New construction will be the foundation of relocated building IMO.
In accordance to the FAIR HOUSING ACT DESIGN MANUAL FHA;
Building Conversions
If a building was used previously for a nonresidential purpose, such as a warehouse, office building, or school, and is being converted to multifamily housing, the conversion is not covered. The Fair Housing Act only applies to covered buildings for first occupancy after March 13, 1991. The regulations define “first occupancy” as “a building that has never before been used for any purpose.” See page 12 for additional discussion of “first occupancy.”
The Fair Housing Act does not require any renovations to existing buildings. Its design requirements apply to new construction only – to covered multifamily dwellings that are built for first occupancy after March 13, 1991. First occupancy is defined as “a building that has never before been used for any purpose.” See also “Definitions Used in the Guidelines,” page 16.
A building is not subject to the design requirements of the Fair Housing Act if:
1. it was occupied on or before March 13, 1991,
– or –
2. the last building permit or renewal thereof was issued by a state, county, or local government on or before June 15, 1990.
For a building to be considered occupied, the following criteria must be met:
1. a certificate of occupancy must have been issued,
– and –
2. at least one dwelling unit actually must be occupied.
a. For a building containing rental units, this means that a resident has signed a lease and taken possession of a unit. The resident must have the legal right to occupy the premises, but need not have physically moved in yet.
b. For a building containing for-sale units, this means that a new owner has completed settlement and taken possession of a unit. The new owner must have the legal right to occupy the premises, but need not have physically moved in yet.
A certificate of occupancy, or the fact that units are being offered for sale but not yet sold, would not be an acceptable means of establishing occupancy. For a project consisting of several buildings which are constructed in phases spanning the March 13, 1991 date, first occupancy will be determined on a building-by-building basis.