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 government. Show all posts
Showing posts with label government. Show all posts

Friday, February 4, 2022

What is the Appraisal Institute? AI is a private non-profit organization and not part of government by Mary Cummins


Many are under the false impression that the Appraisal Institute (AI) is part of the government that oversees and regulates real estate appraisers. That is absolutely false. They are NOT The Appraisal Foundation (TAF). The Appraisal Foundation is "Authorized by Congress as a source of appraisal standards and qualifications." TAF worked with some private appraiser organizations one of which was AI until 2010. TAF stated AI resigned instead of being suspended for violating the Foundation’s Code of Conduct for Sponsoring Organizations. Here's an article I wrote on who actually regulates appraisers and the appraisal industry. 

The Appraisal Institute is instead a private non-profit organization 501 6 c FEIN 36-3739643 formed in 1992 whose mission is to promote real estate appraisers and the business of appraising, IRS code S41 "promotion of business." Their real mission is to sell memberships, classes, publications and their own designations such as MAI... They are primarily focused on commercial appraisers and not really residential. Many feel they are just a private white male commercial appraiser club that promotes itself and not appraisers or the industry as a whole. It costs $15,000 to become an AI MAI appraiser so it's not cheap. Only General Certified Appraisers can become MAI Appraisers. 

Below is their most recent tax return which is their 2019 990 tax return from their Guidestar profile https://www.guidestar.org/profile/36-3739643 . All info came from this public document. Their income was $20,589,361. They allegedly had almost 17,000 members which includes retired, candidates, honorary and affiliates in 2019. In 2007 they stated they had 21,000 members so they lost members?

https://pdf.guidestar.org/PDF_Images/2019/363/739/2019-363739643-202013159349304521-9O.pdf

They state their mission is "THE APPRAISAL INSTITUTE'S MISSION IS TO ADVANCE PROFESSIONALISM AND ETHICS, GLOBAL STANDARDS, METHODOLOGIES, AND PRACTICES THROUGH THE PROFESSIONAL DEVELOPMENT OF PROPERTY ECONOMICS WORLDWIDE."

They have 98 employees and 198 volunteers. Their main income is selling classes, memberships for $18,000,000. Broken down it's $11,000,000 membership dues, $5,800,000 education, $557,000 publications/books, $507,000 admission, grading, $49,000 periodicals. They spend $10,000,000 on salaries. They have about $23,000,000 in assets. $11,000,000 net assets.

Their main employees and salaries, wages are below. Doesn't include bonuses, retirement, health insurance, other items which may be considerably more. AI sometimes pays for travel expenses of spouses. 

Jim Amorin $435,000 50 hrs
Beata Swacha $223,000 50 hrs
Jeffrey Liskar $307,000 50 hrs
William Garber $225,000 45 hrs
Evan Williams $175,000 45 hrs
Stephanie Coleman $179,000 37 hrs
Robert Borst $160,000 37 hrs
Christina Mitakis $151,000 37 hrs

Officers/Directors

Stephen Wagner $164,000 40 hrs/week
Jefferson L Sherman $102,000 20 hrs/week
Rodman Schley $89,000 20 hrs
James Murrett $91,000 20 hrs

Independent Contractors

Heidi Korthase $122,000
Rich Feuer Anderson $120,000
Craig Harrington $100,000

There is an Appraisal Institute PAC Political Action Committee to which AI gives $101,000. They spent $574,000 in lobbying costs. 

PAC disclaimer: APPRAISAL INSTITUTE PAC (AI PAC) PROVIDES A MEANS FOR DESIGNATED MEMBERS, CANDIDATES, AND PRACTICING AFFILIATES TO PARTICIPATE IN THE POLITICAL PROCESS ON A NATIONAL LEVEL. CONTRIBUTIONS CAN BE MADE BY INDIVIDUAL DESIGNATED MEMBERS, CANDIDATES, AND PRACTICING AFFILIATES OF THE APPRAISAL INSTITUTE AND THEIR FAMILIES, AS WELL AS BY APPRAISAL INSTITUTE EMPLOYEES. CONTRIBUTIONS FROM AI PAC SUPPORT THE PRIMARY AND GENERAL ELECTION CAMPAIGN EFFORTS OF CANDIDATES FOR THE U.S. CONGRESS WHO SUPPORT AND PROMOTE THE PRINCIPLES OF THE APPRAISAL PROFESSION. AI PAC DOES NOT CONTRIBUTE TO POLITICAL PARTIES, TO PRESIDENTIAL CANDIDATES, OR TO LEADERSHIP POLITICAL ACTION COMMITTEES.

They received grants $87,000 and paid about $664 in grants. All this money and almost no grants to women, POC or people with less money. Makes it hard to believe they are behind the new grants program for women, POC or people with less money. They basically waited until they were forced to do it. Not only that but they say you must pay to join their club just to apply for a grant. On the flip side they have no problem receiving grants from others such as a PAREA grant from TAF. 

Most in the organization are older white males who are commercial appraisers. There are very few women and fewer POC and residential only appraisers especially on the board or as employees, consultants. 

Below is an article by someone with a lot more knowledge about AI than myself. They had over 25,000 members and now they have about 17,000. It also talks about the loss of education revenue due to online and virtual education. In 2016 main AI started taking the Chapter's money. During this decline in members there has been a great increase in salaries, wages and travel expenses. 

https://www.millersamuel.com/epic-fail-the-appraisal-institute-irs-990s-show-they-needs-to-do-a-180/

Below is a pic of the 2021 BOD. I see a few female tokens and the rest are older white men. 



#appraisalinstitute #AI #TAF #theappraisalfoundation #appraiser #appraisal #appraisalindustry #regulatory #enforcement #appraisalsubcommittee #appraisalinstituteorg 

http://www.linkedin.com/company/appraisal-institute

https://www.youtube.com/channel/UC6mGHNrWBOD12iqKCHqxmZw

https://www.facebook.com/AppraisalInstitute

https://twitter.com/AI_National @AI_National

https://www.appraisalinstitute.org/rss/news.aspx?CategoryId=1

http://blog.appraisalinstitute.org/

https://en.wikipedia.org/wiki/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 DISCLAIMER: https://mary--cummins.blogspot.com/p/disclaimer-privacy-policy-for-blogs-by.html
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Sunday, August 1, 2021

Who oversees, regulates Real Estate Appraisers in the US? The Federal and State governments. by Mary Cummins

real estate appraiser, regulation, firrea, mary cummins, los angeles, california, real estate appraisal, hud, fha, appraisal foundation
real estate appraiser, regulation, firrea, mary cummins, los angeles, california, real estate appraisal, hud, fha, appraisal foundation

Some people seem to be under the misconception that real estate appraisers govern themselves via the Appraisal Institute. The Appraisal Institute is a private nonprofit organization for a few real estate appraisers. It's very expensive so there aren't that many members compared to total number of appraisers in the US. (There are 78,000 real estate appraisers with licenses as of 2018 in the US. Allegedly AI has 25,000 members in the world. They include retired and life time members. Because it's expensive to join I find it hard to believe they have 25,000 members). It has nothing to do with the government, licenses or regulations though they do sometimes publicly comment on issues which affect appraisers. The Appraisal Institute is NOT The Appraisal Foundation (TAF).

Real estate appraisers are regulated by federal and state governments. In 1989 the FIRREA Act (aka Savings & Loan bailout) established The Appraisal Foundation (TAF) and the  Appraisal Subcommittee (ASC). The Appraisal Foundation is authorized by Congress as the source of appraisal standards and appraiser qualifications. The Appraisal Subcommittee (ASC) of the Federal Financial Institutions Examination Council monitors and reviews the work of The Foundation. The Committee also maintains oversight authority over the states to ensure the minimum qualifying criteria to license and certify real estate appraisers are implemented and that appraisers are held to a professional set of ethical standards.  

The Appraisal Foundation’s Appraiser Qualifications Board (AQB) sets the minimum Real Property Appraiser Qualification Criteria and the Appraisal Standards Board (ASB) develops the generally accepted standards of practice for the appraisal profession which is the Uniform Standards of Professional Appraisal Practice. These are reviewed every two years. Everyone can comment while they're being updated.

Each US state or territory has a real estate appraiser regulatory agency that is responsible for licensing and certifying real estate appraisers and supervising their appraisal-related activities, as required by Federal law. Here is a list of all the state regulatory agencies for real estate appraisers. 

Here in California we didn't need a license until 1994 after FIRREA passed. Real estate appraisers had nothing to do with the Savings & Loan crisis but as usual they were falsely blamed and later more heavily regulated. I fully support all real estate appraisers being licensed. It should have happened when they licensed real estate agents. I was both a real estate agent/broker and appraiser at the same time. I was first licensed as a real estate appraiser in 1994. I was licensed as a real estate agent in 1983 and broker in 1986. 

After the great recession the Dodd Frank Act was passed in 2010 which added even more regulations for banks, lenders and real estate appraisers. Again, real estate appraisers were blamed for the crisis. Real estate appraisers only report value based on past sales. We don't drive sales or affect the market. The problem was lenders giving loans to people regardless of their ability to pay them back. When the bubble burst many people who couldn't make their payments lost their homes. 

The Dodd Frank Act set up a system of Appraisal Management Companies (AMCs) via the Home Valuation Code of Conduct (HVCC). "The Home Valuation Code of Conduct (HVCC) is a set of federal guidelines designed to make the home appraisal process more reliable. The HVCC prohibits mortgage brokers and real estate agents from selecting or paying appraisers. Instead, lenders or third-party companies selected by the lenders are the only parties allowed to contact, retain, and compensate appraisers. This adds a buffer between the appraiser and the interested parties trying to close the deal. Conventional conforming loans backed by Fannie Mae and Freddie Mac must comply with the HVCC. FHA loans and VA loans are excluded from compliance with the HVCC." Instead of having the mortgage broker or real estate agent assign an appraiser the lender now hires the AMC who hires the appraisers. The AMC is the new middleman. The purpose was so the lender wouldn't be able to pressure the appraiser to hit an appraisal price. 

The concept of AMCs did not work. The appraiser still must contact the owner, borrower to inspect the property. The owner, borrower sometimes says "Here are some comparable sales from the lender and my real estate agent. I need a value over $500,000." Not only that but after the appraisal is submitted to the AMC who gives it to the lender the owner, borrower, lender, AMC can request a reconsideration of value, an appraisal appeal. They can request that certain other comparable sales and factors be considered. The lender can also make requests in underwriting. The addition of the AMC has only lead to increased appraisal costs, time and red tape for the borrower. 

The real estate appraiser does not have to make the requested changes unless they are legitimate. Obviously if you refuse legitimate changes you won't be hired again. The owner, borrower, lender can also order another appraisal. There are some agents, lenders who refuse to use certain appraisers because they didn't hit their price points in the past. The only thing AMCs did add is an extra middleman fee paid by the owner, borrower. If you are paying $650 for an appraisal, $300 goes to the AMC and $350 goes to the appraiser. If you want a review, it can cost even more. 

If you have a problem with an appraisal, request a reconsideration of value. Here's an article I wrote about how to do that. You can also call the appraiser. If you leave a ranting voicemail, they probably won't return your call. Their client is the AMC. The appraiser doesn't have to speak to you after the appraisal is completed. We only have to speak to the owner in order to inspect the home. 

If you have a problem with an appraiser that is beyond a reconsideration of value, you can file a complaint with the state where they are licensed. You can also file a complaint with the federal government depending upon the nature of the complaint. HUD handles discrimination complaints. Below describes the process for HUD housing discrimination complaints. If you as the home owner or borrower have a problem with an appraisal which was ordered for the lender, you don't have a legitimate legal basis for discrimination because you are not the intended user. Your complaint will be dismissed.  

https://www.hud.gov/program_offices/fair_housing_equal_opp/complaint-process

Below is a chart showing the outcome of HUD discrimination complaints for 2019. Most complaints are for disability discrimination and not skin color or race. Only 2% of the HUD housing discrimination complaints had cause. This is for 2019. 37% had no reasonable cause, 7% withdrawn, 36% conciliated, 14% administrative closure, 4% DOJ referral. This sounds about right. I've seen a few friends claim discrimination about a transaction. I ask them what happened. So far almost all of the time it wasn't discrimination that caused the issue. Most of the time it appears to be quick appreciation or a second appraiser appraising the property way above market value by using sales in a much superior area. Now when it comes to every day events I see discrimination all the time especially as it relates to skin color, gender, race. 


Right now August 2021 some buyers, borrowers feel they are being low-balled because some homes are under contract for more than they are appraised. Appraisals are coming in under purchase price. The problem is the skyrocketing market and limited supply which is causing people to bid over list price and over market value. Appraisers used sold comparables to support the value. That means we're 1-3 months behind the market at times. If there isn't a recent sale of a similar home we have to use older comps. We also can't appraise over the highest unadjusted sold comparable home even though we can time adjust. This is not our fault as we are following the law and regulations. It's happening to everyone regardless of color. Just because your appraisal came in low does not mean the appraiser was racist and discriminated against you. Appraising is a math formula based on home location, size, condition, amenities. Racism and discrimination exist. That doesn't mean every appraisal that is lower than what someone would like is the result of racism. The most common cause of loan denial is actually the creditworthiness of the borrower. 

More information below about real estate appraisal regulation. 

https://www.appraisalfoundation.org/imis/TAF/About_Us/Appraiser_Regulatory_System/TAF/Regulatory_Structure.aspx

#realpropertyappraisers #realestateappraisers #realestateappraisal #hud #fha #marycummins #losangeles #california #firrea #doddfrankact #greatrecession #savingsandloanbailout #uniformstandardsofprofessionalappraisalpractice #uspap #appraisalfoundation #appraisalsubcommittee #asc #appraisersquallificationboard #aqb #complaint #realestate #appraisal 

Mary Cummins of Animal Advocates is a wildlife rehabilitator licensed by the California Department of Fish and Game and the USDA. Mary Cummins is also a licensed real estate appraiser in Los Angeles, California.


Google+ Mary Cummins, Mary K. Cummins, Mary Katherine Cummins, Mary Cummins-Cobb, Mary, Cummins, Cobb, wildlife, wild, animal, rescue, wildlife rehabilitation, wildlife rehabilitator, fish, game, los angeles, california, united states, squirrel, raccoon, fox, skunk, opossum, coyote, bobcat, manual, instructor, speaker, humane, nuisance, control, pest, trap, exclude, deter, green, non-profit, nonprofit, non, profit, ill, injured, orphaned, exhibit, exhibitor, usda, united states department of agriculture, hsus, humane society, peta, ndart, humane academy, humane officer, animal legal defense fund, animal cruelty, investigation, peace officer, animal, cruelty, abuse, neglect #marycummins #animaladvocates #losangeles #california #wildlife #wildliferehabilitation #wildliferehabilitator #realestate #realestateappraiser #realestateappraisal #lawsuit

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Thursday, June 20, 2019

Letter in reply to Andre Perry of the Brookings Institute presentation to the U.S. House Committee on Financial Services

I watched the U.S. House Committee on Financial Services meeting today. All the experts were great except one that didn't belong there, namely Andre Perry. He was not in the real estate or finance industry. He works with the Brookings Institute in the Metropolitan Policy Program. He is clueless about real estate, value and finance.

Andre Perry thinks homes owned by black people are under valued by $48,000 by appraisers. He compared similar sized homes in predominantly white and black areas using computer made valuation models. He determined that real estate appraisers are intentionally reducing the value of the homes owned by black people by $48,000. The valuations were made by computer software and not appraisers. They were based on location, size, bed/bath count, age... 

Did Perry even stop and consider when these people buy these homes in different areas they are paying different prices because they are worth different amounts because they're in different locations? How did the Brookings Institute let this paper get out? I no longer respect the Brookings Institute if they can release this garbage report. The valuations were not made by people, by real estate appraisers but software programs. The software is not biased against people of color, women, elderly, LGBTQ... because it doesn't see the people. It doesn't even see the home. That is not a real valuation. This does not prove bias by real estate appraisers. 

(Turns out Andre Perry has a book coming out about blacks and value. He's hitting up all the shows and meetings gearing up for his book release.)

In the meeting only one person agreed with Mr. Perry. That person was POC Congresswoman Rashida Tlaib (MI-13). She is a new politician elected in 2019. She needs some education. Why was she put on this Committee when she knows nothing about the subject matter? They should know the basics of an issue before they are put on a Committee.

She said, "Homes look identical but homes in white areas are worth more? Doesn't make sense. You are working in a broken system. You should be able to change the value based on other things. It's not right that someone with no money can't buy a home. I want to take you home to my district (to Mr. Perry because what he said agrees with her thinking)."

How is Rashida Tlaib on this committee when she knows nothing about property value, buying homes and owning a home? A similar size home in Detroit, Michigan is worth less than a similar size home in California because people would prefer to live in California. That does make sense. 

If you were to give a poor person money for a down payment and put them in a home they can't afford, they will lose the home when they can't afford to make mortgage payments. They would be worse off. I've seen it happen. Not everyone in the US needs to own a home especially now that the real estate recession started Q4 2018.

Mary Cummins
645 W 9th St #110-140
Los Angeles, CA 90015

June 20, 2019

Amy Liu, Mark Muro, Alan Berube
Brookings Institute
Metropolitan Policy Program
Via email: MetroMediaRelations@brookings.edu
Members of the U.S. House Committee on Financial Services
Via email: FSCDems@mail.house.gov
RE: "Know Your Price: The Devaluation of Residential Property in Black Neighborhoods," authors Andre Perry and David Rubenstein

June 20, 2019 Andre Perry sat before the U.S. House Committee on Financial Services. He presented the above paper to the Committee linked here https://financialservices.house.gov/uploadedfiles/hhrg-116-ba04-wstate-perrya-20190620.pdf.

Andre Perry stated in his paper, "We sought to understand how much money majority-black  communities are losing in the housing market stemming from racial bias, finding that owner-occupied homes in black neighborhoods are undervalued by $48,000 per home on average, amounting to $156 billion in cumulative losses."

Andre Perry does not understand the basics of home valuation or even value. He inferred in the meeting that real estate appraisers intentionally reduce the value of a home owned by a black family. Mr. Perry said he could see no other reason why the similar homes in different locations were valued differently. Everyone knows real estate is valued by location, location, location. When the audience was asked by a Committee member if they thought appraisers discriminate against black people in arriving at the value Mr. Perry was the only person who raised his hand in a room of real estate valuation experts.

I've been a real estate appraiser, broker, expert witness over 35 years in Los Angeles, California. I will give a brief explanation of the concept of value and how appraisers arrive at the value of a home. There is no adjustment for skin color.

The value of a home is what a willing buyer is willing to pay to a willing seller in an open market. Most of a home's value is location. A 1,500 sf 50 year old home in Detroit will be valued differently than a 1,500 sf 50 year old home in Beverly Hills. Facts are facts. Numbers are numbers. The value is what it is.

All real estate appraisers must comply with the Uniform Standards of Professional Appraisal Practice (USPAP). To appraise an average home the appraiser searches for other similar homes which have sold recently, are currently listed or under contract in the same area. The mathematical formula is to search +/- 15% difference in gross living area, within the last six months and within a half a mile radius of the subject property.  The appraiser then selects the comparables which are most similar to the subject property in terms of age, amenities, modifications... We widen or tighten the search parameters as needed to find proper comps. We must bracket for size, bed/bath count and age. We then generally use the three most similar sold comps, one comp under contract and one current listing.

After we have our comps we make adjustments for the differences among the comps and the subject property. One might be slightly larger, have an extra bedroom, bath, garage, be fully remodeled or a fixer. We adjust for all factors which are different. In a perfect world we will find comps exactly like the subject and never have to adjust.

We don't and can't search for the color of skin of the owner of the comp properties. We don't even know the color of skin of the owner of the subject property unless we see them at the property. We generally meet the agent or the home is vacant and we meet no one. If a person or a portrait of a person is in our photos, we must Photoshop the people out of the photos.

Homes in areas that are predominantly black, Latino are generally though not always valued less than homes in primarily white neighborhoods. There are a few areas in Los Angeles where it's reversed. The correlation is between what the buyers can afford to buy and the price at which the homes are selling. No one is steering certain races to certain areas. People buy homes which they like and can afford.

Racism most certainly exists. Blacks, Latinos make less than whites. Women make less than men. That said real estate appraisers do not value homes owned by black people less than homes owned by whites. We value homes based on size, age, amenities and location.

Sincerely,

Mary Cummins
Se habla Español!

https://drive.google.com/file/d/15g-0CdRhvY9WA0-5p2KQoi7dzbMMjK0P/view?usp=sharing

Mary Cummins of Animal Advocates is a wildlife rehabilitator licensed by the
Mary Cummins of Animal Advocates is a wildlife rehabilitator licensed by the California Department of Fish and Game and the USDA. Mary Cummins is also a licensed real estate appraiser in Los Angeles, California.


Google+ Mary Cummins, Mary K. Cummins, Mary Katherine Cummins, Mary Cummins-Cobb, Mary, Cummins, Cobb, wildlife, wild, animal, rescue, wildlife rehabilitation, wildlife rehabilitator, fish, game, los angeles, california, united states, squirrel, raccoon, fox, skunk, opossum, coyote, bobcat, manual, instructor, speaker, humane, nuisance, control, pest, trap, exclude, deter, green, non-profit, nonprofit, non, profit, ill, injured, orphaned, exhibit, exhibitor, usda, united states department of agriculture, hsus, humane society, peta, ndart, humane academy, humane officer, animal legal defense fund, animal cruelty, investigation, peace officer, animal, cruelty, abuse, neglect #marycummins #animaladvocates #losangeles #california #wildlife #wildliferehabilitation #wildliferehabilitator #realestate #realestateappraiser #realestateappraisal #lawsuit
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