: Unemployment rate, manufactured share of housing stock, and state and year fixed effects not shown.
Source: FHA administrative data
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The third column further includes the borrower characteristics used in the selection model as
covariates. Higher credit scores, higher income, and co-borrowers are associated with a lower risk
of default. Minority borrowers are associated with a lower risk of default, whereas older and first-
time homebuyers are associated with higher risk. Including those characteristics reduces the hazard
ratio associated with Title I to 43 percent; that is, approximately two-thirds of the baseline risk
associated with Title I loans (first column) can be explained by the characteristics of the borrowers
that program serves. Exhibit 9 illustrates how the cumulative default hazard of 203(b) mortgages
increases after matching to Title I borrowers. The fourth column of exhibit 10 introduces new risk
factors not included in the selection model. The ratio of required housing payments to income
is associated with an increase in the risk of default, but the overall debt-to-income ratio is not
statistically significant. The indicator of new construction (fifth column of exhibit 10) is also not
significant. Including those risk factors increases the risk associated with Title I.
The sixth column shows the results of including the indicator of paying rent. Roughly one-fourth
of Title I borrowers own their land, 46 percent are on leased private property, and only 23 percent
are in a mobile home park (exhibit 11). Overall, nearly two-thirds do not pay a lot rent. Title I
borrowers without a lot rent payment are associated with a 46-percent increase in the likelihood of
default relative to a 203(b) mortgage borrower. Title I borrowers who pay a lot rent are associated
with an additional 31-percent increase in default risk, which is statistically significant at the
5-percent level, or 92 percent higher than the risk associated with 203(b) mortgage borrowers.
Notably, that estimated effect exists while controlling for the amount of the lot rent, which is
incorporated into the housing payment ratio.
9
Exhibit 11
Title I Land Tenure and Rent
0
10
20
30
40
50
Own
Leased Private
Property
Leased Park
Community
Other
Share of Title I Loans (%)
No Rent
Land Rent
Source: FHA administrative data
9
The lot rent is the amount at time of underwriting. It does not reflect subsequent changes in lot rent.
Real and Personal: The Effect of Land in Manufactured Housing Loan Default Risk
357Cityscape
The final column of exhibit 10 replaces the lot rent indicator with the land tenure classification. The
reference group in the typology is Title I borrowers who own the underlying land. Those borrowers
are associated with a 17-percent increase in the likelihood of claim-default relative to 203(b)
mortgage borrowers; however, the analysis cannot reject the null hypothesis that the default risk is
equivalent to a manufactured home purchase mortgage. Title I borrowers who are on leased private
property are associated with a 46-percent increase in the default risk relative to Title I landowners (71
percent relative to 203(b) mortgages), which is significant at the 5-percent level. Title I borrowers in
leased park communities are associated with a 79-percent increase in default risk (more than twice
the risk of 203(b) mortgages). Exhibit 12 shows the results of an additional specification with select
combinations of construction status, lot rent payment, and land tenure type. The results illustrate that
Title I landowners are not significantly higher risk than similar homebuyers using 203(b) mortgages,
whereas Title I borrowers renting lots in mobile home parks are substantially higher risk.
10
Exhibit 12
Claim Hazard Ratios
0.5
1.0
1.5
2.0
2.5
3.0
No Rent
No Rent
Rent
Rent
203(b)
New
Title I
Existing
Own Lot
Leased Private Property
Leased Park
Community
Other
Title I New
Hazard Ratio
Claim
Claim with Prepayment Risk
Note: Error bars indicate 95-percent confidence interval.
Source: FHA administrative data
The study used a Cox proportional hazard model to understand the causal effect of property and
program type on loan performance (Allison, 2018; Austin, Lee, and Fine, 2016). However, exhibit
13 shows the results of comparable Fine-Gray subhazard models that treat prepayment (i.e.,
termination without insurance claim) as a competing risk.
11
Title I loans are substantially less likely
to prepay, possibly reflecting the difficulty in refinancing personal property loans on manufactured
homes (Goodman and Neal, 2021; Russell et al., 2021)—a circumstance that prolongs the
exposure of Title I loans to the risk of default. Therefore, the estimated risk associated with Title
I loans in the Fine-Gray models shown in exhibit 13 is higher than the comparable estimates
10
FHA requires a lease of at least 3 years for Title I loans in leased park communities. However, an additional specification
(not shown) did not find a statistically significant dierence in hazard ratios for such loans before and after 3 years.
11
Fine-Gray model estimated using the stcrreg command in Stata/SE 15.0.
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358 Policy Briefs
in the Cox models shown in exhibit 10. Nevertheless, the final specification of exhibit 13 and
the additional specification in exhibit 12 confirm that Title I landowners are not associated with
significantly higher risk than 203(b) mortgage borrowers.
Exhibit 13
Default Hazard with Prepayment Risk
(1) (2) (3) (4) (5) (6) (7)
Title I 3.387*** 1.701*** 1.561*** 1.805*** 1.821*** 1.571** 1.264
(0.202) (0.176) (0.161) (0.226) (0.233) (0.222) (0.233)
Credit Score 0.995*** 0.996*** 0.996*** 0.995*** 0.996***
(0.001) (0.001) (0.001) (0.001) (0.001)
Income (Log) 0.746** 1.106 1.134 1.001 1.090
(0.082) (0.195) (0.208) (0.187) (0.205)
Co-Borrower 0.746* 0.667* 0.668* 0.675* 0.679*
(0.100) (0.111) (0.111) (0.112) (0.112)
Age 1.016*** 1.016*** 1.016*** 1.015*** 1.017***
(0.004) (0.004) (0.004) (0.004) (0.004)
Race
African-American 0.708* 0.680* 0.681* 0.689* 0.694*
(0.112) (0.109) (0.109) (0.110) (0.111)
Hispanic 0.495* 0.478** 0.478** 0.472** 0.489*
(0.137) (0.133) (0.133) (0.132) (0.137)
Other 0.457* 0.439* 0.439* 0.456* 0.445*
(0.170) (0.163) (0.163) (0.169) (0.166)
Not Available 0.796 0.791 0.794 0.789 0.792
(0.194) (0.196) (0.196) (0.195) (0.196)
First-Time Buyer 1.535*** 1.526*** 1.523*** 1.494*** 1.459**
(0.184) (0.183) (0.183) (0.180) (0.176)
Housing Ratio 1.021* 1.022* 1.016 1.020*
(0.009) (0.009) (0.009) (0.009)
Debt Ratio 1.005 1.005 1.005 1.005
(0.005) (0.005) (0.005) (0.005)
New Construction 0.873 0.888 0.869
(0.129) (0.132) (0.130)
Rent Lot 1.323*
(0.164)
Land Tenure
Leased Park Community 1.799**
(0.336)
Leased Private Property 1.449*
(0.235)
Other 1.662
(0.962)
Observations 126,775 13,134 13,134 13,134 13,134 13,134 13,134
χ² 419*** 26*** 221*** 233*** 233*** 242*** 258***
AIC 65,634 14,574 14,429 14,416 14,417 14,412 14,406
AIC = Akaike information criterion.
Notes: Unemployment rate, manufactured share of housing stock and state and year fixed effects not shown. Statistically significant at the * 0.050 ** 0.010
*** 0.001 level. Robust standard errors shown in parentheses.
Source: Federal Housing Administration administrative data
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359Cityscape
Conclusion
Manufactured housing is often seen as a technological solution to the affordable housing problem.
The Manufactured Housing Improvement Act of 2000 (Public Law 106-569) states, “[M]anufactured
housing plays a vital role in meeting the housing needs of the Nation, and manufactured homes
provide a significant resource for affordable homeownership and rental housing accessible to all
Americans.
12
FHA is specifically noted as an instrument for improving access to manufactured
housing. The 2000 Act calls for a review of FHAs manufactured housing programs and “developing
any changes to such programs to promote the affordability of manufactured homes, includes
changes in loan terms, amortization periods, regulations and procedures.
13
Eight years later, the
FHA Manufactured Housing Loan Modernization Act aimed to “modernize the FHA title I insurance
program for manufactured housing loans to enhance participation by Ginnie Mae and the private
lending markets.” However, a Government Accountability Office (GAO) review in 2014 found
that “HUD has not yet examined or researched the effectiveness of these loan programs because its
research has focused on other priorities” (GAO, 2014: 29).
This paper compares the performance of personal property insured under Title I with similar
mortgages for the purchase of manufactured homes insured under FHAs flagship 203(b) mortgage
insurance program. Title I loans are more than three times more likely to default than 203(b)
mortgages. However, two-thirds of that difference is because Title I disproportionately serves older,
lower-income borrowers with lower credit scores.
The remaining difference is mostly due to land tenure. One-fourth of Title I borrowers own the
land on which their manufactured home rests. Those borrowers have approximately the same
default risk as 203(b) mortgagors. A plurality of Title I borrowers are on leased private property,
and most of them do not pay land rent. Less than one-fourth rent a lot in a mobile home park.
FHA requires land leases in park communities to have initial terms of at least 3 years, annually
renewable, with 180 days written notice before expiration if the borrower is required to move.
Nevertheless, renting land is associated with an increase in the likelihood of default, particularly if
in a mobile home park.
There are many challenges to reinvigorating FHAs 50-year-old program of personal property loan
insurance for manufactured homes. The maximum loan amount of $69,678 in the Title I program
is less than the average cost of a new manufactured home ($81,900 in 2019), not including the
costs of transportation and installation. Ginnie Mae places additional requirements for Title I
securities issuers compared with issues of securities based on mortgages on single-family homes,
limiting the secondary market. Title I continues to rely on manual underwriting and processing of
paper case binders.
Title I loans carry a significantly higher interest rate, roughly 2.76 percentage points above the
average rate on FHA-insured manufactured home mortgages for otherwise similar borrowers.
Higher rates may be expected given the higher risk associated with personal property loans not
secured by land. However, FHA provides nearly the same loan-level insurance coverage to Title I
12
42 USC § 5401(a).
13
42 USC § 5407(a).
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360 Policy Briefs
loans as to 203(b) mortgages. Investors are reimbursed for 90 percent of losses, and the portfolio
limit on claims was removed by the FHA Manufactured Housing Loan Modernization Act of 2008.
Therefore, the difference may reflect a more limited secondary market for these loans.
The Manufactured Housing Improvement Act of 2000 encourages the government-sponsored
enterprises “to actively develop and implement secondary market securitization programs for the FHA
manufactured home loans and those of other loan programs, as appropriate, thereby promoting the
availability of affordable manufactured homes to increase homeownership for all people in the United
States.” The policy goal was reiterated in the Housing and Economic Recovery Act of 2008 (Public
Law 110-289), which states that Fannie Mae and Freddie Mac have a “duty to serve” manufactured
housing, including developing “loan products and flexible underwriting guidelines to facilitate a
secondary market for mortgages on manufactured homes for very low-, low- and moderate-income
families.” The Act also singles out rural housing markets, where manufactured homes are a greater
share of the housing stock. Fannie Mae and Freddie Mac have proposed pilot programs to securitize
personal property loans on manufactured homes (Fannie Mae, 2021; Freddie Mac, 2020). However,
they currently levy higher fees on manufactured home mortgages; for example, Fannie Mae charges
a 50-basis-point upfront charge to purchase mortgages on manufactured homes. Private mortgage
insurance can add another 18 to 60 basis points to the monthly cost.
Homeownership without landownership is akin to buying down rent. The upfront cost of buying
the housing unit may lower subsequent housing expenses. The potential benefits of this buydown,
however, depend on the terms used to finance the purchase and the stability of tenure after
purchase. FHA was instrumental in increasing homeownership by popularizing the long-term
amortizing mortgage that dominates the American housing finance system. It has an opportunity to
play a similar role increasing access to affordable housing by increasing the availability of personal
property loans with appropriate risk management and consumer protections.
Acknowledgments
The author would like to thank Patricia McBarron for vital assistance in understanding the Title
I program and data and Caitlin Gorback, Lariece Brown, Jessica Russell, Nora O’Reilly, William
Reeder, Kurt Usowski, and Adam Hoffberg for helpful comments and suggestions.
Author
Kevin A. Park is an economist in the Housing Finance Analysis Division of the U.S. Department of
Housing and Urban Development’s Office of Policy Development and Research. He can be reached
at kevin.park@hud.gov.
Real and Personal: The Effect of Land in Manufactured Housing Loan Default Risk
361Cityscape
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