Mary Cummins, Real Estate Appraiser, Animal Advocates, Los Angeles, California

Mary Cummins, Real Estate Appraiser, Animal Advocates, Los Angeles, California
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Showing posts with label HUD. Show all posts
Showing posts with label HUD. Show all posts

Friday, April 12, 2024

Bias Against Real Estate Appraisers by Mary Cummins

appraisal bias, cindy chance, ceo appraisal institute, mary cummins, real estate appraiser, real estate appraisal, confirmation bias, loss aversion, anchoring bias,

Interesting letter from Cindy Chance CEO of the Appraisal Institute. Basically people who automatically claim appraiser bias are they themselves biased. This is why the false narrative of the "racist white male appraiser" has gained so much traction in the media and with the public. It's gotten to the point that the government made up a fake solution to the fake appraisal bias problem to satisfy the public and garner votes for the upcoming election i.e.  PAVE report. What we appraisers actually do is unbiased. We rely on data, numbers and facts only. Appraising is a math formula. 

When I see some lay people claim appraiser bias I feel that they believe this 100% even though AEI's research based on government data proved this is not true. Racism and bias definitely exist. Sadly blacks, Latinos and others have been and continue to be discriminated against in our country. It appears to be human nature or confirmation bias to assume that past biased behavior will always be repeated. They will assume anything they don't like MUST BE the result of racism, discrimination and bias. They will falsely assume any phrase must be code for a discriminating term like "Marin City" in the Marin case. It was just the name of the subject's city.

I've seen this in many areas besides appraisals. A black woman said a white man told her to smile. She claimed he was racist wanting her to smile like old black minstrels to entertain him. I told her that all men tell all women to smile. I've been told the same in the past and my skin is white. It's not about racism but control, harassment, flirting...  Because the woman was black she automatically assumed it was only because she was black.

Now that we know that the public is biased against real estate appraisers what do we do about it? Hopefully the next parts of this letter will answer those questions. We know Automated Valuation Methods AVMs are not the answer. They are more biased than human appraisers because they don't have all the information needed to do a full valuation. They don't know condition, upgrades, lot type, view, specific location in a neighborhood or if the home even exists. Zillow doesn't even use nearby comps if there are no recent ones of a similar size. They'll go two miles away into a neighborhood worth twice as much to find recent, similar sized homes. I have my own suggestions that may help a little. 

Write your appraisal report knowing biased lay people will be reading and sharing it publicly. Don't use abbreviations or subjective terms. Explain everything in clear simple language at a fifth grade reading level like most newspapers. Show your math. Include your regression charts if necessary. This is especially important if the subject doesn't conform to the median home in the area. I've noticed most of the big media cases of alleged appraiser bias were nonconforming homes with major issues on the edge of two very different neighborhoods. Of course they wanted their home to be worth as much as the larger, upgraded homes with views in a different neighborhood that sells for twice as much even though they initially bought it at a huge discount.

If you are given comps and they are not comparable, mention all of them in your report. They'll end up in a Reconsideration of Value ROV anyway. Specifically state why they are not comparable. State why they are worth more than subject, i.e. larger, fully remodeled, full ocean view, cul-de-sac, different neighborhood... 

If anyone has any suggestions on how to counter bias against appraisers and their reports, please, leave a comment. This is a huge problem that affects us all.

"From Cindy's Desk

I’ve heard from many appraisers, particularly residential appraisers, that the Appraisal Institute should have done better at standing up for them by making the public aware of their skills and professional discipline. I agree. Sweeping, sensationalized claims of “bias” about our profession ignore appraisers’ core skills, ethical standards and professional disciplines. The valuer is the only party to a real estate transaction without a financial interest in its outcome; moreover, the appraiser’s duty is to uphold the public trust, by providing an unbiased, impartial opinion of value based on a rigorous process that is continually refined and improved by the profession. Appraisers are heavily regulated to ensure quality standards, held to a rigorous ethical professional code of conduct, and our SRA and MAI designations reflect the profession’s highest standards. Why then has it been difficult for appraisers to respond effectively as a profession to unfair accusations of bias?

One reason is that claims of bias are antithetical to what appraisers do. (In case you’re interested, philosophers and linguists call this a “failure of presupposition,” and it is hard to address because it assumes something that is not actually the case.) As of now, the public is hearing from the media and politicians about a certain terrible kind of bias. What they need to know is that professional real estate appraisal has long been built on eliminating all kinds of irrational bias. Appraisers, ironically, have been ahead of the curve in working continuously to identify and eliminate every kind of bias from their professional analysis.

Thanks to Daniel Kahneman, who died recently at the age of 90, and his partner Amos Tversky, the scientific community has recognized for over half a century that there is a normal human tendency toward bias, which they termed “cognitive bias.” Their research showed that cognitive bias is part of the way all our brains work normally. In fact, our survival depends upon it.

These Nobel Prize winners (followed by several more in the following decades) demonstrated that our rationality is a myth and bias is the norm, and it has been a good thing for humans, evolutionarily speaking, because bias allows us to not have to think too much in cases where a quick judgment increases our odds of survival. Roughly defined as “any predictable error that inclines your judgment in a particular direction,” bias is a natural feature of the way humans think.

It’s easy to recognize some of our most common biases that reflect what is “normal.” We are naturally more averse (two times more!) to negative consequences than we are attracted to positive consequences. This is called “loss aversion,” which helps explain why we don’t like to change, even when things are going poorly. Being twice as likely to avoid downside as to pursue upside helped kept us away from poison plants and cliff edges, but it also often keeps us from pursuing the best courses of action. There are many, many such examples of normal (not good, but normal and understandable) cognitive bias, including “anchoring bias,” the tendency to rely too heavily on the first piece of information one receives, “availability heuristic,” our tendency to overestimate the importance of information we remember easily, and “confirmation bias,” the tendency to focus on information that confirms our pre-existing hypothesis.

Cognitive bias is powerful and can only be managed through the application of methodologies and procedures that require disciplined analysis of data and information (sound familiar, appraisers?). In fact, cognitive bias is why we depend on professionals trained to be unbiased specifically where our proneness to irrationality could create serious problems, such as science, finance, and economics. Appraisers’ impartial analysis protects the public from our hard-wired, everyday biases that would undermine the healthy function of the real estate industry.

Appraisers are essential to a healthy economy because there are all kinds of opportunities for cognitive bias to infect real property valuation; real estate is a context ripe for “loss aversion,” “anchoring bias,” ”availability bias,” “conformity bias” or “conflict avoidance,” to name a few. Appraisers are trained not to fall into these irrationality traps. Appraisers are continually trained to adjust their opinions of value based on data and professional discipline, precisely to avoid cognitive biases to which homeowners, loan officers, and all of us are susceptible. And in case you think machine learning and AI will save us, it is worth noting that AVMs and AI-generated results are not more rational; on the contrary, machines proliferate biases reliably, that is, unless there are educated appraisers who are regularly producing inputs to correct them.

In reality, appraisers have a great story to tell, but we have a long way to go to refocus the terribly flawed “appraiser bias” narrative onto facts and science. With facts, fairness and science all on our side, and with your help, my team and I have committed to advocacy and communications built on each member’s commitment to doing the right thing, the right way.

There’s more to say about bias. That’s why this is part 1 of a 3-part series on bias…next up…the normal biases of homeowners and loan officers, “noise” and bias, cultural bias, the GSEs, and “banned words”…

Cindy Chance, CEO of the Appraisal Institute"


Mary Cummins of Cummins Real Estate is a certified residential licensed appraiser in Los Angeles, California. Mary Cummins is licensed by the California Bureau of Real Estate appraisers and has over 35 years of experience.


Mary Cummins, Mary K. Cummins, Mary Katherine Cummins, Mary, Cummins, #marycummins #animaladvocates #losangeles #california #wildlife #wildliferehabilitation #wildliferehabilitator #realestate #realestateappraiser #realestateappraisal #lawsuit real estate, appraiser, appraisal, instructor, teacher, Los Angeles, Santa Monica, Beverly Hills, Pasadena, Brentwood, Bel Air, California, licensed, permitted, certified, single family, condo, condominium, pud, hud, fannie mae, freddie mac, fha, uspap, certified, residential, certified resident, apartment building, multi-family, commercial, industrial, expert witness, civil, criminal, orea, dre, brea insurance, bonded, experienced, bilingual, spanish, english, form, 1004, 2055, 1073, land, raw, acreage, vacant, insurance, cost, income approach, market analysis, comparative, theory, appraisal theory, cost approach, sales, matched pairs, plot, plat, map, diagram, photo, photographs, photography, rear, front, street, subject, comparable, sold, listed, active, pending, expired, cancelled, listing, mls, multiple listing service, claw, themls, historical appraisal, facebook, linkedin

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Tuesday, March 12, 2024

Why Did Marcia Fudge "Resign" from HUD? by Mary Cummins Real Estate Appraiser

real estate appraisal,real estate appraiser,resignation,marcia fudge,housing and urban development,HUD,mary cummins,fire,joe biden,quit,cabinet,president,resigned,campaign, democrat
real estate appraisal,real estate appraiser,resignation,marcia fudge,housing and urban development,HUD,mary cummins,fired,joe biden,quit,cabinet,president,resigned,campaign, democrat

*This article has embedded linked research and articles which support the statements. You may not be able to see the links based on your browser settings so hover. Everything in this article is backed up with independent research based on government data.

Today March 11, 2024 Marcia Fudge announced her resignation as the head of the Housing and Urban Development (HUD) Department via email. Her resignation will be effective March 22, 2024. Below is Marcia Fudge's press release about her departure as the Secretary of Housing in President Joe Biden's White House cabinet. The press release also includes a list of her alleged achievements. https://www.hud.gov/press/press_releases_media_advisories/HUD_No_24_048

The New York Times posted an article about Marcia Fudge's departure. https://www.nytimes.com/2024/03/11/us/politics/marcia-fudge-hud-resigns.html The article stated that President Joe Biden told his Department heads last fall that he wanted them to either leave quickly or stay on until after the election. Marcia Fudge promised she would stay then all of a sudden she "resigned" with "mixed emotions." Just March 7, 2024 the White House stated they had a cabinet in place that will stay for the election then four days later she resigned. Many question giving only 11 days notice to leave a cabinet position. One other cabinet member Eric Lander stepped down due to reports of bullying staff. Maybe that was also Fudge's issue. Fudge stated "I do believe strongly that I have done just about everything I could do at HUD for this administration as we go into this crazy silly season of an election." "Silly election season" makes one thinks she believes her departure is politically motivated. Maybe her ouster has to do with the Dept being audited and/or the campaign and election. In the NY Times article she stated she wants to spend more time with her 92 year old mother. If that were true, she would have left a while ago. I saw her at the State of the Union address happily shaking everyone's hands. No one knows the real reason but some have possible explanations for the quick unexpected departure.

As a real estate broker, appraiser I have been following Marcia Fudge very closely ever since she was nominated to be the head of HUD. She had no background in real estate, housing, economics yet she was confirmed to be the head of the Housing Department. Many believe she was appointed because of Joe Biden's diversity promises. He promised to appoint black women to positions of power. I'm all for diversity. We all know Biden's predecessor's cabinet was as white as a sheet and almost all male. We desperately need more people of color and women in the upper echelons of government. They just should be qualified, honest and able to get along with people for the greater good of the nation. As a Representative Fudge was never on a housing committee or involved in any housing organization. Fudge herself even mentions the concept of tokenism by stating to Politico November 2020 “We’re going to have to stop looking at only certain agencies as those that people like me fit in. You know, it’s always ‘we want to put a Black person in labor or HUD.’” Sounds like she didn't even want to be at HUD.

My personal issue with Marcia Fudge is the outright lies she told the American people. Fudge's lies hurt everyone in the US because millions were diverted to "fix" a problem that doesn't exist. That money should have been used to fix the real problem which is income inequality which doesn't even fall under her department. She also defamed and attacked real estate appraisers in the process. 

Fudge promoted the false narrative of the "old white racist male" appraiser low-balling blacks and Latinos without any proof whatsoever. I believe it's because she is racist. She promoted the false and totally misleading paper from Andre Perry's book "Know Your Price." Fudge insisted on stating the lie as fact that live appraisers "low ball" the appraisal values of blacks and Latinos and caused them to lose $156,000,000,000 in home equity. American Enterprise Institute AEI proved that Andre Perry's paper was totally false. 

The real issue is income inequality among whites, blacks, Latinos. People who make more money buy more expensive homes. They also buy more expensive cars. Whites make more money than blacks, Latinos so they buy and own more expensive homes in more expensive areas. The correlation between value of white and black homes is income and not race. Appraisers have nothing to do with income inequality. We appraisers didn't even make the appraisals used in Perry's paper. Perry used totally inaccurate robot Zillow values! Appraisers generally don't even know the race of the homeowners or borrowers.

Perry's paper was based on Zillow robot Automated Valuation Methods and not appraisals made by live appraisers. Fudge didn't care and lied stating "old white male" appraisers were responsible for the differences in value. The narrative fit her racist agenda. Those statements were proven to be totally false by independent research by American Enterprise Institute. There is no racism in real estate appraisal values. Fudge then used this fake paper and false facts to write the Biden ordered PAVE Task Force report. AEI has refuted the report in their reply to the government. Fudge wasted millions in resources to write a fake report about a fake problem then stated she alone could fix it then she didn't. Nothing has changed! Fudge didn't fix anything and definitely not the real issues which don't even fall under her department. The real issue is income inequality which falls under the department of labor. Fudge just wanted the extra funding and attention to her department. The entire PAVE report was based on Fudge's lies and wasn't even needed.

Fudge also promoted her fake story about the home across the highway from her home being worth twice as much as her home "only" because a white person owned it. In fact this lie may have finally been part of her undoing. Late January 2024 Joe Biden told this crazy fake story which is based on Marcia Fudge's outright lie. "Today, a home owned by a Black family on one side of a highway, built by the same  builder on the other side of the highway and a white guy living in it, the white guy's home is valued more than the Black guy's!," he said. "I know you know it. And guess what, that's how you build generational wealth."

I debunked Marcia Fudge's big lie here in this blog by valuing her home and the ones across the highway. You can't find the article via Google search because someone (Marcia?) complained and it was removed from search results. The home across the highway from Marcia Fudge's home is newer luxury quality built in a new private community built way off the highway on private streets. Fudge's home is much older, lower quality, fairer condition built on the main highway. The homes are totally different in very different locations so of course they would have different values. This shows that either Fudge doesn't understand the basics of property valuation and is incompetent to be the head of HUD or she's just a racist liar promoting her own agenda. I doubt she even knows the color of the people who own the homes across the highway from her. Race, color isn't listed on ownership deeds. The tenant isn't always the owner. On top of this Fudge is complaining about their inaccurate Zillow values. She's not talking about their actual market or appraisal values. There are no appraisals of Fudge's home and the homes across the street to compare. No appraisers were involved.

Many real estate experts, agents, appraisers have sent in many letters to HUD about Marcia Fudge's many lies. I've sent in a few. Nothing happened except Fudge repeated the lies. Maybe this story making Biden look like a total blithering idiot was the final straw. Many media sites picked up on the crazy nonsensical story. Fudge has stated this same fake story all over the media. Here I debunk her false CNN presentation. I'm pretty sure these false stories by Fudge would have been used against Biden during the campaign. Clearly Biden believed her bullshit until he repeated her fake home story and everyone called him a crazy idiot. I doubt he'll repeat that story.

Fudge also got way too cozy with lenders, AMCs during her tenure at HUD. They pitched her the idea of getting rid of appraisers/appraisals to save consumers money and time. They lied and supported her lie that appraisers are biased so they could make more money while allegedly reducing bias. They asked to use appraisal waivers, AVMs, drive-by appraisals and hybrid appraisals done by non appraisers. HUD agreed and consumers didn't save any money. Instead lenders, AMCs keep the valuation fee in house for reviewing an AVM. Not only that but waivers, AVMs, drive-by appraisals and hybrids have real built in bias by their very nature. No one really knows the true market value of all those homes. Maybe there was insufficient equity or the homes never met loan requirements. Many of these loans are sold and resold as investment vehicles. Many could go bad and they actually have. 

Another issue I have with Fudge is her giving government money to her friends. Fudge gave grants to her friends at private fair housing organizations. These organizations promoted Fudge's false narrative of the racist white appraiser. They stated their research, legal actions against innocent appraisers are the "solution" to US's housing issues. Government money was wasted and lives were destroyed in the process while no racial bias was found. They supported and widely shared the fake paper by Andre Perry. Maybe she was finally caught giving contracts to close, close friends. Her cronyism at HUD was definitely off the charts. 

Another issue though minor is Fudge violating the Hatch Act. In March 2021, during a White House press conference, Fudge made comments on the upcoming Senate election in her home state of Ohio suggesting that Democrats could win it. As a result, she was accused of violating the Hatch Act of 1939. After an investigation, the Office of Special Counsel determined she had violated the Hatch Act. Fudge received a warning. Not a big deal really but still.

Another point "in 2015, Fudge wrote a letter asking for leniency in the sentencing of Cleveland politician Lance Mason on felony assault and domestic violence charges. Fudge described Mason as "kind", and wrote that "Lance [...] has assured me that something like this will never happen again." Mason subsequently attacked and killed his ex-wife, in 2018, stabbing her 59 times. After the murder, Fudge released a statement saying she condemned the crimes committed by Mason."

On top of all of this Fudge is extremely abrasive and abusive. She truly enjoys attacking, degrading appraisers and others in public meetings. She has a huge race, wealth chip on her shoulder which she doesn't hide but proudly flaunts. She wanted to be the head of Agriculture Dept so that may be part of it. Almost every meeting she starts in the same way walking to the podium and stating "Good afternoon." If everyone in the room does not loudly say "Good afternoon, Madam Fudge!" she will put her finger in her ear, shake her head at the audience negatively like she didn't hear their response and say it again to force people to respond as if the audience were in the army or prison. She clearly has major personal insecurities to feel the need to treat people in this manner. One example here https://www.instagram.com/p/C4Y8FhuOiu_/ 


If you search this blog, you will see the other articles I've written about her insulting, harassing, demeaning behavior in government meetings. I highly doubt she wanted to leave this position on her own as she clearly enjoys and relishes being abusive. I believe she was pushed out which is why she has "mixed emotions." Maybe the campaign audited her department and realized she was wasting funds and not accomplishing the goals of HUD. This will be used against Biden in the campaign and election by the GOP. 

I personally feel Marcia Fudge was probably asked to resign because she's a liability in the upcoming election. The lie she told to Joe Biden about her home value which he repeated was the wake-up call for Biden's campaign. The lies she told in the PAVE report and government money she wasted on worthless "solutions" were probably other factors. Her cronyism and giving money to friends also hurt her. Lastly her horribly abrasive, abusive personality and media appearances harm Biden and his campaign. 

Fudge's press release about her departure reads like a golden handshake. She mainly touts a few odd suspect accomplishments resume style. I think she saw the end coming because of an investigation into her actions because she released something similar in February which I thought was odd. It wasn't end of year reporting. I'll be writing another article about her housing "accomplishments" during her term but a few notes. Don't get me wrong. She was 1,000x better than Ben Carson. I just think Trump probably told him to run the Dept into the ground. Even I could have done better than Carson.

"HUD's mission is to create strong, sustainable, inclusive communities and quality affordable homes for all." Our housing crisis is much worse since she was head of HUD. Per HUD homelessness is way up and housing affordability is way down. Things haven't improved. Here's just one fake accomplishment from her list "Ensuring that people who have paid their debt to society can get a fair shot at a second chance and have a home;"  Fudge proposed changing a rule to allow convicted criminals convicted of fraud or perjury to do work for HUD in relation to fair housing investigations. Why would someone hire someone convicted of lying and committing fraud to do legal investigations which could possibly end up in a court of law? Their testimony could be easily tossed because they are convicted liars. Comments were due 01/11/24. I don't know if it became law. 

Fudge's replacement will be Deputy Secretary Adrianne Todman. Joe Biden will not nominate a new head until after the election. They'd never be confirmed in time before the election. Todman is just like Fudge so nothing will change until they find a new head. I can only hope they find someone who is qualified who won't lie and can actually improve housing for our country. We don't have enough housing which is one cause of the homeless and affordability issues. It's also an issue for our economy especially because of recent rate hikes. We also have an income inequality issue.

@secfudge @hudgov @mary_cummins



Mary Cummins of Cummins Real Estate is a certified residential licensed appraiser in Los Angeles, California. Mary Cummins is licensed by the California Bureau of Real Estate appraisers and has over 35 years of experience.


Mary Cummins, Mary K. Cummins, Mary Katherine Cummins, Mary, Cummins, #marycummins #animaladvocates #losangeles #california #wildlife #wildliferehabilitation #wildliferehabilitator #realestate #realestateappraiser #realestateappraisal #lawsuit real estate, appraiser, appraisal, instructor, teacher, Los Angeles, Santa Monica, Beverly Hills, Pasadena, Brentwood, Bel Air, California, licensed, permitted, certified, single family, condo, condominium, pud, hud, fannie mae, freddie mac, fha, uspap, certified, residential, certified resident, apartment building, multi-family, commercial, industrial, expert witness, civil, criminal, orea, dre, brea insurance, bonded, experienced, bilingual, spanish, english, form, 1004, 2055, 1073, land, raw, acreage, vacant, insurance, cost, income approach, market analysis, comparative, theory, appraisal theory, cost approach, sales, matched pairs, plot, plat, map, diagram, photo, photographs, photography, rear, front, street, subject, comparable, sold, listed, active, pending, expired, cancelled, listing, mls, multiple listing service, claw, themls, historical appraisal, facebook, linkedin

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Friday, January 12, 2024

McKissock Learning Will No Longer Offer PAREA Due to Costs by Mary Cummins Real Estate Appraiser

mckissock learning, mckissock,appraisal institute, parea, real estate appraiser, mary cummins, real estate appraisal, training, certified, residential, license, hud, fha
mckissock learning, mckissock,appraisal institute, parea, real estate appraiser, mary cummins, real estate appraisal, training, certified, residential, license, hud, fha

PAREA is the Practical Applications of Real Estate Appraisal. In order to become a licensed appraiser you currently need about a year or two and 1,000-1,500 hours of training experience as a trainee with another licensed and generally certified appraiser. You also need basic classes and other requirements. Because it was so difficult to find mentors willing to train trainees for free the government allowed the PAREA training alternative to hours with a live mentor. Real Estate Appraiser education provider McKissock Learning was going to be one of the government approved companies, organizations offering PAREA training. The Appraisal Institute is another organization offering the training. 

Yesterday January 12, 2024 McKissock emailed people who were interested in the program that they would no longer be offering the PAREA program. See below email.

"Happy New Year to you and yours. We hope this letter finds you well. With a strong commitment to responsibility and transparency, we want to inform you about a significant decision regarding the McKissock PAREA (Practical Applications of Real Estate Appraisal) project.

After careful consideration and thorough evaluation of various factors, we have made the difficult decision to cancel the McKissock PAREA project. We understand that this news may be unexpected, and we want to provide you with a clear understanding of our reasoning and the steps we are taking moving forward.

One of the primary factors contributing to the cancellation is the substantial resource cost required to provide a product of the quality we envisioned. In our pursuit to deliver a premium solution, the associated costs exceeded initial estimates, resulting in a higher-end price to our customers. Regrettably, we recognize that this higher cost would inadvertently create a new barrier to entry into the appraisal profession – specifically, a financial obstacle."

The cost of the program was always a major issue and hurdle to entrance in the field. You couldn't even start the program without first paying for and taking $1,700 worth of McKissock classes. The Appraisal Institute stated the PAREA program would cost about $10,000 per a July 19, 2023 webinar. All of the training would be online. There would be no in person mentorship. 

From a monetary point of view the expensive cost of the training might be a total waste without real mentorship. This is not a trial an error occupation. You need someone training you in the beginning. You won't make any money if you don't know what you're doing. The only people who could end up making money from the training were possibly the training organization. They'd make money from government grants, nonprofit grants and class fees from paying students. It'd be like those worthless online degrees.

Another main problem is the real estate appraisal market today is at its absolute lowest point. There's very little lending work. The main cause is our current high interest rates. No one is selling if they have to buy another home. Why lose a 2.5% interest rate and triple your monthly mortgage at 7.5% or so. No one would want to refinance for the same reason. Sales volume is at its lowest in about 20 years per Ryan Lundquist's fantastic statistics. I've seen the same in Los Angeles, California.

Another even bigger issue is the use of live appraisers has been decreasing recently because of appraisal waivers, AVMs (Automated Valuation Methods) and hybrid type appraisals. Even though a live appraiser is used for part of the hybrid appraisal they aren't being paid as much as a full appraisal, i.e. $75-$165 vs $300-$500. The few full inspection appraisals done by live appraisers are very complex appraisals which only appraisers with many years experience are allowed to do. There's just not as much work today for anyone.

Previously the government said there were not enough appraisers and now there are definitely way too many. If you look at Facebook appraiser groups, everyone is hurting. Many have retired or had to get side gigs. If a fully trained and experienced appraiser of 20 years can't get work, a newbie has no chance at making enough money to survive. Even people with 20-40 years of experience are quitting due to lack of work.

You'd have to really be an idiot to shell out $1,700 for basic classes, $10,000 for PAREA, $6,000 appraisal costs first year just to make no money. Few can afford that upfront cost even if they could make the money back in a year or two. Another huge hurdle is lenders only use appraisers with three years minimum experience. No one would hire you fresh out of PAREA. 

I believe that McKissock realized there probably won't be enough people willing to pay for the classes at the moment to justify their training costs. They couldn't make enough profit off the program today. Even if the government and nonprofits offered grants to pay for the training the students probably wouldn't get any work from the program. No one would be happy. There would be a lot of online complaints.

I'm actually glad McKissock is not continuing with the program at this time for the sake of the potential new appraisers. Now is not the time to start out as an appraiser because of the market conditions. I would at a minimum wait until things rebound when rates go down. Maybe by then there will be an affordable PAREA program maybe subsidized by the government for people who can't afford it. You'd still need live experience and will have to deal with all the other issues noted above but it'd be better than what we have today. 

*FTR I've been taking classes with McKissock since they first started around 1990. Back in the day they only offered in person classes taught by the McKissock's out of a small classroom in Orange County, California. Today I take bundled classes with Calypso because they're cheaper. 


Mary Cummins of Cummins Real Estate is a certified residential licensed appraiser in Los Angeles, California. Mary Cummins is licensed by the California Bureau of Real Estate appraisers and has over 35 years of experience.


Mary Cummins, Mary K. Cummins, Mary Katherine Cummins, Mary, Cummins, #marycummins #animaladvocates #losangeles #california #wildlife #wildliferehabilitation #wildliferehabilitator #realestate #realestateappraiser #realestateappraisal #lawsuit real estate, appraiser, appraisal, instructor, teacher, Los Angeles, Santa Monica, Beverly Hills, Pasadena, Brentwood, Bel Air, California, licensed, permitted, certified, single family, condo, condominium, pud, hud, fannie mae, freddie mac, fha, uspap, certified, residential, certified resident, apartment building, multi-family, commercial, industrial, expert witness, civil, criminal, orea, dre, brea insurance, bonded, experienced, bilingual, spanish, english, form, 1004, 2055, 1073, land, raw, acreage, vacant, insurance, cost, income approach, market analysis, comparative, theory, appraisal theory, cost approach, sales, matched pairs, plot, plat, map, diagram, photo, photographs, photography, rear, front, street, subject, comparable, sold, listed, active, pending, expired, cancelled, listing, mls, multiple listing service, claw, themls, historical appraisal, facebook, linkedin

DISCLAIMER: https://mary--cummins.blogspot.com/p/disclaimer-privacy-policy-for-blogs-by.html

Friday, August 11, 2023

AEI Report Shows Andre Perry's Paper is Fraudulent. Same Difference in Home Values in White Areas.

This is from an email from Jeremy Bagott, MAI. AEI used Andre's Perry own dataset and methodology to study race and home values.  February 2023 the report was updated. Andre Perry previously stated the main difference in home values between white and black is race alone. Perry blamed that on home valuations. AEI's research has proven the main difference is caused almost entirely by socioeconomic factors and not race. I've been yelling this from the mountain tops since Perry's paper first came out but AEI has nailed it down with facts and independent research. People who make more money have more money and buy more expensive homes in more expensive areas, period. 

Maybe lower income white people should be yelling about home value differences compared to higher income white and black people. Maybe they should be demanding money, free homes, cheap loans, debt relief like Andre Perry and his following have been doing. "Rich white people have stolen $46,000 from every poorer white person's home value in the US!" Maybe all poor people need their own type of reparations for being trapped by low wages and poverty for generations. It won't solve the problem because the income gap is the main cause for everyone but the story will probably sell online media ads. We need to reduce the income/wealth gap among everyone. AEI stated this in their summary but the government will not listen to facts for some reason on this issue.

https://mailchi.mp/0b513ed845f9/report-finding-of-bias-in-home-valuations-fails-by-own-measure-8037698

"REPORT: FINDING OF BIAS IN HOME VALUATIONS FAILS BY OWN MEASURE

VENTURA, Calif. (August 11, 2023) – In an updated refutation of the findings of Brookings Institution researcher Andre Perry, Edward Pinto and Tobias Peter of the AEI Housing Center demonstrated just how broken the Brookings research was.

Perry’s 2018 research, titled “The Devaluation of Assets in Black Neighborhoods,” pinned the nation’s racial wealth gap on 80,000 state-licensed real property appraisers.

Unfortunately, these now-discredited findings have been levered by housing-industry lobbyists, partisan policymakers, agitators and grievance groups to malign the nation’s 80,000 real property appraisers and hollow out America’s mortgage underwriting safeguards.

A dataset provided to Pinto and Peter earlier in the year by Perry allowed the AEI Housing Center to fully refute the latter’s conclusions.

While their original refutation was still largely correct, Pinto and Peter have now updated their key findings and takeaways using the new dataset. To the surprise of no one, their redacted study found that what Perry et al. had characterized as race-based differences in home valuations were almost entirely due to socio-economic status, not racial bias by real estate appraisers.

Using the dataset and Perry’s own methodology, Pinto and Peter created a simple case study of so-called “entirely white” tracts (tracts demographers rate as 97.5% white or greater). In those tracts, racial animus, by definition, is ruled out as a factor. The duo then compared high and low socio-economic status in these so-called all-white neighborhoods and found differences as large as – or even larger than – the ones Perry et al. incorrectly attributed to racial bias.

But much damage has been done by Perry’s now-discredited findings. Perry’s 2018 report took the nation’s real property appraisers from the table and onto the menu. The flawed findings have most recently served as a pretext to justify the current administration’s whole-of-government effort to insert race into every corner of the mortgage underwriting process, including collateral valuation.

Pinto and Peter determined:

• That while lower socio-economic status may leave blacks at a large income (and wealth) disadvantage relative to most whites, this is not due to any statistically relevant bias in home appraisals

• The primary remedy would be policies that work to address the income and wealth gap, not those that scapegoat appraisers.

• The focus should be on increasing financial security, creating generational wealth, and shrinking the socio-economic gap through sustainable home ownership. This is largely a buying power issue, not a valuation one. To do otherwise risks repeating the mistakes of the past."


Mary Cummins of Cummins Real Estate is a certified residential licensed appraiser in Los Angeles, California. Mary Cummins is licensed by the California Bureau of Real Estate appraisers and has over 35 years of experience.


Mary Cummins, Mary K. Cummins, Mary Katherine Cummins, Mary, Cummins, #marycummins #animaladvocates #losangeles #california #wildlife #wildliferehabilitation #wildliferehabilitator #realestate #realestateappraiser #realestateappraisal #lawsuit real estate, appraiser, appraisal, instructor, teacher, Los Angeles, Santa Monica, Beverly Hills, Pasadena, Brentwood, Bel Air, California, licensed, permitted, certified, single family, condo, condominium, pud, hud, fannie mae, freddie mac, fha, uspap, certified, residential, certified resident, apartment building, multi-family, commercial, industrial, expert witness, civil, criminal, orea, dre, brea insurance, bonded, experienced, bilingual, spanish, english, form, 1004, 2055, 1073, land, raw, acreage, vacant, insurance, cost, income approach, market analysis, comparative, theory, appraisal theory, cost approach, sales, matched pairs, plot, plat, map, diagram, photo, photographs, photography, rear, front, street, subject, comparable, sold, listed, active, pending, expired, cancelled, listing, mls, multiple listing service, claw, themls, historical appraisal, facebook, linkedin

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Thursday, July 20, 2023

PAREA Update from David Samnick - Practical Applications of Real Estate Appraisal , comment by Mary Cummins

parea, practical applications of real estate appraisal, mary cummins, real estate appraiser, real estate appraisal, los angeles, california, hud, ai, appraisal institute, mckissock, aqb, Appraiser Qualifications Board, mentor, trainee, license, certified residential, 

I haven't been following PAREA as closely as I should have but thankfully appraiser David Samnick has been following it. He attended an Appraisal Institute meeting yesterday about the program. It's disheartening to say the least. The purpose of PAREA was to make it easier, cheaper and faster for new appraisers to get the training and hours of real life experience they need to get their license. A main purpose was to help diversify appraisers by making it cheaper and getting rid of the mandatory mentor/trainee. Lower income people can't work as a trainee for free for two years. I wrote a few articles about this huge obstacle to getting a license. Here's one from June 2021. https://mary--cummins.blogspot.com/2021/06/difficulties-becoming-real-estate.html

This post below by David Samnick makes it clear that AI and others such as McKissock have used the issue of diversity just to line their pockets with money. The Appraisal Institute, McKissock make money selling education hours to appraisers. AI got a grant from the government to work on PAREA. May 18, 2023, the AQB approved the first PAREA program, belonging to the Appraisal Institute (AI). I wish I were wealthy and retired so I could train people for free. I'd only train POC if that were legal and not discriminatory.

"Practical Applications of Real Estate Appraisal (PAREA) is a program that aims to revolutionize the real estate industry by increasing the number of appraisers. However, after listening to the Appraisal Institute speaker at yesterdays board meeting it quickly became evident that this initiative is a complete failure.

A) You cannot start PAREA until you have received all your real estate appraisal education. 94 hours = $1,700 per McKissock

B) Appraisal Institute speaker said that most AMC's/banks won't accept licensed appraisers work so he suggests going the CR route. Cost to become a CR appraiser through PAREA - $10,000

C) PAREA is a complete online course. Zero mentorship in the real world. No physical measuring. No driving. No real time experience. No true mentorship.

D) No discussion with the PAREA student about the pay to play. Multiple MLS services, E&O insurance, business expenses, accounting, appraisal software, computers, reliable transportation, and other miscellaneous expenses. Total costs can exceed $6,000 per year.

E) The Appraisal Institute said that this would increase diversity into the appraisal field yet could not tell us the breakdown of how many applicants were minorities.

F) PAREA graduates will be scooped up by AMCS to sign off on Hybrid reports performed by third party data collectors.

G) PAREA graduates have no geographic competence.

H) Total cost for PAREA at the end of the day = $17,700 and potentially more.

 

The Average Joes argued several points in the board meeting.

A) A graduate of the PAREA course would be paid and treated like a trainee as they have no real-world experience.

B) We could have more appraisers back into the industry if banks/amcs would allow appraisers to use their trainees.

C) Reinstate Licensed appraisers to be able to mentor new trainees. This would introduce the next generation of appraisers into the business.

D) Petition FHA to reinstate any licensed appraiser who took the FHA course and had to pass the test.

E) More appraisers would hire trainees if the AMC model wasn't taking so much money out of the pockets of working appraisers. Work is slow. Most have the mentality that my bills come before your bills.

 

In closing PAREA launched in 2019. And the program has not been successful in diversifying the appraisal profession. In fact, a study by the Appraiser Qualifications Board found that the PAREA program has had a negative impact on diversity in the appraisal profession.

The study found that the PAREA program is disproportionately used by white appraisers. In fact, white appraisers are more than twice as likely to use the PAREA program than minority appraisers. The study also found that the PAREA program is not as effective in providing a more accessible pathway to licensure as the traditional apprenticeship model."

https://www.linkedin.com/feed/update/urn:li:activity:7087764386198556672/

Below was stated May 2023 by AI. “Market research has shown that value proposition—what PAREA is worth to someone in the marketplace—is around $5,000,” DiBiaso said. “Our pricing strategy may be different than that and include scholarships and discounts and payment plans. We have a commitment to The Appraisal Foundation that we will give preference of our scholarships to minorities, veterans, and people who indicate a willingness to serve in rural areas. The scholarships will come from a number of different sources including AI.” 

McKissock stated their program will be ready June 2023. “We are investing heavily in the technology tools that appraisers use,” Nancy Gerome said, McKissock’s appraisal general manager. “Our hope is to have them consistently trained. You’ll get all different types of properties and scenarios because we’re leaning into the technology and experience. We’re trying to be thorough, that’s why we’re taking our time. We want to get it right.”  

McKissock staff is preparing their launch to accommodate thousands of trainees, over a staggered period. They estimate the average time a person will take to complete the program is six months. The cost for participating is not yet determined. Staff did confirm there will be a “buy now, pay later” option, as well as scholarships.  

“We are building a scholarship program because we know one of the goals of PAREA is to bring diversity into the profession, and we want to make it as affordable as we can,” Gerome said. Those interested in participating in a PAREA program of either McKissock or AI need to have already completed their Qualifying Education. "

Clearly when the government said there was a probably with diversity among real estate appraisers and the government would give money to help diversify appraisers all these companies heard was MONEY. They will just be training more appraisers for more money and the appraisers will probably all still be mainly older white men. 

Appraisal Institute talks about grants and scholarships for POC and women all the time. I tried to apply and they said I have to pay to join their organization before they'd even talk about it. What if I had no qualifications or were denied? I'd be out the membership fee which is not cheap. It normally costs $15,000 to become an AI MAI appraiser even though I have 40 years of experience and have taken every publicly available real estate appraisal class in existence over the last 40 years. This is clearly a racket when you consider the government gave them money for the program. Gate keeping with a membership fee to the Appraisal Institute before you can access government funding.


Mary Cummins of Cummins Real Estate is a certified residential licensed appraiser in Los Angeles, California. Mary Cummins is licensed by the California Bureau of Real Estate appraisers and has over 35 years of experience.


Mary Cummins, Mary K. Cummins, Mary Katherine Cummins, Mary, Cummins, #marycummins #animaladvocates #losangeles #california #wildlife #wildliferehabilitation #wildliferehabilitator #realestate #realestateappraiser #realestateappraisal #lawsuit real estate, appraiser, appraisal, instructor, teacher, Los Angeles, Santa Monica, Beverly Hills, Pasadena, Brentwood, Bel Air, California, licensed, permitted, certified, single family, condo, condominium, pud, hud, fannie mae, freddie mac, fha, uspap, certified, residential, certified resident, apartment building, multi-family, commercial, industrial, expert witness, civil, criminal, orea, dre, brea insurance, bonded, experienced, bilingual, spanish, english, form, 1004, 2055, 1073, land, raw, acreage, vacant, insurance, cost, income approach, market analysis, comparative, theory, appraisal theory, cost approach, sales, matched pairs, plot, plat, map, diagram, photo, photographs, photography, rear, front, street, subject, comparable, sold, listed, active, pending, expired, cancelled, listing, mls, multiple listing service, claw, themls, historical appraisal, facebook, linkedin

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Monday, April 10, 2023

HUD only cares about appraisals UNDER contract price which is dangerous by Mary Cummins

appraisal value over under contract sales price, mary cummins, real estate appraiser, real estate appraisal, fannie mae, percent sales price, contract price, appraisal, value
appraisal value over under contract sales price, mary cummins, real estate appraiser, real estate appraisal, fannie mae, percent sales price, contract price, appraisal, value

Dave Towne sent out this linked article about bias and appraisal gap.

"The article below was in the Inside Mortgage Finance Publications e-newsletter on 4/06/23:

"FHFA Data Fueling Looks into Appraisal Bias

dhollier@imfpubs.com

The Federal Housing Finance Agency is a is a critical provider of the data necessary for oversight, enforcement and research, FHFA Director Sandra Thompson noted during a discussion in late March.

According to aggregate statistics from the Uniform Appraisal Dataset released by the FHFA, roughly 57% of appraisals were above the contract price in 2021. Just 15.2% were below the eventual sale price, but these are the under-valuations that could possibly reflect bias.

And the important datum here is that this percentage is growing. In 2013, only 8.4% of appraisals came in under the contract price.

In addition to providing data, Thompson noted that FHFA has coordinated with the Department of Housing and Urban Development, the Consumer Financial Protection Bureau and the Department of Justice “to provide additional information for fair lending enforcement and oversight.”

If this actually reflects the true thinking of Ms. Thompson, she has aligned with so many others who believe SALE PRICE is immutable, and is the ultimate indicator of Value, and apparently, of bias, when not accepted as gospel by the appraiser.  My gosh, what a misguided opinion!

Apparently Ms. Thompson didn’t see, experience or understand what happened during the ‘pandemic era’ in mid-2020-early ‘22, when overly emotional, and irrationally exuberant buyers paid astronomical prices for homes way above what their actual value was.  The same thing happened in 2006-2008.....but it wasn’t considered ‘bias’ then due to the different political climate and attitude at that time.

Conversely, how can it be said that valuing a property lower than its eventual sale price based on current market evidence is tantamount to BIAS?  And, if 57% of the appraised values were ABOVE the sales price, couldn’t that also reflect BIAS?  Seems to me that if one comparison in one direction is considered bias, the other in the opposite direction can be equally judged the same.

To better understand this concept, look up the definition of bias.

The political drumbeat of appraisal bias just because an appraisal Value doesn’t reflect Sales Price is blatantly wrong-headed.  In fact, it reflects internal personal bias at worst, and exhibits a definite lack of understanding of the appraisal process, by the person promoting such falsehoods.

More appraisers should stand up and challenge Ms. Thompson’s assertions."

I agree that we should be looking at the over valuations. That is probably where most of any alleged "bias" would be. In the major media cases of alleged bias the first lower appraisal is considered the wrong one when it was actually the higher second appraisal that was wrong and above market value. 

The second higher appraisals were influenced, biased by the AMC, Lender and borrowers who stated the first appraisal was too low. The second appraiser knew there'd be a complaint or lawsuit if they didn't come in high. Clearly the second appraiser was influenced to come in over market value. In the appraiser's eyes he has much to lose coming in at market and much to gain by coming in above market. That's all fine until the borrower goes under and the gov reviews the appraisal in default which they stated they will do. This is a concern because the current economy and real estate market is going down. People are losing jobs as interest rates rise. More homeowners could end up under water and in default. 

Things are a little similar to the beginning of the Great Recession. We all know what happened after the Great Recession. The gov pushed appraisers to come in high to meet higher values. After values dropped the government blamed appraisers! We report values. We don't set them. The gov caused the huge run up with reduced financial regulations and programs which helped lower income people take on loans they couldn't easily afford. The gov caused great financial damage to the people they said they were helping.

Image above came from this article
https://www.fanniemae.com/research-and-insights/perspectives/opportunities-improve-value-appraisals

Nice quote from the above linked article, "Reforms following the 2008 housing crisis attempted to improve the independence and accuracy of appraisals, and some early research indicated these reforms were marginally successful, with the percent of transactions confirmed falling from a high of 98 percent in 2007 to 94 percent in 2009. Confirmation rates, however, have since drifted back up as we have moved further away from the financial crisis."

So was it the financial crisis or reforms which caused change in % of appraisals meeting contract price?

What's interesting is there were appraisals done pre and post contract. When the appraiser knew the contract price, the value was more likely to meet or exceed that contract price. Maybe appraisers shouldn't know the contract price because it clearly influences them. Fannie Mae even makes that suggestion in their article.

Fannie Mae knows the industry and what's really happening. They can't speak freely because they are dependent upon HUD and the government no matter how "independent" they claim to be. For this reason they kiss HUD's ass and support all this false alleged appraisal bias. AEI's research has shown there is no appraisal bias based on race in the government's own data. HUD still falsely insists there is for political reasons. 2024 elections are coming. I bet Dem candidates will still be hawking racial appraisal bias in their campaigns to get the black, brown vote. They will claim they already solved most of the alleged bias but will continue to do more.


Mary Cummins of Cummins Real Estate is a certified residential licensed appraiser in Los Angeles, California. Mary Cummins is licensed by the California Bureau of Real Estate appraisers and has over 35 years of experience.


Mary Cummins, Mary K. Cummins, Mary Katherine Cummins, Mary, Cummins, #marycummins #animaladvocates #losangeles #california #wildlife #wildliferehabilitation #wildliferehabilitator #realestate #realestateappraiser #realestateappraisal #lawsuit real estate, appraiser, appraisal, instructor, teacher, Los Angeles, Santa Monica, Beverly Hills, Pasadena, Brentwood, Bel Air, California, licensed, permitted, certified, single family, condo, condominium, pud, hud, fannie mae, freddie mac, fha, uspap, certified, residential, certified resident, apartment building, multi-family, commercial, industrial, expert witness, civil, criminal, orea, dre, brea insurance, bonded, experienced, bilingual, spanish, english, form, 1004, 2055, 1073, land, raw, acreage, vacant, insurance, cost, income approach, market analysis, comparative, theory, appraisal theory, cost approach, sales, matched pairs, plot, plat, map, diagram, photo, photographs, photography, rear, front, street, subject, comparable, sold, listed, active, pending, expired, cancelled, listing, mls, multiple listing service, claw, themls, historical appraisal, facebook, linkedin DISCLAIMER: https://mary--cummins.blogspot.com/p/disclaimer-privacy-policy-for-blogs-by.html

Thursday, March 23, 2023

Biden Claims to Have "Fixed" the Alleged Racial Bias in Home Valuations but Didn't, by Mary Cummins




UPDATE: 03/24/23 Marcia Fudge just said the same thing in a video almost word for word. Notice how different her tone of voice is in this video compared to other videos. Here she is speaking slow, politely, calmly and even has an interesting accent which is very different than her normal speaking voice. She's not as sharp, condescending, abrasive, abusive or calling all appraisers and whites racists like she usually does. She is flat out lying when she says data proves that "appraisal bias is real." There is no data or research which proves that. There is research based on the government's data which proves it does not exist in the reports and valuations.
https://www.linkedin.com/company/hud/videos/native/urn:li:ugcPost:7044684730058895360/

ORIGINAL: Today the White House claimed they "fixed" the alleged "racial and ethnic bias in home valuations." They claim the Biden-Harris PAVE task force has "fixed" the "wealth gap" among whites and blacks, browns related to home value.  https://www.whitehouse.gov/briefing-room/statements-releases/2023/03/23/fact-sheet-biden-harris-administration-tackles-racial-and-ethnic-bias-in-home-valuations/ This is beyond misleading and couldn't be further from the truth.

Let me preface this by stating I'm a Latino Democrat woman who voted for Biden. I support Biden in most of his policies. I do not support his policies related to real estate appraisers and the appraisal industry. Biden, Harris merely created a non-existent problem to get black, brown votes. They stated they alone can fix the problem if elected. They formed the PAVE task force to fix the made up problem. Then they claimed they fixed the problem. Ta da! Pat on back. No easier problem to solve than a nonexistent one.

Nothing has really changed. The main reason is because the problem never existed. The "fixes" also already existed. Black, brown owned homes are worth less than white owned homes because of the income gap. It's a fact that blacks, browns make less money than whites. If you make less money, you have less money in general and less generational wealth. If you have less money, you buy a less expensive home than someone who makes more money. That less expensive home is in a less expensive area. Here is research provided to the PAVE task force which proves this https://www.aei.org/research-products/report/aei-housing-center-response-to-perry-and-rothwell-2021/ . Appraisers are not appraising the homes differently based on race! People who make less money also buy and own less expensive cars. Are car values also the fault of "biased" real estate appraisers?

The release states "In just 12 months, the PAVE Task Force has made critical progress towards fully implementing the Action Plan, including by empowering consumers with new tools and greater awareness of appraisal bias; leveraging data to identify trends and crack down on offenders of appraisal bias; and supporting a well-trained and dynamic appraiser profession." Let's take a look at these three areas of "success."

1. "Empowering consumers to take action against appraisal bias."

They claim borrowers can now file a Reconsideration of Value if they don't like the value. Borrowers have always been able to file a ROV! I've seen ROVs for at least 30 years. HUD stated they're giving $54,000,000 to private non-profits to help them educate the public about ROVs and related items. A huge waste of funds that should have been used to solve the income gap problem and actually help people. This also shows the agenda of the private nonprofits receiving the funds. They will support this flawed idea to get millions of dollars.

2. "Increasing transparency and leveraging federal data to inform policy and improve enforcement against appraisal bias."

They've released similar data for at least 20 years. This is how people have been able to do research on appraisals and home sales, values. This research on this "new" data proved there was no racial bias by appraisers. It also proved that the values are based on location. Remember the three biggest indicators of value are location, location, location. This data proved that the main correlation between home value and borrower is income and not race.

3. "Cultivating an appraiser profession that is well-trained and looks like the communities it serves. The Administration is taking steps to remove unnecessary educational and experience requirements that make it difficult for underrepresented groups to access the profession and to strengthen anti-bias, fair housing, and fair lending training of existing appraisers."

They proposed adding education on bias as part of license requirements and it's not even final yet. This was already a requirement and had been a requirement since at least 1989. Appraisers were talking about using different types of experience i.e. PAREA, to get a license long before Biden was elected or any talk of racial bias. The apprentice experience program is difficult for people of every color and race. They still have not finalized a change in the requirements for experience. While they talked about making appraisers more diverse there has not been an actual change in the diversity of appraisers. Luring black, brown people to become a new appraiser in a market with no business that requires three years minimum experience to get work is actually a cruel thing to do to lower income people.

Most upsetting in this puff release is they mention the Austin lawsuit in Marin, California, "Austins' home was appraised at roughly $500,000 more than its initial appraised value after having a white friend stand in for them. Earlier this month, the Tate-Austins settled a housing discrimination lawsuit." They forget to mention that the Defendant not only didn't admit wrong doing but there was no wrong doing on the part of the first appraiser. They assumed the second appraisal was correct when it wasn't. The first appraiser only settled because of legal fees and harassment which the Federal government encouraged and aided. Having a white friend stand in for them had no effect on value. They requested another appraiser and appraisal from the same AMC. That appraiser knew the borrower's target value and wanted to please the borrower for fear of a lawsuit and AMC, lender to keep getting work.

This entire issue of alleged bias in appraising is beyond frustrating, maddening and sad. It makes me wonder how many other fake problems were created in politics just to get votes. How many other "we fixed the problem!" statements were just fake puff statements like this one. The worst part is the administration hasn't helped the people who are suffering from the income gap among white and black, brown. It's clearly easier to call appraisers "racists" and blame them for the wealth gap than fix the real problem of income disparity.

*I'm using "black," "brown" because that is what the release states to be clear.

Mary Cummins of Cummins Real Estate is a certified residential licensed appraiser in Los Angeles, California. Mary Cummins is licensed by the California Bureau of Real Estate appraisers and has over 35 years of experience.


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Monday, February 20, 2023

Rebuttal to Marcia Fudge's Misleading 2022 CNN Interview by Mary Cummins Real Estate Appraiser

Marica Fudge, HUD, Laura Coates, CNN, interview,Mary Cummins real estate appraiser, bias, discrimination, racism,white, black, Latino, home value, 


Marcia Fudge of the Housing and Urban Development Department (HUD) was on CNN August 22, 2022 with Laura Coates discussing alleged appraisal bias. "Housing and Urban Development Sec. Marcia Fudge says her department is examining the process in which home appraisers collect data, which she says is systemically biased against people of color." "HUD Secretary On Battle Against Racism In Real Estate."

Here is a link to the show:   https://www.cnn.com/videos/business/2022/08/22/hud-sec-fudge-racism-in-home-appraisal-process-coates-intv-ctn-vpx.cnn

Here is a link to the transcript: https://transcripts.cnn.com/show/se/date/2022-08-22/segment/01

Marcia Fudge continues to promote the false narrative of the alleged "racist appraiser" "devaluing black owned homes." Marcia Fudge has the facts and independent research yet actively intentionally promotes the false narrative to promote her own agenda. Fudge's agenda is to get media attention for herself and more money for her department. Fudge and politicians have created this problem so they can state they alone can fix it. In fact based on what Fudge said in the interview the problem has already been fixed just by doing the same thing they've done for years.

The real issue is the income gap. White owned homes are valued more than black, Latino owned homes because of the income gap. Whites make more money than blacks, Latinos. The more money you make, the more money you have. The more money you have, the more expensive home you can buy and own. The more expensive home you have, the more generational wealth is created.  If you want to fix the home value gap, fix the income gap. Fudge won't admit to that because then the problem is not in the jurisdiction of her department HUD and she won't get more money.

Below are some very misleading quotes by Marcia Fudge.

"Because what we know is that it used to be that these things happen only in redlined
communities. But now it is pervasive, it is happening everywhere. And we determined that part of the problem was how appraisers are trained, who was in the appraisal industry, and how they are governed. And so, what we did, in March, was to present a report that showed how deeply, this whole bias situation, is across this country. It is systemic, and it is intentional to some degree."

Marcia Fudge doesn't understand redlining. Here's an article I wrote about it. Those risk maps were made by her own government agency HUD FHA and no longer exist. Government made risk maps were a way to determine loan risk. They included many factors. We still use all of these factors except we don't use race or country of origin. If you took race and country of origin out of the old maps, they were 100% as effective in determining risk. Obviously race and nation of origin have nothing to do with loan risk. Correlation is not causation. Not all maps even included those factors. 

"That's part of the problem, Laura, it's the data. So, they collect data, and the data is not what it should be. They then use the data, in a way that it should not be used. And so, they come up with these biased appraisals. But as well, when you look at an industry, that is more than 95 percent White, you find that people of color, are treated differently, because there is an inherent bias with a lot of them. And because they collect the data, the data is not good data."

Appraisers don't collect data. The data is home sale prices. It's just data. HUD collects this data. Zillow has and uses the same data. MLS, Title collect data. Appraisers use the public data according to the law and well established, accepted economic theory. HUD is one of the government agencies which told appraisers what data to use and how to use it. Appraisers are doing what HUD told us to do.

95% of all appraisers aren't white. I've gone over the misleading statistics in previous articles. Almost the same amount of appraisers are white as real estate agents. If most agents are white, does that mean they are also all racists? Most people in the US are white. Does that mean every white person is racist? Of course not. 

"If those homes are appraised the way that they should be Laura, then we look at being able to pass down, significantly, more resources, and more wealth, to generations that follow." "And if we are
constantly being discriminated against - and that is really what this is. We can call it bias, if you want. But it is systemic racism, and it is built within most federal agencies, and those agencies that we oversee." 

This is the result of the income gap and not appraisers. Here is AEI's response to the PAVE Task Force. Fudge knows this. She has the facts, data and research. If she truly believes this, she should be fired because she's incompetent. Fudge is just lying to the public. 

"So, we're tackling it. We are now advising first-time homebuyers, on their rights, if they get low appraisals. We are doing it to people, who sell properties. We are going to train all of the appraisers through fair housing and lending laws. We're going to make sure that the data is collected properly. And we're going to make sure that the right people have the data."

Fudge's solution is to do what we've already been doing for years. Fudge created a "horrible" problem then instantly fixed it by doing nothing. All these things have already been done years before she was the head of HUD. This proves she knows the problem doesn't really exist. She hasn't made any real changes and now it's "fixed."

Marcia Fudge stated that her own home is worth less than white owned homes down the street because she is black. This is of course false. I did a valuation of her much older home on a busy highway. It's worth less than the homes up the street because they are new luxury homes off of the highway. If Fudge doesn't understand this, she doesn't understand the basics of home appraisal and should resign as head of HUD. She states this falsehood for effect every time she speaks. 

Mary Cummins of Cummins Real Estate is a certified residential licensed appraiser in Los Angeles, California. Mary Cummins is licensed by the California Bureau of Real Estate appraisers and has over 40 years of experience.


Mary Cummins, Mary K. Cummins, Mary Katherine Cummins, Mary, Cummins, #marycummins #animaladvocates #losangeles #california #wildlife #wildliferehabilitation #wildliferehabilitator #realestate #realestateappraiser #realestateappraisal #lawsuit real estate, appraiser, appraisal, instructor, teacher, Los Angeles, Santa Monica, Beverly Hills, Pasadena, Brentwood, Bel Air, California, licensed, permitted, certified, single family, condo, condominium, pud, hud, fannie mae, freddie mac, fha, uspap, certified, residential, certified resident, apartment building, multi-family, commercial, industrial, expert witness, civil, criminal, orea, dre, brea insurance, bonded, experienced, bilingual, spanish, english, form, 1004, 2055, 1073, land, raw, acreage, vacant, insurance, cost, income approach, market analysis, comparative, theory, appraisal theory, cost approach, sales, matched pairs, plot, plat, map, diagram, photo, photographs, photography, rear, front, street, subject, comparable, sold, listed, active, pending, expired, cancelled, listing, mls, multiple listing service, claw, themls, historical appraisal, facebook, linkedin DISCLAIMER: https://mary--cummins.blogspot.com/p/disclaimer-privacy-policy-for-blogs-by.html

Wednesday, February 8, 2023

Mary Cummins Comment to ASC Bias Committee February 8, 2023, Real Estate Appraiser

Mary Cummins, ASC, appraisal subcommittee, appraisal bias hearing, @asc.gov, real estate appraiser,real estate appraisal, los angeles, california, hud, marcia fudge, appraisal institute, aei, american enterprise institute, bias, discrimination, junia howell, paul austin, tenisha tate austin, craig steinley, Michael Fratantoni, Mortgage Bankers Association
Mary Cummins, ASC, appraisal subcommittee, appraisal bias hearing, @asc.gov, real estate appraiser,real estate appraisal, los angeles, california, hud, marcia fudge, appraisal institute, aei, american enterprise institute, bias, discrimination, junia howell, paul austin, tenisha tate austin, craig steinley, Michael Fratantoni, Mortgage Bankers Association

02/26/2024 I never got a reply about my comment. It is not public anywhere except here. I doubt anyone read my comment letter. They definitely didn't respond to any issue. If you send in a comment, post it publicly on your own. Otherwise it just ends up in a black hole. They tell you to send comments just to make it appear they are listening to you. They are not listening to appraisers. They are only listening to what fits their agenda which is the promotion of the false narrative of the old male male racist appraiser. Research by AEI has shown there is no racism in appraisals, see below.

ORIGINAL: Below is the comment letter I sent to the Appraisal Subcommittee in regard to the January 24, 2023 Appraisal Bias Hearing. It was confirmed as received. "Appraisal Bias Hearing via appsubcomm.onmicrosoft.com 2:07 PM (1 hour ago) We are in receipt of your message. Thank you for contacting the Appraisal Subcommittee." While they probably won't read it, it's now part of the Federal record for ASC and HUD. 


Mary Cummins

February 7, 2023

Appraisal Subcommittee

Appraisal Bias Hearing Comment Letter

AppraisalBiasHearing@asc.gov

I watched the January 24, 2023 ASC Appraisal Bias hearing. Comments were requested after the hearing. This letter is my comment. 

I've been a real estate appraiser in Los Angeles, California for 40 years. I've been a licensed California Certified Residential Appraiser since licenses were first offered in 1993/1994. I'm a Latino woman who speaks English and Spanish. I appraise property in the diverse county  of Los Angeles and state of California.

There is no denying that racism exists in our country. We must do all we can to stop racism, sexism, ageism and all the other isms. As an appraiser I support fair, unbiased appraisal practices and valuations. I support using the scientific method and facts in order to identify the real problem in order to solve it.

I witnessed a lot of misinformation and disinformation during the hearing. Marcia Fudge the head of HUD and some of the specifically chosen speakers made racist and other statements which are not supported by facts and evidence. While there is an income, wealth and home value gap among whites, blacks and Latinos it's not caused by real estate appraisers. It's caused by the income gap. That is the real problem which must be solved. Blaming appraisers for the income gap will never solve the real underlying problem.

Government research has shown that there is an income gap between whites, blacks and Latinos ( AEI Housing Center Response to Perry and Rothwell, 2021, https://www.aei.org/research-products/report/aei-housing-center-response-to-perry-and-rothwell-2021/ ). Whites make and have more money than blacks and Latinos. Men make more than women. Married couples make more than singles. The income gap is the cause of the wealth gap including the generational wealth gap. It's the cause of the difference in value among white and black, Latino owned homes. 

Research has shown that people who make more money have more money and buy more expensive homes (see link above). People buy homes they can afford in areas they can afford. People who make more money also buy more expensive cars. The difference in value of the cars is also not caused by real estate appraisers. 

If the race and color of the homeowners were the cause of the differences in home valuations, why do identical white owned homes in the same areas of black, Latino owned homes have the same value as black, Latino owned homes? The value has nothing to do with race or skin color but location. Everyone knows the three main indicators of value are LOCATION, LOCATION, LOCATION. A home in a small town in Ohio with few amenities is generally worth less than a home of the same size in prime Beverly Hills, California. The value is mainly in the dirt.

Fudge and some of the others spent their time attacking and blaming "old white male" real estate appraisers for the home value gap. Appraisers report market value based on the sound economic theory of matched pairs analysis. This same theory has been used since the beginning of time to value all assets. This is set by the concepts of the free market and willing and able buyers and sellers. Fudge's promotion of the false narrative of the "racist appraiser" will never solve the real problem which is the income gap.

I will now reply to the individual instances of misinformation by the speakers in order starting with Marcia Fudge. 

I. Marcia Fudge, HUD

Marcia Fudge is one of the heads of the PAVE Task Force. American Enterprise Institute (AEI) provided research, data and information to the Task Force ( AEI Comments on PAVE, March 2022 https://www.aei.org/research-products/report/comments-on-the-pave-report/ ) which proved the real cause of the home value gap is the income gap. Fudge knows this yet instead irresponsibly promotes the false narrative of the "racist appraiser" as the cause of the home value gap. Fudge promotes Andre Perry's false, misleading and debunked "paper" instead of independent verifiable research and facts. Perry's paper was based on robot valuations and not appraisers. 

While Fudge states she hates and fights racism Fudge's multiple comments against white people reflect her own racism. It appears that Fudge prefers to falsely state that the problem is (white) real estate appraisers because her department HUD oversees those issues. HUD has received extra funding for this issue even though the real cause of the problem is not within control of her department. Government funding should be provided to the Departments that can actually solve the income gap problem. This is why we must first determine and state the problem which is the income gap.

Fudge stated that property tax paying for police, fire and schools was unconstitutional. It's inconceivable that the head of a major US government department would make this statement which is a violation of her oath. When Fudge became the head of HUD she took an oath March 2021 stating "I will support and defend the Constitution of the United States (snip), that I will bear true faith and allegiance to the same; I will well and faithfully discharge the duties of the office on which I am about to enter. So help me God." 

Fudge inferred that she wanted property tax assessment values to rise so people would pay more property tax so they could get more police, fire protection and money for local schools. She doesn't realize that most older retired disabled people can't afford to pay more taxes and keep their homes. They'd be forced to sell with higher taxes. Appraisers don't even make property value assessments. Those are made by Tax Assessors. 

Fudge stated that black people remove personal photos, items to increase home value. That is false. All real estate agents tell all home owners of every color to remove personal articles such as photos, collectibles from their home. It shows the home bigger and better. Buyers don't want to see any other person reflected in the home. They want to envision themselves in a blank slate of a home. It's not about race.

Fudge stated she started the appraisal appeal process for racial bias. Appraisal appeal, Reconsideration of Value (ROV) have ALWAYS been available to borrowers of all types. They can appeal based on any reason. A difference in appraised value and contract price is not about bias. It happens more in black, Latino areas based on the home values and not the race. Research by AEI based on government loan documents proved there is no effect of race on home value ( AEI, How Common is Appraiser Racial Bias https://www.aei.org/how-common-is-appraiser-racial-bias/ ). AEI presented this to the government in the meeting about the PAVE task force yet Fudge keeps denying these facts.

Fudge brought up her home value previously. She said her older home is worth less (than a white person's home up the street) BECAUSE SHE IS BLACK. I included a valuation of her home and of the NEW, LUXURY homes up, across the street from her in a past article. It's a private development of new luxury homes tucked away off the main street. I have no idea if the home owners are all white. I doubt Fudge does either. There is a reason why those homes are worth more. They're new, luxury, in a new development, with a clubhouse, off the main street highway... Not all homes of the same size in the same county are worth the same. An old run down home in South Los Angeles is worth less than a new one of the same size in Beverly Hills. If Fudge doesn't know this basic appraisal theory, she should resign because she's clearly unqualified to run the Department of Housing and Urban Development.

II. Dr. Junia Howell

Howell prefaced her research by basically stating without any proof that appraisers are racist and appraise homes in black, Latino areas for less than areas with more white owned homes. Howell promotes the false narrative of the racist appraiser. Howell states she did research on property values in white, black and Latino areas in Texas. Howell supports this with a chart showing the difference in home values of predominantly white vs black, Latino owned homes. We're back to the income gap. Blacks, Latinos make less money than whites. For this reason they buy less expensive homes in less expensive areas.  I can only assume they promote this falsity for their personal agenda of wanting more funding to pay them for more research.

Howell doesn't understand basic real estate cycles, i.e. Growth, Stability, Decline, Revitalization. Howell stated areas which were redlined but are now mainly white owned increased in value. Areas which were not redlined but are now mainly black, Latino have decreased in value. Howell states this proves it's based on race when it actually proves it's based on real estate cycles and income. When values go up in an area, people with more money buy and own those homes. When values go down, blacks, Latinos are more likely to buy and own the homes because they make less money. When people get pushed out of more expensive areas, they buy homes in lower priced surrounding areas. Those lower priced areas are generally more black, Latino. Some call this "gentrification" but it's just a real estate cycle called "revitalization." It's all because of the income, wealth gap.

Howell misstates "redlining" as a "map based on race of inhabitants." There were many, many factors involved in the original Federal Housing Administration (FHA) lending policies. They were based on income on inhabitants, age of buildings, condition of buildings, beds/baths, location... to determine loan risks. We still use all of those factors today EXCEPT race. It's racist and against the law to use race, religions or any other similar factor.

Howell stated that whites in the US government used these risk maps to intentionally value white owned property higher than black, POC owned property. Howell is so uneducated in this matter that she doesn't even realize that back in the 1930's most areas which were mainly inhabited by POC were actually owned by whites. The risk maps prevented white property owners from receiving lower cost Federal guaranteed loans. Howell stated "White, affluent areas were appraised as most valuable." The key here is "affluent areas." It's the income wealth gap. Correlation does not equal causation. 

There are poor white areas in the US. How does Howell explain the difference in property values between wealthy and less wealthy white owned properties? She doesn't. It's not the color of their skin but the income gap. Howell made many more false and uneducated statements before stating that more research should be done. Howell wants more money to do more uneducated flawed research to promote the false narrative of the "racist appraiser."

III. Paul Austin and Tenisha Tate-Austin

I have covered this case in great detail because I'm an appraiser in California where the Tate's home is located. While the Austins may feel the difference in two home appraisals was due to racial discrimination the facts show it was not. Based on my research and experience the first appraiser used the best local comparables in Marin City and came in at market value. The second higher appraisal used dissimilar comparables in a very different more affluent area in Mill Valley much farther away from the subject. That is why it came in over market value. Marin City was built on swamp land as a Federal low income poor quality housing project built by the lowest bidder. The Tate's home was built cheaply using telephone poles on very steep previously unbuildable land. Mill Valley is an upscale community with high quality larger homes and some of the best schools and amenities in the state. 

The Tates stated in their testimony and lawsuit that Marin City is basically populated by African Americans while Mill Valley is white. The Tates wanted the appraiser to only use high valued comps from Mill Valley and not lower valued comps from Marin City right next to their home. That would violate Federal appraising regulations besides being bank fraud.

The Tates believe their whitewashing of their home increased the second appraisal value. It didn't. What increased the value was another appraiser with lower ethics who was most likely pressured by maybe the AMC, Lender to come in higher. The second appraiser is the reason why the first appraiser was falsely sued for coming in "low." The second appraiser should be sued for bank fraud, appraisal violations and lose their license. 

IV. Michael Fratantoni, Mortgage Bankers Association

Frantantoni basically promoted the MBA. Frantantoni suggested Automated Valuation Methods (AVMs) could reduce bias in appraisals.  AVMs don't reduce but increase bias. AVMs are robots that don't actually see or inspect the home. They base their value on recently sold allegedly similar homes based on home/lot size, bed/bath count and age. They don't know if the home actually exists, its condition, upgrades, view, lot type, specific location in a neighborhood, actual size, true bed/bath count, permitted/unpermitted additions... AVMs value average homes in poor condition over market value and improved homes with views under market value. Marcia Fudge stated she also supports AVMs. Zillow's AVM actually produced the false and misleading data used in Andre Perry's "paper." 

V. Craig Steinley, President, the Appraisal Institute, AI

The AI is a non-government non-profit organization. It costs about $15,000 to become an MAI AI designated appraiser. For this reason AI mainly represents wealthy older white male appraisers. It does not represent the average appraiser or most appraisers in the US.

AI wants to maintain its working relationship with the government. For that reason they support many though not all falsehoods stated by Fudge, HUD and other some government agencies. In their letter they promote their own actions as supporting the government.

That said AI makes some important points about AVMs and the Sales Comparison Approach.  

AVMs are not reliable. "One thing to be noted is that a good portion of the research that has been conducted on valuation bias has evaluated automated valuation model data – not appraisal data, including the contrasting research from the Brookings Institution and the American Enterprise Institute. We cannot overlook the Zillow CEO’s statement in the 4th quarter of 2021 concerning the “difficulty of accurately estimating market value” as a concern for AVM reliability." 

Sales Comparison Approach is reliable. Some have called for the "elimination of the sales comparison approach in appraisal. The BRSPT suggests those recommendations be ignored, and we will go on record as being outright opposed to such efforts. The sales comparison approach is grounded in economic theory, and it is universally accepted throughout the world." Some in government have suggested getting rid of the sales comparison approach which would destroy our economy. No bank would give a loan and no investor would buy a loan that is not based on an appraisal using the sales comparison approach.

In conclusion the cause of the difference in home valuations between whites and blacks, Latinos is the direct result of the income gap. The government needs to recognize and state the real problem so it can be solved. Blaming real estate appraisers will never solve the income gap or the home value gap. Blaming appraisers for the income gap is as ridiculous as blaming appraisers for gun violence and gas prices.

Please, rely on qualified independent scientific research and facts. Promoting the false narrative and attacking appraisers instead of trying to solve the real issue hurts everyone.  Throwing money at HUD won't fix the income gap. Please, fix the income gap and all its causes so we all may experience the American Dream of owning a valuable home.

Mary Cummins

California Certified Residential Appraiser

License # AR010207

Los Angeles, California

http://www.MaryCummins.com

https://www.facebook.com/CumminsRealEstateServices


Mary Cummins of Cummins Real Estate is a certified residential licensed appraiser in Los Angeles, California. Mary Cummins is licensed by the California Bureau of Real Estate appraisers and has over 35 years of experience.


Mary Cummins, Mary K. Cummins, Mary Katherine Cummins, Mary, Cummins, #marycummins #animaladvocates #losangeles #california #wildlife #wildliferehabilitation #wildliferehabilitator #realestate #realestateappraiser #realestateappraisal #lawsuit real estate, appraiser, appraisal, instructor, teacher, Los Angeles, Santa Monica, Beverly Hills, Pasadena, Brentwood, Bel Air, California, licensed, permitted, certified, single family, condo, condominium, pud, hud, fannie mae, freddie mac, fha, uspap, certified, residential, certified resident, apartment building, multi-family, commercial, industrial, expert witness, civil, criminal, orea, dre, brea insurance, bonded, experienced, bilingual, spanish, english, form, 1004, 2055, 1073, land, raw, acreage, vacant, insurance, cost, income approach, market analysis, comparative, theory, appraisal theory, cost approach, sales, matched pairs, plot, plat, map, diagram, photo, photographs, photography, rear, front, street, subject, comparable, sold, listed, active, pending, expired, cancelled, listing, mls, multiple listing service, claw, themls, historical appraisal, facebook, linkedin DISCLAIMER: https://mary--cummins.blogspot.com/p/disclaimer-privacy-policy-for-blogs-by.html