Key Differences Between Subpart I, Dispute Resolution, and Warranties

Understanding Your Rights and Protections as a Manufactured Home Owner

Subpart I	Dispute Resolution	Warranties
Manufacturers must investigate issues, regardless of source of information or home's age Consumer complaints trigger manufacturer investigation (among other sources) Required actions include investigation, notification, and possible corrective action for failures to conform to HUD's standards or imminent safety hazards Applies to homes manufactured after June 15, 1976	Resolves disputes between manufacturers, retailers, and installers Only covers disputes about responsibility for defects, not consumer complaints Consumers can initiate disputes, but are not direct participants Requires alleged defects to be reported within one year of installation	Optional manufacturer-offered warranties, typically for one year May cover repairs and issues not addressed under federal standards and regulations Warranties are separate from Subpart I or Dispute Resolution protections Do not affect eligibility for Subpart I remedies or Dispute Resolution programs

Subpart I of the Manufactured Home Procedural and Enforcement Regulations (24 CFR Part 3282) applies to all homes manufactured for sale or lease to purchasers on or after the effective date of the standards (June 15, 1976). Depending on the root cause and seriousness of the issue, a home manufacturer may be required to notify homeowners and may also be required to correct failures to conform to HUD’s standards or imminent safety hazards.

The regulations require manufacturers to conduct investigations to determine if a manufactured home fails to comply with an applicable standard or contains a defect or an imminent safety hazard. The sources of information that obligate a manufacturer to initiate such an investigation include consumer complaints, in addition to other possible sources of information (suppliers, news/media, retailers, installers, etc.).

These sources include complaints received by the retailer, states which enforce the Federal manufactured housing program in cooperation with HUD, and complaints received through HUD or sent directly to the manufacturer.

Under Subpart I, HUD and/or State Administrative Agencies may direct the manufacturer to furnish notification to homeowners and retailers, and in some cases, to remedy/correct the failure to conform or imminent safety hazard.

Consumer Complaint Examples:

Cracks in the walls and/or ceiling
Outlets with no electricity
Doors stuck or hard to open
Windows stuck or leaking
Shock from light switch
Floor boards separating

The Manufactured Home Dispute Resolution Program (24 CFR Part 3288) provides for the timely resolution of disputes between manufacturers, retailers, and installers of manufactured homes regarding responsibility, and for the issuance of appropriate orders for the correction or repair of defects in manufactured homes. DRP does not affect the manufacturers’ responsibilities under Subpart I.

At the time of signing a contract for the sale or lease of a manufactured home, the purchaser must be provided with a retailer's dispute resolution notification and each home must be sold or leased with a manufacturer's dispute resolution notification located in the homeowner’s manual.

Depending on the state of a home’s location, the state may administer a HUD-approved Dispute Resolution Program. In all other states, HUD administers a federal Dispute Resolution program. A consumer may also initiate a dispute resolution request but are not party to a dispute resolution case.

Consumers must first report any alleged defects to the home manufacturer, retailer, installer, HUD, or State Administrative Agency and the issues must be reported within one year of the home’s initial installation.

A home warranty may be offered by the home manufacturer as part of its consumer satisfaction program. Warranties usually have duration limits and may also have coverage limitations. HUD does not require home manufacturers to offer any home warranty as part of the Federal Manufactured Home Construction and Safety Standards program.

Other federal programs may require home warranties with specific provisions for homes to qualify for financing (such as FHA insured mortgage programs) or other federal program benefits.

Some states may also require manufactured home warranties under state law. Home warranties do not replace, nor do they otherwise impact a home manufacturer’s regulatory obligations to execute Subpart I responsibilities, including notification and or correction when required and warranty coverage is not a factor in determining eligibility for the federal dispute resolution program.