HUD “Clarification” on Frost-Free IB Offers More Questions and Confusion Than Answers


OCTOBER 17, 2018

                     MHARR STATE AFFILIATES

FROM:           MHARR
RE:                 HUD “Clarification” on Frost-Free IB Offers
More Questions And Confusion Than Answers

As a follow-up to the MHARR memorandum sent earlier today regarding finalization of the proposed “frost-free” Interpretive Bulletin (IB), it now appears that the HUD program, after doing nothing during the October 16, 2018 installation conference call (which was conducted by the contractor) to correct the impression created by its contractor – that HUD would not be taking action to finalize that IB – is now trying to backpedal, or leave itself room to adopt the proposed IB at some point in the future.

The supposed HUD program “clarification” (reproduced in full below), however, actually creates more confusion and questions about how the program plans to handle this entire matter both near and long-term, and illustrates the type of regulatory and enforcement uncertainty that is inevitably created when regulatory and pseudo-regulatory functions are unlawfully delegated to contractors.

This incident, moreover, and HUD’s conduct regarding this matter, could indicate that the federal program might be starting to gravitate toward the type of unacceptable practices that characterized it before the arrival of the Trump Administration.

MHARR will closely monitor this matter very carefully for further discussion at the upcoming MHARR Board of Directors meeting.

Further, on the specific issue of the proposed “frost-free” IB, MHARR will continue to oppose the final adoption of the proposed IB – or any variant thereof – and will continue to press this matter until it gets full and complete answers.


From: Payne, Teresa L
To Lesli Gooch, mmarkweiss
Cc Gormley, Joseph M, Mcjury, Jason C

Lesli and Mark,

Due to questions from both industry associations, this email is being sent to further clarify the answer provided by SEBA Professional Services to a question received during the Open Industry Conference Call for the Installation program.  The incoming question and response stated:

Question: “Has there been any update to the Interim Guidance on use of Frost-free Foundations?“

Answer: “At this time, HUD has decided not to take action on finalizing the Interpretive Bulletin concerning frost free foundations.”

The answer provided was not intended to state any new or final program or policy decisions by HUD with respect to the future of the proposed Interpretative Bulletin on Foundations in Freezing Temperature Areas (the IB).  Rather, the answer provided was consistent with similar commentary provided by HUD during the recent MHCC Meeting.  To reiterate the essence of those comments, at this time, there has been no work or decisions on finalizing the IB.  HUD’s limited resources and current priorities for the office are not currently focused on finalizing the IB.  To be clear, at this time, there have not been any new or final policy decisions on the future of this proposed action.   The Department has received public comment on the proposed IB and HUD has also received previous comments from the MHCC.  HUD is also aware of the MHCC’s consideration of log items from the September 2018 MHCC meeting agenda.


Teresa Payne
HUD Office of Manufactured Housing Programs (OMHP)
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