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 race. Show all posts
Showing posts with label race. Show all posts

Friday, August 11, 2023

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

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

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

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

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

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

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

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

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

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

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

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

Pinto and Peter determined:

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

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

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


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


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

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Wednesday, July 19, 2023

Fed Michael Barr: AI could 'perpetuate or even amplify' racial bias in mortgages, by Mary Cummins

Michael Barr of the Federal Reserve stated artificial intelligence AI could perpetuate or even amplify racial bias in mortgages, mary cummins, real estate appraiser, real estate appraisal, los angeles, california, michael barr, racial bias,federal reserve, fed, loan origination, race, black, white, bias
Michael Barr of the Federal Reserve stated artificial intelligence AI could perpetuate or even amplify racial bias in mortgages, mary cummins, real estate appraiser, real estate appraisal, los angeles, california, michael barr, racial bias,federal reserve, fed, loan origination, race, black, white, bias

Artificial Intelligence (AI) is now being accused of racial bias. They're basically stating math, statistics, numbers themselves are racially biased. Again, the correlation between race and home value is caused by the income gap. If you have less money, you buy a less expensive home. Same with credit scores. The less money you have, the lower your credit score. POC make less money than whites. I'm just glad they're not still falsely accusing appraisers of AI's bias like they did previously with Andre Perry's fraudulent paper. No appraiser was involved in his data only robot Automated Valuation Methods (AVMs) which were basically accurate.

https://www.americanbanker.com/news/feds-barr-ai-could-perpetuate-or-even-amplify-bias-in-mortgages

"Fed's Barr: AI could 'perpetuate or even amplify' bias in mortgages

By  Kyle Campbell

Michael Barr, vice chair for supervision at the Federal Reserve, said in a speech Tuesday that artificial intelligence in mortgage underwriting could exacerbate racial bias if left unchecked.Bloomberg News

The Federal Reserve's top regulator is wary of the use of artificial intelligence in mortgage underwriting. 

Speaking at the National Fair Housing Alliance's national conference Tuesday morning, Fed Vice Chair for Supervision Michael Barr said advancements in mortgage origination technology could lead to discriminatory lending practices."

Just did some Googling on racial bias in loan origination. 98-99% of the difference in loan origination between blacks, whites explained by credit scores and leverage. Did they consider LTV on the home or all debts? There's more to credit than credit score and LTV ratios. They include savings, how long at current job, debts, monthly financial responsibilities, single vs married, children... AEI research considered those factors.

"How much does racial bias affect mortgage lending? We assess racial discrimination in mortgage approvals using new data on mortgage applications. Minority applicants tend to have significantly lower credit scores, higher leverage, and are less likely than white applicants to receive algorithmic approval from race-blind government automated underwriting systems (AUS). Observable applicant- risk factors explain most of the racial disparities in lender denials. Further, we exploit the AUS data to show there are risk factors we do not directly observe, and our analysis indicates that these factors explain at least some of the residual 1-2 percentage point denial gaps. Overall, we find that differential treatment has played a limited role in generating denial disparities in recent years."

https://www.federalreserve.gov/econres/feds/how-much-does-racial-bias-affect-mortgage-lending.htm

I'm thinking this is just showboating for political reasons. The banks, credit unions don't want to give up credit scores. They correlate highly with ability to repay loans. 

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


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

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Tuesday, 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 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

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
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 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

Sunday, June 26, 2022

Wealth gap, income gap, home value gap, race, gender, marital status and Roe v Wade by Mary Cummins

Research has unequivocally shown there is an income and wealth gap between whites and blacks, Latinos. This is why homes owned by white people are worth more than homes owned by blacks, Latinos. People buy the homes they can afford and whites can afford to buy more expensive homes. Appraisers aren't appraising them differently. 

We also know there is a wealth, income gap among men and women, married verses single and especially single mothers with children under 18. Research has also shown that poor, black, Latino women were more likely to get abortions than white women. https://abc7.com/abortion-cdc-data-women/11815941/ 

The reversal of Roe v Wade forcing poor women especially of color to have babies is just going to make the wealth, income gap that much worse. It's also going to cost the states money in welfare, Section 8 housing, Medicare, EBT.... I don't think the GOP really thought about the repercussions of banning abortions. White Supremacists who tow the GOP line including anti-abortion will only have themselves to blame when POC actually do replace them via a higher birth rate. That's already happening but banning abortions will make it happen faster. 

Here's a great article to share with lots of pictures for those who don't care to read.

https://www.vox.com/the-highlight/23182150/abortion-rights-economic-justice

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

Sunday, March 13, 2022

Misleading False Race Related News from Bloomberg Analyzed by Mary Cummins Real Estate Appraiser





Bloomberg writers Shawn Donnan @sdonnan , Ann Choi @annjychoi , Hannah Levitt @hannahlevitt and Christopher Cannon @homiedonttweet just published an article titled "Wells Fargo Rejected Half Its Black Applicants in Mortgage Refinancing Boom. Fewer than half of Black applicants were approved by the biggest bank mortgage lender." This is an incredibly misleading article full of misinterpreted information and some fake data. (editors, contributors Robert Friedman @rfriedman305 Alex Tribou @AlexTribou David Scheer @david_scheer Jason Grotto @jasongrotto)

In the first anecdote with no evidence it's stated Mauise Ricard III tried to refinance a home he didn't live in. Non owner occupied is considered investment property. It's a riskier loan so there is always a higher rate, lower loan to value ratio and stricter loan requirements. They didn't charge him a higher rate because he's black. There is plenty of racism in this world but not everything is racism. Why didn't the writers talk to a loan agent or appraiser to get some accurate information? They wanted more traffic to their article so they intentionally made these false sensationalist claims of racism and outlandish click bait title. 

Let's start with some real facts based on real independent data. Whites make and have more money than blacks, Latinos. "As of 2020, black families have a median household income of just over $41,000, whereas white families have a median household income of more than $70,000." Ref. 1. People who make more money have more money, assets and a higher FICO score Ref. 2. They are a lower credit risk when it comes to loans because they are more likely to be able to afford to pay back the loans. The higher the FICO, the more likely you are to get loan approval, see top chart. Chart below shows the correlation between income and FICO scores. National Association of Realtors NAR research shows the higher the income, the less likely you are to be denied a loan. This is a money issue and not a race issue. 



People buy homes they can afford. Someone who makes less money will buy a less expensive home in a less expensive area because that is what they can afford. That is the correlation. If you want blacks to have higher credit ratings and own more expensive homes, help them make more money. Don't yell at banks and home appraisers for not giving them loans and not appraising their homes over market value. You can complain all day and banks, appraisers can't do anything to fix it. In fact when banks were allowed by the government to be looser with loans and home values were skyrocketing, black homeowners got loans then lost their homes in the great recession because they couldn't afford the payments. You would do a disservice to someone with less money, less income if you gave them a loan they couldn't afford because they are more likely to be foreclosed upon and lose their entire investment and home. You'd be hurting and not helping them.

Here's an analogy maybe people can more easily understand. Blacks and Latinos own cars which are in general worth less money than cars owned white people because they make and have less money. Is Kelly Blue Book the reason why black, Latino owned cars are worth less than white owned cars? No, it's because they bought less expensive cars to begin with because that is what they could afford. Why aren't these people calling KBB racist and biased like they're calling banks and appraisers? It would make just as much sense. 

The article goes on to state that whites were able to refinance more often than blacks in the recent real estate run up with low interest rates. This goes back to income inequality. Even if black, Latino owned homes increased in value, the borrower is still making the same amount of money. While the loan to value ratio is important your home loan amount is based on your ability to repay the loan. Banks don't want a repeat of the great recession where they gave loans to people with equity but no ability to repay those loans. People blamed appraisers for that when it was actually caused by less government oversight and the resulting loose lending. The government and people forced banks to give risky loans to blacks, Latinos and people with low credit ratings. They're trying to do it again now. They do it every time there is a run up in home values. When they did it before the great recession many poorer people just took all the equity out of their homes and spent it on personal items. Then they lost their homes. 

"Wells Fargo, which declined to comment about individual customers, didn’t dispute Bloomberg’s statistical findings. It says it treats all potential borrowers the same, is more selective than other lenders, and an internal review of the bank’s 2020 refinancing decisions confirmed that “additional, legitimate, credit-related factors” were responsible for the differences." (FYI the bank can't comment about individual customers to the media or anyone except the borrower based on privacy, confidentiality law)

Banks have the right to set their lending requirements based on finances. They can discriminate based on finances. After Wells Fargo's tough times a while back you can bet they will tighten lending requirements which is their right. Do people want them giving fast and loose loans to anyone then have another banking crisis and have to bail them out? Remember this below?!

"Wells Fargo agreed in 2012 to pay more than $184 million to settle federal claims that it unfairly steered Black and Hispanic homeowners into subprime mortgages and charged them higher fees and interest rates. The bank didn’t admit to any wrongdoing and said at the time that it treated all customers fairly regardless of race." (FYI government doesn't have to prove bias in these cases. They just have to show one race was treated differently than another).

Previously Wells Fargo gave loans to riskier borrowers and they defaulted. This goes back to income inequality. The less money your make and have, the more likely you are to default on a loan. This time around Wells Fargo decided to reject riskier borrowers and people claim racism, bias and discrimination. No win situation here. Damned it you lend to riskier borrowers, damned if you don't. 

"Rohit Chopra, head of the Consumer Financial Protection Bureau, said at a press conference in October announcing a new push by the Justice Department and regulators to combat so-called redlining by financial institutions. Among the issues he singled out was the role of mortgage underwriting algorithms that banks have long used, calling the disparities in lending outcomes a sign of “digital redlining, disguised through so-called neutral algorithms.”"

The algorithm is based on income, assets, debts, loan to value ratio, debt to income ratio... Research based on millions of loans over decades has shown a positive correlation between higher income, more assets to the ability to repay a loan. The opposite correlates with the inability to repay a loan. It's not redlining. Credit cards, auto loans, other loans are based on the same FICO scores but they're not tied to a property address. That is how people have made lending decisions for centuries all over the world. If a nonprofit or the government wants to loan money to high risk people, let them do it. Don't force private businesses to do it especially government insured banks.

"Kristy Fercho, who in August 2020 became the first Black woman to oversee Wells Fargo’s home-lending business and its more than 25,000 employees, says the bank’s processes are race-blind and that its lending decisions were “consistent across racial and ethnic groups.” Any racial disparity in outcomes for refinancing in 2020 was the result of variables Wells Fargo doesn’t control, she and other executives say, including credit scores, the appraised value of homes and broader inequities in the U.S. economy."

Finally the article speaks a truth, "A typical White family had eight times more wealth than a Black one, according to a triennial Fed survey last published in 2019." And now a huge misleading statement, "The refinancing gap gets at the ability of Black families to build on the wealth they have. Not being able to refinance a home “means that people have less resources to invest in their children, less resources to start businesses, less resources to renovate their homes, less resources to buy additional homes,” says Andre Perry, a senior fellow at the Brookings Institution whose 2018 study found that the average Black home was valued at $48,000 less than its White equivalent. That differential amounts to $156 billion in missing Black wealth."

Andre Perry's "study" is a paper written by himself that was not published or peer reviewed Ref 3. It was based on inaccurate Zillow robot home estimates. No appraisers were involved. Perry intentionally chose two very different groups made up of homes in areas where 0-1% were black and homes in areas well over 50% were black. He didn't know if the homes were owned by white or black people because it's impossible to tell ownership. He compared the very different group values to each other. He did not adjust for location because it's impossible to adjust for location. Everyone knows the main indicators of home value are location, location, location. That misleading paper based on a very small intentionally misleading sample allegedly showed a difference of $48,000 in value between homes in majorly white verses black areas. 

We again go back to the real research which shows whites make more money than blacks, Latinos. Again, people buy homes they can afford. Someone with only $1,000 and a low credit score is not going to buy a $5,000,000 home in Beverly Hills no matter what race they are. They may buy a $75,000 home in Detroit with government financing. Is the bank or appraiser responsible for the differences in value between the $5,000,000 home and the $75,000 home? Not in reality but according to the article they are. 

The article stated that blacks were even less likely to refinance more recently. This goes back to income, credit rating. Even if their home appreciated in value their income, assets, credit rating stayed the same. Banks are more cautious after the great recession. They now make sure people can pay back the loan, make the loan payments based on their income.

Finally after reading the entire article they post a truth, "A 2021 study by Fed researchers given access to a privileged version of the same data used by Bloomberg that included applicants’ credit scores showed racial gaps can be largely attributed to those scores and the recommendations automated underwriting systems make to lenders." Credit scores are the main indicator of underwriting decisions! 

Of course the article went on to state that the credit score algorithm is biased and should be changed. It should include rent payments. Fine, let it include rent payments then do some research to see how that affects ability to repay home loans. Clearly it would only affect first time buyers as second time buyers don't pay rent.

The article then promotes the false biased appraiser myth. Then the article stated that banks raised the credit scores needed to get loans after the great recession which they state is not fair for black people. These people complained when black people lost their homes after the great recession and now they're complaining that they can't get a loose and easy loan? The only way some of these people will be happy is if people just gave them free money and houses. They might think that is fair. 

The authors end their article on the big lie, "He and his wife moved their young family to a bigger home in the more expensive, and predominantly White, Fulton County suburb of Sandy Springs in 2017 to be closer to better schools. (snip)” The move has also given him a rare perspective on the economics of segregation. His new home and those around it are valued far higher than those in the predominantly Black southwestern Fulton County suburb they left behind, where they still own the property they sought to refinance with Wells Fargo. But Ricard says he pays almost as much for the home insurance on his old home, which he now rents out, as his new one."

Ricard wanted to move out of his old predominantly black neighborhood into a predominantly white neighborhood per his own words. He was willing to pay more for a home in a different whiter location. He noted the better schools. Property taxes pay for most of a school's budget. Property taxes are based on home values. The higher the home values, the more money for schools and the better they are. There is also a correlation with lower crime. Lower crime, lower home insurance rates. Of course his insurance is lower in the more expensive neighborhood. This has nothing to do with segregation today. These are all common sense facts for anyone especially anyone in finance, banking and real estate. 

I believe these writers wrote this article knowing full well it's totally inaccurate. The real cause of the wealth gap between whites and blacks is the income gap. Fix the income gap and you will fix the wealth gap. White and black owned homes would eventually appraise the same if their incomes were the same. Stop blaming banks and appraisers for the income gap. Stop spreading this false and misleading misinformation. This misinformation has been weaponizing race to further divide our nation. Racism is a big enough problem as it is. We must do everything we can to stop racism but false and misleading articles like this just make it worse. They detract from the real issues of racism. 

*I sent this blog article to all of the writers, contributors and editors of this misleading article.

Article: https://www.bloomberg.com/graphics/2022-wells-fargo-black-home-loan-refinancing/

Ref. 1. Szapiro, Aron (October 6, 2020). "Can Baby Bonds Shrink the Racial Wealth Gap?". Morningstar.com. Retrieved October 8, 2020.

Ref. 2. People who make more money, have more money and a higher FICO score.August 13, 2018. "Are Income and Credit Scores Highly Correlated?" Rachael Beer, Felicia Ionescu, and Geng Li1

https://www.federalreserve.gov/econres/notes/feds-notes/are-income-and-credit-scores-highly-correlated-20180813.htm

Ref. 3. Andre Perry's paper is based on erroneous data and contains major statistical and analytical errors making the results meaningless.

https://mary--cummins.blogspot.com/2021/06/false-statement-by-president-joe-biden.html

Chart below shows loan approval rating for difference FICO scores for FHA loans. They have looser requirements. Still, the higher the FICO, the higher the chance of loan approval.



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

Wednesday, January 19, 2022

PAVE Task Force Report Coming February 2022, by Mary Cummins Real Estate Appraiser

False and misleading. "The Interagency Task Force on Property Appraisal and Valuation Equity. An equitable path toward addressing the persistent misvaluation and undervaluation of properties experienced by families and communities of color." pave, task force, mary cummins, real estate appraiser, los angeles, california, 

The image above came from the PAVE Task Force website at https://pave.hud.gov . Their statement "the persistent misvaluation and undervaluation of properties experienced by families and communities of color" is very misleading. "Misvaluation" and "undervaluation" have not been proven. There hasn't even been any independent research on the issues. Andre Perry's non peer reviewed, non published personal paper has been shown to have major statistical flaws intentionally made by Andre Perry for his agenda in promoting his book for money. Fannie Mae's research showed there was no major difference in appraisal gap based on the race of the borrower. 

Per the National Association of Realtors (NAR) the Task Force report is coming out February 2022. It will be interesting to read the final report. With statements like the above they clearly have an agenda. If you remember, this was Joe Biden's campaign platform. Here's an article I wrote about Joe Biden's false statements about appraisals and appraisers. Team Biden basically invented a problem that didn't exist so they could promise to fix it just so they could get the vote of POC. I'm a Democrat. I understand politics and campaigning but this is just plain wrong to vilify people and a profession for your own agenda. 

Here's an article I wrote about the purpose of the Task Force. It lists all the members of the Task Force. Again I'd like to note that James Park of the Appraisal Subcommittee (ASC) is the only Appraiser on the Task Force. He doesn't represent Appraisers but the ASC. 

There are some things which should be changed such as the requirements to become an appraiser. The apprentice mentor program is not working. It's too difficult for apprentices and mentors. 

It will be interesting to see the final report. I predict it will basically suggest regulations and actions which are similar to our current regulations but worded as if they are new.

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


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Tuesday, September 28, 2021

California Assembly Bill AB 948 signed by Governor inre Real Estate Appraisal, Bureau of Real Estate Appraisers, by Mary Cummins

California Bill AB 948 Bureau of Real Estate Appraisers, Real Estate Appraisal , Mary Cummins, Los Angeles, Governor Gavin Newsom, signed, license, continuing education, bias, complaints, race, discrimination

Governor Gavin Newsom just signed California Assembly Bill AB 948. AB 948 modifies and adds regulations for appraising, buying, selling, making loans on real estate in California. The new regulations have to do with any alleged bias from anyone. This includes lenders, mortgage brokers, real estate agents and real estate appraisers. 

It's already illegal to discriminate in real estate and housing per the Fair Housing Act of 1968. This new bill basically just restates that. It also adds new educational requirements in regard to bias. They aren't additional educational hours. They are just specific hours for new applicants and renewals.

The bill amends "Sections 11340 and 11360 of, and to add Sections 11310.3 and 11424 to, the Business and Professions Code, to add Section 1102.6g to the Civil Code, and to amend Section 12955 of the Government Code, relating to real estate."

From the Bill, "LEGISLATIVE COUNSEL'S DIGEST AB 948, Holden. Bureau of Real Estate Appraisers: disclosures: demographic information: reporting: continuing education.

Existing law, the Real Estate Appraisers’ Licensing and Certification Law, creates a Bureau of Real Estate Appraisers within the Department of Consumer Affairs to administer and enforce that law. Existing law requires the protection of the public to be the highest priority for the bureau in exercising its licensing, regulatory, and disciplinary functions.

This bill, among other things, would require the bureau to place on an existing complaint form a check box asking if the complainant believes that the opinion of the value of the real estate is below market value. The bill would also require the bureau to collect specified demographic information, voluntarily provided, regarding sellers, those seeking to refinance, buyers, or an authorized representative in real estate transactions making a complaint. The bill would require the bureau to compile the collected demographic information and report that information to the Legislature on or before July 1, 2024.

This bill would prohibit a licensee from basing their appraisal of the market value of a property on the basis of race, color, religion, gender, gender expression, age, national origin, disability, marital status, source of income, sexual orientation, familial status, employment status, or military status of either the present or prospective owners or occupants of the subject property, or of the present owners or occupants of the properties in the vicinity of the subject property, or on any other basis prohibited by the federal Fair Housing Act.

Existing law requires the Chief of the Bureau of Real Estate Appraisers to adopt regulations governing the process and procedures for applying for a license, including education and experience equivalency, and for renewal of a license, including, but not limited to, continuing education requirements on a 4-year cycle.

This bill would require, beginning January 1, 2023, an applicant to complete at least one hour of instruction in cultural competency, as defined. The bill, as part of the continuing education requirement in order to renew a license or restore a license to active status, would require for each licensee renewing on or after January 1, 2023, at least 2 hours of elimination of bias training. Beginning January 1, 2023, a licensee would be required to complete at least one hour of instruction in cultural competency every 4 years.

Existing law requires that specified disclosures be made upon transfer by sale, exchange, real property sales contract, lease with an option to purchase, any other option to purchase, or ground lease coupled with improvements, of any single-family residential property.

This bill, after July 1, 2022, would require that every contract for the sale of single-family residential real property contain a notice stating that any appraisal of the property is required to be unbiased, objective, and not influenced by improper or illegal considerations. The bill would require the notice to include information regarding reporting biased appraisals to the financial institution or mortgage broker that hired the appraiser or the Bureau of Real Estate Appraisers. The bill would also require the notice to be delivered by a licensed person, as defined, refinancing a first lien purchase money loan secured by residential real property containing no more than 4 dwelling units either prior to, or with, the loan estimate or the mortgage loan disclosure statement.

Existing law, the California Fair Employment and Housing Act, prohibits housing discrimination, including discrimination through public or private land use practices, decisions, or authorizations, and based on specified personal characteristics. Existing law makes it unlawful for any person or other organization or entity whose business involves real estate-related transactions to discriminate against any person in making available a transaction, or in the terms and conditions of a transaction, because of specified personal characteristics.

This bill would make it unlawful for any person or other entity whose business includes performing appraisals of residential real property to discriminate against any person in making available those services, or in the performance of those services, because of race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, familial status, source of income, disability, genetic information, veteran or military status, or national origin."

Link to actual bill below.

https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220AB948

This bill appears to be a political response to a couple of California media articles about alleged bias in real estate appraising. One article was about Cora Robinson who filed a complaint. Based on my research the first appraisal was within the range of market value. I did a FOIA request to get a copy of the investigation results and will post them here when they are available. Another article was about Saleem Shaheed. This was another case where the first appraisal was within the range of market value. Shaheed did not file a complaint. 

September 21, 2021 Marcia Fudge the head of HUD stated that there were few complaints for racial bias in appraising. I looked at the HUD stats and agree. A lot of the outrage in the media is from a handful, about five actually, alleged cases of alleged low appraisals caused by alleged racial bias. I researched the five cases and wrote articles in this blog about them. The first appraisals were within the range of market value. They were not low. The markets were quickly appreciating. The second appraisals came in over market value because the second appraiser used comps outside of the area which were not true comparables. I will be posting the results of the FOIA requests of the two complaints filed here.

A lot of these recent claims of alleged racial bias stem from the change in political climate related to George Floyd. "The country is in a time of racial reckoning, heightened by a summer of protests against systemic racism and police brutality following the death of George Floyd in police custody." Floyd's death "sparked the largest racial justice protests in the United States since the Civil Rights Movement." "According to data from various sources, the Black Lives Matter movement is now the largest movement in US history." While racism exists and must be banished from our nation the pendulum has now swung to the extreme side. In this new light anything and everything is automatically "racist" today before even looking at the facts.

It light of everything that is currently happening I believe real estate professionals need to educate their clients and the public about the real estate appraisal, lending and selling processes. Generally the person reading the appraisal report is not the client. The client is the AMC and the lender. The report is made for real estate professionals and not lay people. I think it's a good idea for appraisers to add language for lay people who will probably end up reading the report. Some of the complaints about reports that I've read clearly show that the reader doesn't understand market value or the underwriting process. I believe this has caused some to assume that any value they don't like must be "racism" when it's not. 

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