Mary Cummins, Real Estate Appraiser, Real Estate Appraisal, Los Angeles, California, Mary Cummins.

Mary Cummins is a real estate appraiser in Los Angeles, California with 38+ years of experience. Cummins provides real estate appraisals for banks, lenders, mortgage brokers, Appraisal Management Companies (AMCs), lawyers, Courts, factors and private parties for lending, lawsuits, probate, estate planning, divorce and all types of litigation. Cummins provides 1004, 1073, 1025 and other form reports, narrative reports and historical appraisals besides real estate research and appraisal advice.

Showing posts with label appraisal. Show all posts

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

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

Mary Cummins

Mary Cummins of Cummins Real Estate Services has been in real estate since 1983, over 35 years. She is licensed by the Bureau of Real Estate Appraisers. Mary Cummins was an agent and broker licensed with the California Department of Real Estate selling residential income, commercial buildings, raw land and homes for Merrill Lynch Realty in Beverly Hills and Westside Properties in Los Angeles before concentrating on appraisals. Mary Cummins currently provides real estate appraisals, expert witness testimony, historical research, legal real estate research for mortgage brokers, banks, lawyers, factors, insurance companies, financial consultants and private individuals. Mary Cummins was born and raised in Southern California. Cummins attended Beverly Hills Good Shepherd Catholic School and Beverly Hills High School. Besides being on the Dean's list, Mary Cummins was a top ten national swimmer and competed on the men's water polo team. Mary Cummins began college at the age of 15 attending the University of Southern California on scholarship, majoring in Psychology/Sociology. http://www.animaladvocates.us http://www.facebook.com/AnimalAdvocatesUSA

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

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

Tuesday, February 14, 2023

Real Reasons Appraisers Come in Below Contract Price by AEI. It's not Racism, by Mary Cummins

AEI just released a report about appraisers coming in below contract price in areas with lower income buyers, lower priced homes and more blacks and Latinos. This is exactly what I've been talking about. Again, AEI proves it with science and facts. Just FYI AEI is considered a "conservative" source.

"Our critique points out some significant shortcomings of these studies. Notably, they focus on entire
neighborhoods, when they should study the actions of individual appraisers. They use the greater share
of under-valuations as evidence of racial bias, when they should consider explanations unrelated to bias
that might account for under-valuations, including for example the greater share of first-time
homebuyers, who tend to overbid, or the greater presence of seller concessions, which will reduce the
appraisal amount when they are properly accounted for. They also fail to note the size of these undervaluations. Using the Aggregate Statistics Data File and Dashboards, our analysis indicates they are relatively small, averaging about $1,100 to $1,900.5 These levels are too high if they are in fact due to racial bias. However, our analysis finds multiple other plausible explanations for under valuations of this magnitude such as the greater presence of first-time homebuyers or seller concessions. We also note
that under valuations of this magnitude of are unlikely to depress entire neighborhoods and, they may
in fact provide a disproportionate consumer benefit to minority homebuyers.

We conclude with a renewed call on Fannie Mae, Freddie Mac, and regulators such as the FHFA to mass screen individual appraisers for racial bias and inaccuracies. We have already laid the groundwork for this research with a published working methodology."

The most important issue which I've stated previously is they focus on appraisal value and contract price for purchases and no refinances. When doing an appraisal for purchase the appraiser NEVER sees, meets the borrower, buyer. We may see the seller or the seller's agent but never the borrower. The government study also doesn't know the race or color of the borrower, buyer AND appraiser. What if it's only black appraisers coming in low with black borrowers? A recent horrible unreliable "study" showed that the appraiser who came in the lowest for black people was themselves black.

More important observations from AEI's study. Contract price does not equal market value. First time home buyers which are more likely in these lower priced areas are more likely to over bid. They don't always know they can negotiate. These same areas tend to have homes in lower condition. The appraiser adds more comps to appraisals which are below contract price. I do this to fully back up my work so everyone can understand the value. An appraisal that comes in below the contract price would not endear you to the AMC or lender. Appraisers HATE coming in below contract price but we do it because it's the right legal fair thing to do. The appraisal is to secure the loan not help a buyer or seller.

Some good snippets though you should read the entire report.

Fist time buyers offer over market value. "Shui and Murthy (2019) conclude that first-time homebuyers using Fannie Mae or Freddie Mac financing overbid for a home by approximately $3,000, or about 1% of the contract price for the average home compared to repeat buyers. They also find that FTBs with higher LTVs tend to overpay by more compared those with lower LTVs. FHA borrowers, who are disproportionally concentrated in minority census tracts and largely FTBs, typically have higher LTVs and lower credit scores and may thus be more likely to overpay than other buyers."

There are more seller concessions in these first time buyers, buyers using gov funding and these areas. If a home sells for $100,000 and has a $3,000 seller concession, appraisers subtract $3,000 from $100,000 in the adjustments. The net price is $97,000 which is under contract price now by 3%. There are more concessions to help buyers buy the property and because of condition.

There are more buyers for lower priced homes. This causes buyers to over bid for homes based on supply and demand. We saw this during the recent Covid runup. Buyers bid and paid over list price. They had to make up the difference in loan amount with a larger down payment.

First time buyers aren't just competing against other buyers but also against their rent. Many only compare what they are paying in rent to what their mortgage will be. Quick story. Friend of mine was buying a cheap mobile home. She wanted to buy a cheap home because the mortgage is less than her rent. She was buying it to save monthly expenses. Appraisal came in $20,000 below contract price of $85,000. She asked me for help. I told her appraisal value looked correct. I told her to ask seller to reduce price. She said "but it's actually worth $85,000! It's almost the cheapest house on the market! I will lose the home to someone else! I have to buy this home because the monthly payments are cheaper than my cheap rent!" She didn't care about the price but the monthly payment being less than rent. She only wanted to find a way to get $20,000 more cash for the down payment. Thankfully seller reduced the price. The appraisal gap prevented her from over paying for her first home. Many first time buyers in less expensive areas feel the same way.

Buyers using government funding tend to overbid. They're buying the home with someone else's money because of lower down payment requirements.They just want the home at any price believing it will instantly go up in value and they will have thousands in equity to take eventually. The government told them this is the American dream.

The actual appraisal gap is small. There is almost no gap in Latino areas and 1% in black areas. The government made this huge stink about appraisal gap and there barely is one! "In our prior critique of Freddie Mac’s research note, we find that “there appears to be no gap [in home purchase appraisals] relative to White tracts for Latino tracts and a relatively small gap [in home purchase appraisals] of 1-2% for Black tracts.” They mean predominantly white, Latino or black census tracts. None are 100% white, black or brown. That means whites are having the same issues in those areas as blacks and Latinos. The gap is not a color issue because the same things happens to whites in the same area.

AEI again debunks Andre Perry's "paper." Perry stated appraisers devalue black owned property by $48,000 per home. That's much more than the difference in contract price and appraised value of 1%. AEI pointed out that homes owned by poor whites are also valued less than homes owned by wealthier whites. It's not because of skin color but income, wealth and location.

Appraisals coming in below contract price can help lower income Latino, black buyers. They can renegotiate with the seller. The government didn't say the buyers never closed on the properties and the deals died. They're prevented from overpaying and ending up upside down. AEI state that the government is part of the problem. They help and allow buyers to over pay for homes at the top of the market only to lose those homes later when the market tanks or they have a financial emergency. And you know who the government falsely blames for that? Appraisers!

This kind of reminds me of the destroyed apartment buildings in the Turkey earthquake. Their President bragged that he reduced earthquake requirements to allow the construction of 300,000+ homes for lower income people. That is one of the major causes of the high fatalities in the earthquake. The President basically killed people. FHA and the government like to brag that they helped low income people buy homes. Then they lose their homes because they over paid at the peak of the market and couldn't easily pay the mortgage. Also reminds me of our student loan problems. Latinos, blacks are the ones stuck with huge student loans while the government brags they helped them get an education. Most didn't even finish their education and get the degree or certificate. Most of the ones that did didn't even get the better paying promised job. Governments just want to brag that they "helped" people not caring that they actually destroyed them financially. If the government helped them find a way to earn more money, they could buy a home on their own and afford to stay in it.

AEI suggest mass screening of appraisers to check for racial bias. I support this. If any appraiser knew of a racist appraiser who came in low on a black, Latino owned home because of their racial bias, they would love to take that appraiser back behind the wood shed. All appraisers are being attacked, vilified, defamed based on this false narrative of the "racist old white male appraiser." While racism sure as hell exists, not all appraisers are racists who lowball Latinos and blacks. If there are appraisers doing this, other appraisers would be the first to hold them accountable and strip them of their license.

FTR Dan Wiley of Freddie Mac stated this about their appraisal gap research. "We have not reached any conclusion for cause of the gaps or correlation. Our research showed that further studies are warranted." Danny Wiley and Freddie Mac are doing further research into the possible causes of the appraisal gap. They are looking at all the new data and reviewing all appraisals involved in the appraisal gap research. Of course that hasn't stopped Marcia Fudge, HUD, media... from running with Freddie Mac and other's inconclusive data about appraisal gap from stating it's allegedly caused by racial discrimination by appraisers.

https://www.aei.org/research-products/report/exploring-alternative-explanations-for-appraisal-under-valuation/?utm_source=newsletter&utm_medium=email&utm_campaign=exploring_alternative_explanations_for_appraisal_under_valuation&utm_term=2023-02-14

Mary Cummins

Wednesday, February 1, 2023

AMC, Lender Pressure Appraisers to Appraise Over Market Value in Violation of Law by Mary Cummins Appraiser

The lawsuit is "Naftali Horowitz v. Nicole Andrews, Fastapp AMC founder v. Fastapp. AMC president. Horowitz, Fastapp founder, filed a lawsuit in New York court on January 31, 2022 against defendant Andrews to, among other things, remove Andrews as an officer and director of the Company because, when he brought her on as shareholder in 2020, he claimed that she made certain false representations and promises that were never kept." The lawsuit is really about Nicole Andrews trying to get rid of Naftali Horowitz and take over the company per Horowitz. It's kind of messy because there are other accusations involved so we don't know the full, full truth.

This lawsuit is among principles in an Appraisal Management Company AMC Fastapp. They are suing each other because allegedly Nicole Andrews unethically pressured appraisers to hit target values. The purpose was to please the lender clients so they could close a loan to make money. When the lender makes money, the AMC makes money with more orders. One principle was allegedly worried about government enforcement actions. I personally believe both parties knew about this activity all along.

This is the stupidest lawsuit I've ever seen. Generally criminals like this would settle their grievances quietly so they don't all go to jail. It almost sounds like threats of extortion. Once the parties realized this looked bad publicly they reached a settlement a month later and the case was dismissed. Too late. All these juicy incriminating emails are now public. Nicole Andrews is still with the company per their website so... https://fastapp.com/

Generally when these value instances arise the parties are notified to call the office. These things are discussed on the phone and not in writing. It's shocking and beyond dumb these people put these things in writing.

This is why when appraisers come in at market value they sometimes get a complaint or sued for discrimination. A second willing to please "fixer" appraiser desperate for work will come in over market value making the borrower assume the first appraisal was too low and biased. The second appraisal is generally the wrong one over market value. It's the second appraiser that should be sued in all of these big "racial discrimination" media articles, complaints and lawsuits. I'm trying to get ahold of those second appraisals so I can report the appraisers so they can lose their license. They should go to prison for bank fraud along with the AMCs who approved those appraisals.

#realestateappraiser #realestate #appraiser #appraisal #AMC #DoddFrankAct #bias #discrimination https://appraisersblogs.com/alleged-violations-of-appraiser-independence-at-fastapp-amc

"The following court documents in the case Naftali Horowitz v. Nicole Andrews, Fastapp AMC founder v. Fastapp AMC president, confirm what appraisers have been saying all along, that if you want high-volume AMC work, you have to lower your fees to 1980’s level, have 24 hour turn times, and, above all, be a number hitter.

Horowitz, Fastapp founder, filed a lawsuit in New York court on January 31, 2022 against defendant Andrews to, among other things, remove Andrews as an officer and director of the Company because, when he brought her on as shareholder in 2020, he claimed that she made certain false representations and promises that were never kept. Horowitz is an individual residing in Brooklyn, New York, and is the founder, and, at all relevant times, a 49% shareholder Fastapp. Andrews is an individual residing in Newport Beach, California, and, at all relevant times, a 51% shareholder of Fastapp.

Horowitz claimed that Andrews engaged in conduct constituting potential violations of the Appraiser Independence Requirements under the Dodd-Frank Act of 2010 (“Dodd-Frank Act”), including unlawfully seeking to influence an appraiser to encourage a targeted value to facilitate the making or pricing of the transaction in violation of 15 U.S.C. § 1639e(b)(3). (See copies of emails in Exhibit 3)."

Read the article here with all the email exhibits. This has been happening forever. If you are a kiss ass AMC pleasing appraiser you will never have a complaint or lawsuit filed against you.

https://appraisersblogs.com/alleged-violations-of-appraiser-independence-at-fastapp-amc

fastapp, nicole andrews, naftali horowitz, mary cummins,real estate appraiser, appraiser, appraisal, dodd frank, violations, appraiser independence, lawsuit

Mary Cummins

Monday, January 30, 2023

Maryland Lawsuit Alleged Racial Discrimination Real Estate Appraisal Nathan Connolly, Shani Mott by Mary Cummins

Shane Lanham, 20/20 Valuations Inc, Shani Mott, Nathan Connolly, real estate appraiser, appraisal, discrimination, maryland, 209 Churchwardens, Baltimore, Maryland 21212, lawsuit, complaint, defamation, Mary Cummins

UPDATE 03282024 Link to another article about case.

https://appraisersblogs.com/loandepot-appraisal-discrimination-settlement/

03272024 One Plaintiff Dr Mott passed away early March. There has been a settlement by the AMC. Lawyer Peter Christensen has the story. I agree with Peter that most Plaintiffs truly believe they have been discriminated against. They've probably been discriminated against based on their race in the past so they believe any discrepancy must be race discrimination.

There is a confidential financial component to the settlement but publicly the AMC "loanDepot.com agreed to an extensive revamping of: (a) its reconsideration of value practices; (b) fair housing/non-discrimination training requirements; (c) statistical tracking of appraisal outcomes; and (d) contractual requirements for AMCs and appraisers." I personally feel this won't change anything in the real world. As AEI research has shown there is no discrimination or racial bias in real estate appraisals. It's a math formula. Based on my research the appraiser was correct and Plaintiffs in this case were wrong, see below for evidence.

https://www.linkedin.com/feed/update/urn:li:activity:7178159528901816320/

As far as I know the appraiser has not settled.

UPDATE: Shane Lanham real estate appraiser with 20/20 Valuations Inc just sued homeowners Shani Mott and Nathan Connolly for defamation for their alleged false public claims about him. This is a countersuit to their United States District Court case 1:22-cv-02048-SAGU.S. District Court, District of Maryland (Baltimore).

Shani Mott and Nathan Connolly sued Shane Lanham for racial discrimination based upon his real estate appraisal valuation of their home. They stated he intentionally appraised their home for less than market based on, due to their race, color because he is allegedly a "white racist." Below is the court information.

CIVIL DOCKET FOR CASE #: 1:22-cv-02048-SAG Connolly et al v. Lanham et al, Assigned to: Judge Stephanie A. Gallagher, Cause: 42:405 Fair Housing Act, Date Filed: 08/15/2022, Nature of Suit: 443 Civil Rights: Accomodations.

I read the original case last year but was too busy with other things to fully research it and write an article. I did do some research at that time. Based on my research the Plaintiffs over paid for their home when they originally bought it. It is not fully remodeled or upgraded. It's on a very busy highway. It's smaller with fewer beds, bath than MLS listings.

It was on the market a while starting at $536K 04/2016 then $529K 06/2016 then $499 07/2016 then $479 10/2016 then sold $450 03/2017 a year later. 10% drop in list price. Sold 6% less than final list price. Just because you pay less than list doesn't mean it's a good price. You can still be paying over market value. It took a long time to sell because of condition, size, bed/bath count and location on a very busy road. These people intentionally bought almost the cheapest house in the neighborhood because it had major issues. Now they want it to be worth as much as the best home in the entire neighborhood. There is a more valuable neighborhood near the subject property neighborhood. The homeowners wanted the appraiser to only use fully remodeled larger sales in that more expensive neighborhood that are not on busy streets like subject. Those comps aren't similar to subject. They are superior. I agree with every argument made by appraiser Shane Lanham in his answer and counter claim.

The busy street is a negative. Most people would NEVER buy a home on a busy multi-lane double lined highway. The issue is noise pollution, air pollution, safety because of cars and security. The subject also has fewer bedrooms, bathrooms than the higher sales. The original appraisal was seven months before the second appraisal. The market appreciated between the time of the first and second appraisal.

We have not seen the second appraisal. Based on what I'm seeing it came in way too high. Maybe the appraiser was pressured by the lender, AMC or homeowners. Maybe he feared a complaint or lawsuit. Considering that the false narrative of the "racist white appraiser" has been amplified by the media I could understand that. I still would never come in at any value other than market value. That second appraiser's misleading value is the reason for the original frivolous, meritless lawsuit.

Shane Lanham has been severely damaged. Look at the false online reviews against his business. I've read some articles and the comments are hateful. I bet he got death threats. I'm sure he's stressed to the max. I'm positive he lost business. His reputation has been destroyed.

In these instances of alleged racism in appraisals you can't prove the results were the result of racism. You must prove that to win a lawsuit against an individual appraiser. It could be error, malpractice or totally explainable by facts like in this case and the other cases I've investigated. There is no evidence except the homeowner not liking the value. It's just someone's emotion. It feels that way to them in light of the current tension between some whites and some blacks, Latinos. Police brutality against blacks, Latinos like George Floyd, Tyre Nichols is flaming the tension. The misleading, misinterpreted paper by Andre Perry makes it worse. Politicians, some nonprofits, media promoting the false narrative of the racist appraiser to get votes, money for their department, donations for their nonprofit and ad revenue. It's also the existence of the very real income gap. I'm sure some really feel the appraiser was racist because of their past experience with some whites, racism and what's happening in the media. Some are on the defensive. Still, one needs to separate emotion from facts.

An example comes to mind. A black woman on LinkedIn said a white man told her to smile. She flew into a rage saying it was racist. She said the white man treated her like a black minstrel player that he wanted to entertain him. Ask any woman of any color and they will all tell you that guys have told them to smile. Happened to me and I have white skin. The real reason has nothing to do with race. Here's an article about it. I separated my emotion from fact and realized that I wasn't targeted because of my race, color, hair color, what I was wearing... It was because I was a female and the person telling me to smile was a guy.

I just did some robot appraisals. Mind you all of these are too high because robots don't know it's inferior condition, size and location on a busy street. AVMs will appraise these homes higher than market value for this reason. Knowing that all of the AVMs came in much lower than the second appraisal. That shows the second appraisal is the issue. Did their buddy do the second appraisal? Something is very wrong there. The only time an appraiser should come in higher than robots is when the subject is vastly superior in quality, upgrades, condition, view, specific location or some other factor. This property should come in lower than robots for that reason.

First appraisal was on 06/14/21 for $472K
Second was on 01/18/22 for $750K

Below are robot values which are too high because they don't know subject is on busy street, smaller and in inferior condition to most other homes recently sold. The AVMs are also using comps from subject area and other surrounding neighborhoods. They should only use comps in the same neighborhood with same busy street location and condition. The names of the sites have links to their guesstimates of value. Notice the large range in values. CoreLogic is the lowest. They are generally the most accurate as they use sales in same area. CoreLogis is high because AVMs can't see condition, location on busy road or the real smaller size.

Realtor

June 2021 6/21

Collateral Analytics $564K
CoreLogic $542K
Quantarium $576K

January 2022 1/22 $571 $591 $610

01/23 $765

Trulia

01/23 $669

Zillow

6/21 $620
1/22 $605
01/23 range $602-750

RedFn

6/21 $559K
1/22 $587K
01/23 $627K

Original lawsuit by Plaintiffs.

https://www.courthousenews.com/wp-content/uploads/2022/08/refinance-complaint-loandepot.pdf

Shane Lantham's lawsuit for defamation, counterclaims and answer to above lawsuit.

https://drive.google.com/file/d/1gvlDz22T4zUfhnNPW8KqFDeZbhSK_CRJ/view?usp=sharing

Good articles about this lawsuit. Turns out Nathan Connolley teaches racism, capitalism and politics. He wrote a book "A World More Concrete: Real Estate and the Remaking of Jim Crow South Florida." Mott teaches African studies. Looks like this lawsuit was to promote themselves.

https://www.workingre.com/appraiser-counter-sues-black-plaintiffs-who-alleged-discrimination/

This article posted the first appraisal and motion to dismiss. Because the homeowner mentioned and included parts of the appraisal in the lawsuit the appraiser may share it in a lawsuit. Normally these are confidential and can't be shared with anyone except the client.

https://wp-orep-cdn.s3.us-west-1.amazonaws.com/wp-content/uploads/2023/01/30175939/Baltimore_Bias_Suit_Motion_to_Dismiss_Dec122022_48.pdf

Another good article on the case.

https://appraisersblogs.com/appraiser-countersuing-black-homeowners-4-defamation

Docket to date is below

Date Filed

Docket Text

08/15/2022

COMPLAINT

against 20/20 Valuations, LLC, Shane Lanham, Loandepot.com, LLC ( Filing fee $ 402receipt number AMDDC-10102080.), filed by Nathan Connolly, Shani Mott. (Attachments: #

CivilCover Sheet, #

Summons, #

Summons)(Relman, John) (Entered: 08/15/2022)

08/15/2022

MOTION to Appear Pro Hac Vice for Soohyun Choi

(Filing fee $100, receipt number AMDDC-10102238.) by Nathan Connolly, Shani Mott(Relman, John) (Entered: 08/15/2022)

08/15/2022

MOTION to Appear Pro Hac Vice for Gabriel Diaz

(Filing fee $100, receipt number AMDDC-10102268.) by Nathan Connolly, Shani Mott(Relman, John) (Entered: 08/15/2022)

08/15/2022

Jury Trial Demand by Nathan Connolly, Shani Mott(jb5s, Deputy Clerk) (Entered: 08/15/2022)

08/15/2022

Summons Issued 21 days as to 20/20 Valuations, LLC, Shane Lanham, Loandepot.com, LLC.(jb5s,Deputy Clerk) (Entered: 08/15/2022)

08/15/2022

NOTICE of Case Assignment. This case has been assigned to Magistrate Judge Beth P. Gesner. NathanConnolly, Shani Mott or counsel for Nathan Connolly, Shani Mott are required to review and complywith the Magistrate Judge Pilot Project Procedures which can be downloaded

here

. Pursuant toStanding Order 2019-07, which can be downloaded

here

, counsel has 14 days from the date of thisnotice to file their consent, or decline to consent to proceed before a U.S. Magistrate Judge which canbe downloaded

here

. To file your consent, go to

Civil > Other Filings > Other Documents > 25 PctMag - Consent to Proceed Before a Magistrate Judge

. To file your declination, go to

Civil > OtherFilings > Other Documents > 25 Pct Mag - Decline to Proceed Before a Magistrate Judge

. Failure tofile a consent or declination will result in issuance of an Order to Show Cause. Please review the casemanagement order that has been issued in this case. Magistrate Election Form due by 8/29/2022. (jb5s,Deputy Clerk) (Entered: 08/15/2022)

08/15/2022

Case Management Order. Signed by Magistrate Judge Beth P. Gesner on 8/15/2022. (jb5s, DeputyClerk) (Entered: 08/15/2022)

08/19/2022

PAPERLESS ORDER granting

Motion to Appear Pro Hac Vice on behalf of Soohyun Choi.Directing attorney Soohyun Choi to register for pro hac vice filing in the District of Maryland throughPACER at https://pacer.uscourts.gov/ if attorney has not already done so. The

Pro Hac Vice

optionmust be selected when registering. Signed by Clerk on 8/19/2022. (mh4s, Deputy Clerk) (Entered:08/19/2022)

08/19/2022

PAPERLESS ORDER granting

Motion to Appear Pro Hac Vice on behalf of Gabriel Diaz. Directingattorney Gabriel Diaz to register for pro hac vice filing in the District of Maryland through PACER athttps://pacer.uscourts.gov/ if attorney has not already done so. The

Pro Hac Vice

option must beselected when registering. Signed by Clerk on 8/19/2022. (mh4s, Deputy Clerk) (Entered: 08/19/2022)

08/26/2022

Case Reassigned to Judge Stephanie A. Gallagher. Magistrate Judge Beth P. Gesner no longer assignedto the case. (jf3s, Deputy Clerk) (Entered: 08/26/2022)

09/01/2022

SUMMONS Returned Executed by Nathan Connolly, Shani Mott. All Defendants.(Relman, John)(Entered: 09/01/2022)

09/07/2022

NOTICE of Appearance by Mark Patrick Johnson on behalf of 20/20 Valuations, LLC, Shane Lanham(Johnson, Mark) (Entered: 09/07/2022)

09/07/2022

NOTICE of Appearance by Gregg Edward Viola on behalf of 20/20 Valuations, LLC, Shane Lanham(Viola, Gregg) (Entered: 09/07/2022)

09/07/2022

NOTICE of Appearance by David Edward Mills on behalf of Loandepot.com, LLC (Mills, David)(Entered: 09/07/2022)

09/07/2022

NOTICE of Appearance by Katherine L Halliday on behalf of Loandepot.com, LLC (Halliday,Katherine) (Entered: 09/07/2022)

09/07/2022

Joint MOTION for Extension of Time

to Respond to Complaint and to Set a Briefing Schedule forDefendants' Motions to Dismiss

by Loandepot.com, LLC (Attachments: #

Text of Proposed Order)(Halliday, Katherine) (Entered: 09/07/2022)

09/07/2022

ORDER granting

Joint Motion to Extend Time to Respond to Complaint and to Set a BriefingSchedule for Defendants' Motions to Dismiss. Signed by Judge Stephanie A. Gallagher on 9/7/2022.(kk5s, Deputy Clerk) (Entered: 09/07/2022)

09/07/2022

MOTION to Appear Pro Hac Vice for Michelle L. Rogers

(Filing fee $100, receipt number AMDDC-10141478.) by Loandepot.com, LLC(Halliday, Katherine) (Entered: 09/07/2022)

09/07/2022

MOTION to Appear Pro Hac Vice for Jorge Sarmiento

(Filing fee $100, receipt number AMDDC-10141493.) by Loandepot.com, LLC(Halliday, Katherine) (Entered: 09/07/2022)

09/08/2022

PAPERLESS ORDER granting

Motion to Appear Pro Hac Vice on behalf of Michelle L. Rogers.Directing attorney Michelle L. Rogers to register for pro hac vice filing in the District of Marylandthrough PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The

Pro Hac Vice

option must be selected when registering. Signed by Clerk on 9/8/2022. (mh4s, Deputy Clerk)(Entered: 09/08/2022)

09/08/2022

PAPERLESS ORDER granting

Motion to Appear Pro Hac Vice on behalf of Jorge Sarmiento.Directing attorney Jorge Sarmiento to register for pro hac vice filing in the District of Marylandthrough PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The

Pro Hac Vice

option must be selected when registering. Signed by Clerk on 9/8/2022. (mh4s, Deputy Clerk)(Entered: 09/08/2022)

10/12/2022

Joint MOTION for Extension of Time to File Answer

to Respond to Complaint

by 20/20 Valuations,LLC, Shane Lanham (Attachments: #

Text of Proposed Order Order)(Johnson, Mark) (Entered:10/12/2022)

10/13/2022

PAPERLESS ORDER granting

Motion for Extension of Time to Answer. Answer due 11/14/2022.Signed by Judge Stephanie A. Gallagher on 10/13/2022. (vals, Chambers) (Entered: 10/13/2022)

10/27/2022

MOTION to Withdraw as Attorney

by Loandepot.com, LLC (Attachments: #

Text of ProposedOrder)(Halliday, Katherine) (Entered: 10/27/2022)

10/27/2022

PAPERLESS ORDER granting

Motion to Withdraw as Attorney. Attorney Katherine L Hallidayterminated. Signed by Judge Stephanie A. Gallagher on 10/27/2022. (kb3s, Deputy Clerk) (Entered:10/27/2022)

10/28/2022

AMENDED COMPLAINT against 20/20 Valuations, LLC, Shane Lanham, Loandepot.com, LLC,filed by Nathan Connolly, Shani Mott.(Relman, John) (Entered: 10/28/2022)

10/31/2022

NOTICE by Nathan Connolly, Shani Mott re

Amended Complaint

Amended Complaint Redline

(Relman, John) (Entered: 10/31/2022)

11/07/2022

Joint MOTION for Extension of Time to File Response/Reply as to

Amended Complaint

and forBriefing Schedule for Motion to Dismiss

by 20/20 Valuations, LLC, Shane Lanham (Attachments: #

Text of Proposed Order Order)(Johnson, Mark) (Entered: 11/07/2022)

11/08/2022

ORDER granting

Joint MOTION for Extension of Time to File Response/Reply as to

AmendedComplaint and for Briefing Schedule for Motion to Dismiss

and for Briefing Schedule for Motion toDismiss

. Signed by Judge Stephanie A. Gallagher on 11/8/2022. (kb3s, Deputy Clerk) (Entered:11/08/2022)

12/05/2022

MOTION to Appear Pro Hac Vice for David DePriest

(Filing fee $100, receipt number AMDDC-10304019.) by Nathan Connolly, Shani Mott(Relman, John) (Entered: 12/05/2022)

12/05/2022

PAPERLESS ORDER granting

Motion to Appear Pro Hac Vice on behalf of David DePriest.Directing attorney David DePriest to register for pro hac vice filing in the District of Marylandthrough PACER at https://pacer.uscourts.gov/ if attorney has not already done so. The

Pro Hac Vice

option must be selected when registering. Signed by Clerk on 12/5/2022. (mh4s, Deputy Clerk)(Entered: 12/05/2022)

12/12/2022

MOTION to Dismiss for Failure to State a Claim

by 20/20 Valuations, LLC, Shane Lanham(Attachments: #

Memorandum in Support Memo of Law, #

Exhibit 1, #

Exhibit 2, #

Exhibit 3,#

Exhibit 4, #

Exhibit 5, #

Exhibit 6, #

Exhibit 7, #

Exhibit 8, #

Text of Proposed OrderOrder)(Johnson, Mark) (Entered: 12/12/2022)

12/12/2022

MOTION to Dismiss for Failure to State a Claim

by Loandepot.com, LLC (Attachments: #

Memorandum in Support, #

Exhibit A, #

Exhibit B, #

Exhibit C, #

Text of Proposed Order)

(Mills, David) (Entered: 12/12/2022)

12/13/2022

NOTICE by Loandepot.com, LLC re

MOTION to Dismiss for Failure to State a Claim

Replacement Exhibit A to Motion to Dismiss

(Mills, David) (Entered: 12/13/2022)

12/29/2022

Joint MOTION for Extension of Time to File Response/Reply as to

Order on Motion for Extensionof Time to File Response/Reply,

by Nathan Connolly, Shani Mott (Attachments: #

Text of ProposedOrder)(Relman, John) (Entered: 12/29/2022)

12/29/2022

PAPERLESS ORDER granting

Motion for Extension of Time to File Response/Reply re

MOTION to Dismiss for Failure to State a Claim

MOTION to Dismiss for Failure to State aClaim

. Signed by Judge Stephanie A. Gallagher on 12/29/2022. (vals, Chambers) (Entered:12/29/2022)

01/24/2023

ANSWER to

Amended Complaint

, COUNTERCLAIM against All Plaintiffs by 20/20 Valuations,LLC, Shane Lanham.(Johnson, Mark) (Entered: 01/24/2023)

01/24/2023

Local Rule 103.3 Disclosure Statement by 20/20 Valuations, LLC, Shane Lanham identifying OtherAffiliate General Star National Insurance Company for 20/20 Valuations, LLC, 20/20 Valuations,LLC, Shane Lanham, Shane Lanham.(Johnson, Mark) (Entered: 01/24/2023)

01/26/2023

NOTICE of Appearance by David S Wachen on behalf of 20/20 Valuations, LLC, Shane Lanham(Wachen, David) (Entered: 01/26/2023)

01/30/2023

Joint MOTION to Amend/Correct 35 Order on Motion for Extension of Time to File Response/Reply,

by Nathan Connolly, Shani Mott (Attachments: #

Text of Proposed Order)(Relman, John) (Entered:01/30/2023)

Mary Cummins

Wednesday, January 25, 2023

Appraisal Subcommittee Hearing on Appraisal Bias January 24, 2023, notes by Mary Cummins

Appraisal Subcommittee Public Hearing on Appraisal Bias, January 24, 2023, marcia fudge, mary cummins, asc, hud, real estate appraiser, pave taskforce, cfwb, jim park, race, racial bias, discrimination, black, brown, white, value, neighborhood, appraisal, valuation

https://www.consumerfinance.gov/about-us/events/appraisal-subcommittee-hearing-on-appraisal-bias/

https://www.youtube.com/watch?v=QW8ADw9vOSc

Appraisal Subcommittee Hearing Meeting about Appraisal Bias in Residential Real Estate Market ASC notes, comments by Mary Cummins. Part of the meeting was on C-SPAN 2.

Time: 2:10:35

“Streamed live on Jan 24, 2023. Join the Federal Financial Institutions Examination Council’s Appraisal Subcommittee (ASC) for a hearing about appraisal bias. Invited witnesses representing key stakeholder groups will share their views with the ASC during the hearing.”

Official information and files.

The Federal Financial Institutions Examination Council’s Appraisal Subcommittee (ASC) held a hearing about appraisal bias.

"This first-ever ASC hearing was led by Deputy Director Martinez and ASC Executive Director Jim Park. HUD Secretary Marcia L. Fudge, CFPB Director Rohit Chopra, and FHFA Director Sandra Thompson also participated in the hearing. Panel witnesses included:

Dr. Junia Howell, Visiting Assistant Professor of Sociology at the University of Illinois Chicago; Witness Testimony. It'd be better to read her testimony because she was extremely nervous, waving her arms around wildly, misspeaking and acting agitated. Most upsetting and more importantly she stated some totally false and ignorant things. She said the sales comparison approach was developed in the 1930s by whites in the US government to intentionally value white owned property higher than POC owned property. She doesn't even realize that most living in areas which were, are primarily POC especially back then were, are renters and not owners. There are also poor white areas in the US. How does she explain that? The sales comparison approach to value is the main method used to value all assets all over the world since the beginning of time. She said the government should basically give more money to her to do more deeply flawed "research." It appears that all speakers had to swear to the host of the meeting that they will only agree with the government's incorrect and preconceived ideas on the issue of the alleged "appraisal" and wealth gap. She's so ignorant she doesn't realize it's caused by the income gap and not appraisals. Lots of independent research out there to prove this. People buy homes they can afford. People who make less money but less expensive homes.

https://files.consumerfinance.gov/f/documents/cfpb_appraisal-hearing_junia-howell-testimony_2023-01-24.pdf

Paul Austin and Tenisha Tate-Austin, homeowners from Marin, California; Witness Testimony

https://files.consumerfinance.gov/f/documents/cfpb_appraisal-hearing_paul-austin-and-tenisha-tate-austin-testimony_2023-01-24.pdf

Michael Fratantoni, Senior Vice President of Research and Technology and Chief Economist, the Mortgage Bankers Association; Witness Testimony

https://files.consumerfinance.gov/f/documents/cfpb_appraisal-hearing_michael-fratantoni-testimony_2023-01-24_Tw7XwtE.pdf

Craig Steinley, President, the Appraisal Institute; Witness Testimony

https://files.consumerfinance.gov/f/documents/cfpb_appraisal-hearing_craig-steinley-testimony_2023-01-24.pdf

More information about the Appraisal Subcommittee can be found here"

MEETING START

Time: 6:29 Introduction by Zixta Martinez Chair of Board of ASC and CFPB. Jim Park will talk about ASC. We’ll hear from a panel of witnesses, a home owner, lender, appraiser and academic. She introduced Marcia Fudge head of HUD.

Time: 9:28 Honorable Marcia L Fudge of HUD and PAVE. I'm only going almost word for word what Fudge said because it's so important. Fudge makes her own personal bias very clear in what she said and the falsehoods she stated.

Fudge said “good morning” and got a mild response. She basically responded she didn’t like the mild response and again said “GOOD MORNING!” and everyone then responded with “GOOD MORNING!” It set the tone.

Since day one the Biden Harris administration has worked to root out bias in the appraisal system. The work is critical to advance racial equity. It’s important to me as secretary of HUD and as a black woman. I know first hand what it’s like to be told that your home is worth less than the house down the street because of the color of your skin. It’s heartbreaking to hear the stories of black and brown families who feel forced to remove family mementos and photos in hopes of receiving a fair and accurate valuation. I do not intend to do that!

Fair Housing Act of 1968 was to end housing segregation. Owning a home should provide a path to the American dream. Instead this country does not see us as equitable. June 1, 2021 100 years after Tulsa Race massacre Biden and Harris established PAVE task force a first of its kind initiative to root out racial discrimination in the home buying process so families of all backgrounds and neighborhoods can have a better chance at building generational wealth. Less than a year after PAVE was established we delivered an action plan which constitutes set of reforms to advance racial equity in the home appraisal process. We want to cultivate a well trained and diverse work force, to make sure technology doesn’t perpetuate bias. HUD made $28M available to fund testing, education, and outreach to communities on appraisal bias. Next week we will start a three part webinar on training for appraisers and housing professionals on how to identify bias and protect homes. We, (pointing to herself), know how to identify it as we see it every day. We are giving an avenue for FHA loan seekers, if they believe their appraisal was skewed by racial bias. You can make comments on our drafting table platform. Please, make comments.

I’m going to say things not in my script because I live this every day. I live in a black community by choice, BY CHOICE! I want kids in my neighborhood to get same schools as properties next to me. You do that by property tax even though I think it’s unconstitutional, that we fund schools by property tax. I want same police, fire protection but you can’t do it if my house is valued at $50,000 less than the house next to me. Two doors from me there is a neighborhood that is all white. My house is bigger, my lot is bigger, my house is nicer (laughter). That (other) house is valued more than mine. This is not the America that we should be living in, in the year 2023. It is a travesty, outrageous and we must change it. I’m hopeful the ASC will do what is right for the American people.15:44.

Mary Cummins comments. Homes are not valued differently because of the color of the skin of the owner, borrower or occupants. It's a mathematical formula based on most recent similar sales in the same neighborhood. Appraisers don't know the color of skin of homeowners, borrowers, tenants, buyers, sellers. We don't see the borrower, buyer and definitely don't know who owns properties in the area we use as comparable sales. We don't look at census tracts. We don't know race or color. It's possible all the owners of the homes we used as comp sales for a property owned by a black person were white. That would mean Fudge's false narrative holds no water.

Fudge states she wants home values and their property taxes to increase. Many poor people would be forced to sell their property and move if property taxes were increased to the level of newer more luxury expensive neighboring properties.They wouldn't even be able to sell their property for the higher non market value. That would be beyond unfair and cruel.

All real estate agents tell all home owners of every color to remove personal articles such as photos, collectibles and other items from their home.It shows the home bigger and better. Buyers don't want to see any homeowner in the home. They want to envision themselves in a blank slate of a home. It's not about race.

HUDs PAVE report was late. It was due in six months. Fudge acts like she finished it early in less than a year. Nope. Late.

Appraisal appeal, reconsideration of values have ALWAYS been available to borrowers forever. They can appeal based on any reason. They have done this. This is not about bias. Research by AEI based on government loan documents proved there is no effect of race on home value. They used the government's own data to show this. AEI presented this to the government in the meeting about the PAVE task force.

AVMs Automatic Valuation Methods do not consider race or color of homeowner or borrower. It's a math formula, technology computed by robots. No human is involved. The math formula is not based on race or color. It's based on location, size, age. It does not know condition, view, upgrades, amenities, true size, additions, lot type, location in neighborhood... AVMs value homes in poor condition higher than market. It values upgraded homes with views lower than market. AVMs aren't accurate. They are BIASED against everyone.

Fudge brought up her home value previously. She said her home is worth less BECAUSE SHE IS BLACK. I included it in a past article with address and attributes. I included a valuation of her home and of the NEW, LUXURY homes up, across the street from her. It's a private development of new luxury homes tucked away off the main street. I have no idea if the homeowners are all white. I doubt Fudge does either. Has she visited all of them personally? They're new so they're not in the census report. 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... Not all homes of the same size in the same county are worth the same. An old run down home in South LA is worth less than a new one of the same size in Beverly Hills. If Fudge doesn't know this, she must resign because she's unqualified. I know she knows this and is just lying for effect. She's a politician working for politicians selling lies for votes, money and promotions.

The real reason why homes owned by whites are worth more than homes owned by black, brown people is the income gap. People who make more money have more money, more generational wealth and can buy and own more expensive homes. THIS IS THE REAL ISSUE! The government needs to fix the income gap then the wealth gap would solve itself. Men also make more than women. Blaming appraisers will never fix the real issue. The government can't fix the problem (if there even is one) until they admit the real cause of the problem. The first step Scientific Method to solving problems is to determine the actual problem.They clearly don't want to fix the real problem. That means the government doesn't really care about POC or the poor. They need to stop pretending like they do care when they clearly don't. You can yell at appraisers all the live long day and that won't solve the problem.

I'll post notes from rest of the meeting letter. I will also be sending in a comment. I see some of the speakers are the Austins from California. I have covered their case since the beginning. In their linked statement they said they wanted the appraiser to use comps from the "white area" instead of their immediate neighborhood which they said is a "black area." Who are the racists here?

There were five witnesses who basically read word for word their submitted statements linked above except AI Craig Steinley. He omitted a large portion of his written statement. I think he omitted it because he didn't want questions and to get under five minutes. While other speakers said we need to get rid of the "racist" government mandated sales comparison approach AI's statement said they are adamantly opposed to that. Their statement says the approach is based on valid and accurate economic principles which it is. That is how all assets in the world have been valued forever because it is based on supply and demand between buyer and seller. I'll do a short summary in a few minutes anyway.

After that ASC members were allowed to ask ten minutes worth of questions each.

Email after the meeting

“Yesterday the Appraisal Subcommittee held its first ever Hearing on Appraisal Bias, hosted at Consumer Financial Protection Bureau headquarters in Washington D.C.

The event opened with remarks by U.S. Department of Housing and Urban Development Secretary Marcia L. Fudge. ASC’s Executive Director James Park spoke on the agency’s role in the appraisal regulatory landscape.

Attendees, both in person and on the livestream, heard testimony from Dr. Junia Howell, University of Illinois-Chicago, homeowners Paul Austin and Tenisha-Tate Austin, Michael Fratantoni, Chief Economist, Senior Vice President, Research and Industry Technology, Mortgage Bankers Association, and Craig Steinley, President of the Appraisal Institute.

Now ASC wants to hear from you! You are encouraged to provide a comment on your perspective on or experience with appraisal bias; comments can be submitted to AppraisalBiasHearing@asc.gov until February 8, 2023.”

Four of the five witness speakers, Appraisal Subcommittee Public Hearing on Appraisal Bias, January 24, 2023, marcia fudge, mary cummins, asc, hud, real estate appraiser, pave taskforce, cfwb, jim park, race, racial bias, discrimination, black, brown, white, value, neighborhood, appraisal, valuation

Witness Dr Junia Howell, Appraisal Subcommittee Public Hearing on Appraisal Bias, January 24, 2023, marcia fudge, mary cummins, asc, hud, real estate appraiser, pave taskforce, cfwb, jim park, race, racial bias, discrimination, black, brown, white, value, neighborhood, appraisal, valuation

Tenisha Tate Austin, Paul Austin, Appraisal Subcommittee Public Hearing on Appraisal Bias, January 24, 2023, marcia fudge, mary cummins, asc, hud, real estate appraiser, pave taskforce, cfwb, jim park, race, racial bias, discrimination, black, brown, white, value, neighborhood, appraisal, valuation

ASC members, Appraisal Subcommittee Public Hearing on Appraisal Bias, January 24, 2023, marcia fudge, mary cummins, asc, hud, real estate appraiser, pave taskforce, cfwb, jim park, race, racial bias, discrimination, black, brown, white, value, neighborhood, appraisal, valuation

Mary Cummins

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

Monday, April 10, 2023

Thursday, March 23, 2023

Monday, February 20, 2023

Tuesday, February 14, 2023

Wednesday, February 1, 2023

Monday, January 30, 2023

Wednesday, January 25, 2023