I have received a few emails recently asking how the shutdown of the federal government (most notably HUD) impacts the roles and responsibilities of manufactured home installers and retailers operating in states where HUD oversees the installation program.
I think it is important to know that the daily activities required by the Manufactured Housing Installation Program (24 CFR 3285 & 3286) are carried out by SEBA who is under contract with HUD. So, we can assume that SEBA is still at work processing HUD 305, 306, 307 and 309 forms and performing other related activities.
Currently the biggest impact is the issuing of installer licenses. While SEBA continues to process the forms for installer license applications, the folks at HUD issue the actual license. So, don’t expect your license to be renewed or any new licensees issued until the shutdown impasse is resolved.
Regarding the reporting that is required for new manufactured homes sold and installed, (forms 305, 306 & 309) my advice is that retailers and installers should continue to conduct business just as before. Keep submitting the forms within the required time frames and keep good records! The processing of these forms is conducted by SEBA, who is currently working as usual.
Eventually, all federal government contractors will want to be paid and there could be further impact should things drag on much longer.
It is important to remember that regardless of the when the government reopens, the requirements are still in place. A lack of enforcement or oversite doesn’t change the law. So be certain to complete the needed forms in a timely manner and submit them as usual.