Tax Permits

## Issue Summary

**Feedback from registry staff highlights procedural gaps in the Manufactured Home Registry (MHR) transfer process.**
Staff reiterated concerns, particularly around the *Confirm Completion* section of the transfer workflow, and urges a future review to improve registry integrity.

---

## Context

From staff email:
> “Pertaining to the *Confirm/Completion* portion of the transfer of ownership process, in hopes you will review this and perhaps we can make some changes eventually.
> Two things are most concerning to me…”

This feedback builds on previously raised concerns that remain unresolved and continue to affect both registry staff and data integrity.

---

## Primary Concerns

### 1. Lack of Meaningful User Confirmation
- The current "Confirm Completion" message is often overlooked.
- Passive language and optional reading mean users frequently proceed without understanding obligations.
- Staff recommends adding required interactions (e.g., checkboxes, toggles) to compel engagement and comprehension.

### 2. No Validation of Home Location
- The transfer form includes location, but the registry does not use it to verify or trigger any checks.
- If the form’s location differs from what is currently registered:
- There is no system prompt or warning.
- The user is not required or guided to resolve the discrepancy.
- This undermines data accuracy and could cause downstream issues (e.g., taxation, liens, land usage).

---

## Additional Risks Identified

- **Lien Visibility**
- Non-blocking liens (e.g., tax liens) are not displayed during the UI transfer flow.
- This may lead to a false belief that no encumbrance exists, despite declarations in the Bill of Sale.
- Risk: users unknowingly accept liability for encumbered homes.

- **Over-reliance on Qualified Suppliers (QSs)**
- With fewer UI safeguards, QSs are expected to catch and correct issues themselves.
- In reality, errors are frequent, and registry staff must often intervene after the fact.
- No QA loop or education mechanism is in place to address recurring issues.

---

## Recommendations

1. **Revise Confirm Completion Interaction**
- Introduce mandatory checkboxes or toggles for key acknowledgments.
- Break out confirmation statements to highlight obligations (e.g., location accuracy, lien awareness).

2. **Introduce Location Validation or Prompting**
- Compare registry and form locations during transfer.
- Prompt user to confirm if different, or offer guidance for required steps (e.g., location change filing).

3. **Surface Liens Clearly in UI**
- Display all active liens during the transfer flow, even if non-blocking.
- Include warnings or flags on potential implications for buyer/seller.

4. **Implement QA Measures for QSs**
- Introduce sampling audits or trigger-based checks.
- Consider alerting registry staff when high-risk fields (e.g., location, lien, names) are mismatched.
- Encourage refresher training for QSs with repeated issues.

---

## Desired Outcome

A more robust, transparent, and procedurally sound transfer process that:
- Improves user understanding and accountability.
- Reduces reliance on registry staff for post-transfer interventions.
- Strengthens the accuracy and reliability of registry data.