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

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

Wednesday, February 1, 2023

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Mary Cummins

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

Monday, January 30, 2023

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Realtor

June 2021 6/21

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

January 2022 1/22 $571 $591 $610

01/23 $765

Trulia

01/23 $669

Zillow

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

RedFn

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

Original lawsuit by Plaintiffs.

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

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

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

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

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

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

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

Another good article on the case.

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

Docket to date is below

Date Filed

Docket Text

08/15/2022

COMPLAINT

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

CivilCover Sheet, #

Summons, #

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

08/15/2022

MOTION to Appear Pro Hac Vice for Soohyun Choi

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

08/15/2022

MOTION to Appear Pro Hac Vice for Gabriel Diaz

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

08/15/2022

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

08/15/2022

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

08/15/2022

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

here

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

here

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

here

. To file your consent, go to

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

. To file your declination, go to

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

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

08/15/2022

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

08/19/2022

PAPERLESS ORDER granting

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

Pro Hac Vice

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

08/19/2022

PAPERLESS ORDER granting

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

Pro Hac Vice

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

08/26/2022

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

09/01/2022

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

09/07/2022

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

09/07/2022

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

09/07/2022

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

09/07/2022

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

09/07/2022

Joint MOTION for Extension of Time

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

by Loandepot.com, LLC (Attachments: #

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

09/07/2022

ORDER granting

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

09/07/2022

MOTION to Appear Pro Hac Vice for Michelle L. Rogers

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

09/07/2022

MOTION to Appear Pro Hac Vice for Jorge Sarmiento

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

09/08/2022

PAPERLESS ORDER granting

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

Pro Hac Vice

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

09/08/2022

PAPERLESS ORDER granting

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

Pro Hac Vice

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

10/12/2022

Joint MOTION for Extension of Time to File Answer

to Respond to Complaint

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

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

10/13/2022

PAPERLESS ORDER granting

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

10/27/2022

MOTION to Withdraw as Attorney

by Loandepot.com, LLC (Attachments: #

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

10/27/2022

PAPERLESS ORDER granting

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

10/28/2022

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

10/31/2022

NOTICE by Nathan Connolly, Shani Mott re

Amended Complaint

Amended Complaint Redline

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

11/07/2022

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

Amended Complaint

and forBriefing Schedule for Motion to Dismiss

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

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

11/08/2022

ORDER granting

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

AmendedComplaint and for Briefing Schedule for Motion to Dismiss

and for Briefing Schedule for Motion toDismiss

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

12/05/2022

MOTION to Appear Pro Hac Vice for David DePriest

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

12/05/2022

PAPERLESS ORDER granting

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

Pro Hac Vice

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

12/12/2022

MOTION to Dismiss for Failure to State a Claim

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

Memorandum in Support Memo of Law, #

Exhibit 1, #

Exhibit 2, #

Exhibit 3,#

Exhibit 4, #

Exhibit 5, #

Exhibit 6, #

Exhibit 7, #

Exhibit 8, #

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

12/12/2022

MOTION to Dismiss for Failure to State a Claim

by Loandepot.com, LLC (Attachments: #

Memorandum in Support, #

Exhibit A, #

Exhibit B, #

Exhibit C, #

Text of Proposed Order)

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

12/13/2022

NOTICE by Loandepot.com, LLC re

MOTION to Dismiss for Failure to State a Claim

Replacement Exhibit A to Motion to Dismiss

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

12/29/2022

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

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

by Nathan Connolly, Shani Mott (Attachments: #

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

12/29/2022

PAPERLESS ORDER granting

Motion for Extension of Time to File Response/Reply re

MOTION to Dismiss for Failure to State a Claim

MOTION to Dismiss for Failure to State aClaim

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

01/24/2023

ANSWER to

Amended Complaint

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

01/24/2023

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

01/26/2023

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

01/30/2023

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

by Nathan Connolly, Shani Mott (Attachments: #

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

Mary Cummins

Wednesday, January 25, 2023

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

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

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

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

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

Time: 2:10:35

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

Official information and files.

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

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

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

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

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

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

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

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

Craig Steinley, President, the Appraisal Institute; Witness Testimony

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

More information about the Appraisal Subcommittee can be found here"

MEETING START

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

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

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

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

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

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

Mary Cummins comments. Homes are not valued differently because of the color of the skin of the owner, borrower or occupants. It's a mathematical formula based on most recent similar sales in the same neighborhood. Appraisers don't know the color of skin of homeowners, borrowers, tenants, buyers, sellers. We don't see the borrower, buyer and definitely don't know who owns properties in the area we use as comparable sales. We don't look at census tracts. We don't know race or color.

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 until they admit the real cause of the 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

Saturday, January 21, 2023

FHFA Uniform Appraisal Dataset Aggregate Statistics and How it Impacts You, by Mary Cummins Real Estate Appraier

FHFA Uniform Appraisal Dataset Aggregate Statistics and How it Impacts You, notes and comments by Mary Cummins real estate appraiser, Appraisal Institute, Jillian White, Dr Rashida Johnson-Forsey, Doug Potts, AI, real estate appraisal, appraisal bias, race, white, black, MAI, SRA, FHFA

January 12, 2023 the Appraisal Institute AI posted a video titled "FHFA Uniform Appraisal Dataset Aggregate Statistics and How it Impacts You." Below is their text about the video. Below that are notes which I took and my personal comments about these issues.

"The Federal Housing Finance Agency (FHFA) recently published its new Uniform Appraisal Dataset (UAD) Aggregate Statistics Data File, consisting of 47.3 million UAD appraisal records collected from 2013 through the second quarter of 2022 on single-family properties.

FHFA also launched UAD Aggregate Statistics Dashboards on its website to provide user-friendly visualizations of the newly available data. The UAD Aggregate Statistics Data File and UAD Aggregate Statistics Dashboards give stakeholders and the public new access to a broad set of data points and trends found in appraisal reports.

In this webinar recording, hear from the FHFA Representative who worked on the UAD release, as well as appraiser practitioners about their initial observations and potential use cases of the UAD information for appraisers."

Link to video.

https://www.youtube.com/watch?v=kKGzW1652EI

1. First speaker was Dr. Rashida Johnson-Dorsey of FHFA. She spoke until the 22 minute mark about the FHFA data set statistics. She stated the new data set is from many anonymized real estate appraisals. She believes its most important use is to allegedly discern appraisal bias in valuations of white versus black home buyers. She feels the most important statistic is how many appraisals came in lower or higher than the contract price. She believes this shows bias against minorities specifically blacks.

My comment. Appraisers should not try to meet the contract price. We are mandated to appraise for market value based on most similar, recent sold comparables. If someone wants to offer $10 billion for a $50K shack, fine, but it won't appraise for $10 billion. Contract price does not equal value. The most important thing is market value and not contract price.

https://www.fhfa.gov/DataTools/Pages/UAD-Dashboards.aspx

2. Second speaker was Jillian White. She worked for Better Mortgage as an appraiser then was promoted right before they basically went under. She quit right before the end. Better was known for stating all other appraisers, companies are racist except them. It was part of their marketing. They said they were going to hire diverse appraisers but instead just went out of business. White mainly spoke about racism by white appraisers against blacks at various meetings and to the media while she was at Better. Generally Jillian White talks about racism and appraiser bias against black people. She generally brings up the stories about how she told black relatives to white wash their homes before sale or appraisals. All agents tell everyone to remove all personal photos, items... for many other reasons. She has repeatedly talked about how most appraisers are white old racist men who hate black people and appraise their homes for less than market value. She even said the appraiser trainee program is racist. I based this upon her recorded public statements in the media and public meetings which I've quoted. She supports Andre Perry's false statistics and paper. She was involved in "Our America: LowBalled" promoting the false narrative of the racist appraiser. I've copy/pasted her quotes, comments here in previous articles. While racism definitely exists not everything is racism. Research by AEI showed there was no effect of race of borrower on appraised values.

She actually talked about the "practical application of aggregate UAD statistical data" and
how lenders, AMCs and appraisers can use the data to find alleged racism and bias in appraisals and appraisers. She emphasized that the most important data is whether appraisers come in below or above contract price. Mind you the data set is HUGE and covers every factor involved in appraising. Contract price is one of many, many, many factors but it's the only one they care about. She stated there will be more "scrutiny" if appraisers come in below contract price. There will "be more noise if the value is below the contract price." Noise means complaints. You come in high, you're good to go.

White stated the PAVE report Action 2.3 stated regulators will look at lenders to identify appraisal bias. They will track whether you come in over or under contract price. They will check areas that are 80-100 % minority in census tracts. The lender must explain why they "came in low." "Came in low" per contract price and not market value. She stated over 23% of appraisals were under the contract price in minority areas. We don't have to explain if he come in high. (Wink, wink, hint, hint, come in high.)

My comment: This came up previously. There is another correlation between over/under contract price appraisals. It's not the race of the buyers or appraisers. It has to do with lower income people buying in lower priced areas.

White stated the AMCs will also be questioned. They will have to ask appraisers "why" they came in under the contract price in those areas. Appraisers will then be "forced to explain" why they came in lower than contract price more often than their peers.White stated AMCs will have to ask their appraisers "why are you out of whack in this territory?" i.e. why did you come in below the contract price in this minority area?

My comment: So much for the Dodd Frank Act when you have the government trying to force, push the appraiser to meet the contract price only in minority areas. So much for independent appraisers and appraisals. Appraisers are now being pushed to come in higher than market value in only minority areas. The purpose of the Dodd Frank Act was to stop lenders from trying to force appraisers to meet the contract price! They said it was a cause of the Great Recession. Now the government wants to violate the act and repeat the huge mistake! They're encouraging appraisers to commit bank fraud and commit federal crimes.

White stated that the statistics look at adverse site condition adjustments. She stated that's where appraisers make adjustments that make the value come in lower. She stated maybe in the past there would be a market reaction to a negative site but not today. Is it on a busy street? People don't care today. She feels some appraisers used this adjustment to devalue some properties of some people specifically minorities.

My comment: In the crazy 2021, 2022 market frenzy there could be dead rotting bodies in the homes and buyers would not have cared. They'd just push the dead corpses to the street and carry on. They were willing to buy shit homes in shit condition in shit locations just to own a home. They waived appraisals, inspections, repairs, paid way over list price...and now they regret it. Soon the banks will too.

I saw this. I still mentioned all the negatives I saw and included a market reaction if there was one. You know what? A bank is going to care about those factors if the loan goes south when the market goes down. The market has already made that change. When the market goes down buyers will not want to own a house wedged between a strip club, a recycling center and the 110/10 interchange. They either won't buy that home or they'll pay much less for it. Appraisers appraise at market value to protect the bank and government. Our purpose is not to help a buyer over pay for a property they may not be able to afford and will probably lose to foreclosure in a downturn. This is how people lost their homes after the Great Recession. And guess who was blamed? "Racist appraisers!"

White spoke from 22-45 minutes in the video.

3. Doug Potts, MAI Appraiser.

This guy promotes the false, misleading and totally debunked Andre Perry Brookings Institute "paper." I had a problem with this speaker and what he said. I watched the video after I heard about the crazy things he said from other appraisers. Here we go!

Doug Potts is involved in a grant project that looks at wealth creation and equality. He said blacks have been denied access to wealth in Detroit, Cleveland, Baltimore. If you are born black and poor, you are more likely to stay poor than if you are white. He mentioned redlining.

My comment: This again goes back to the income gap and socioeconomic issues. The real correlation is race is related to income which correlates with wealth, generational wealth and the value of a home you can afford to buy and own. Race is not the cause of the value of a home appraised by an appraiser. Here is an article I wrote about AEI's research about the correlation between race and socioeconomic issues including the income gap. https://mary--cummins.blogspot.com/2022/03/aei-reply-to-pave-report-andre-perrys.html

He mentioned redlining. I wrote an article about redlining here https://mary--cummins.blogspot.com/2021/05/redlining-in-home-loan-financing-mary.html We still use all the same factors to calculate loan risk EXCEPT race, nation of origin. The correlation is not race = home value. It's race = income = value of home one can afford to buy and own. Race, nation of origin never mattered in the redlining maps. If you removed them, the risk didn't change. They should have never been included and weren't included in all stats, maps or records.

Doug Potts said if there is no capital for homes, home loans, areas will collapse.

My comment: It's called capitalism and real estate cycles. People don't want to live in one area so they move to a nicer more expensive one. The old area decreases in value as a result while the new one increases in value. Banks wants to loan money where they can make a profit and limit risk and loss.

Doug said the denial of capital caused whites to leave. No, it didn't! Some people moved to a different area which they found more desirable. THEN values decreased and banks loaned less money to the area based on the lower values of the homes. It's called real estate cycles which has happened forever all over the world. Why is Beverly Hills land worth more than land in Watts? It wasn't "denial of capital." Denial of capital is a result of the change in real estate cycle and property values. Here's an article I wrote on real estate cycles. https://mary--cummins.blogspot.com/2017/04/real-estate-cycles-mary-cummins-real.html

Doug thinks appraisers value homes lower in high minority areas because of the race of buyers. If he really believes this, he should surrender his appraiser license because he's not fit. I appraise in high minority areas with lower values in South Los Angeles. Most of the new buyers are uneducated, inexperienced first time buyers. They want their first home so bad they will offer over market value without knowing it. They will make offers on the worst homes in the area with small lots, poor condition, only one bathroom, recently renovated after major fire, home recently destroyed by tenants, located between freeway and industrial site... because it's all they can afford.

If the median home in the area is 1,000 sf with C3 condition on a 5,000 sf lot built 1920 and goes for $350,000, they offer $325,000 for a smaller home in worse condition on a smaller lot in an inferior location in the neighborhood. Looks like a good deal to them but it's probably worth much less. You're generally looking at minimum home purchase prices. Sometimes they want to buy a home because they were offered government loans with no money down. They have no skin in the game and think they're getting a free house which will double in value in a year. I've had people call me up asking me to find them a VA home, home they can buy with government funds. They tell me they have no job, income or money and believe they can buy the home. Some desperate scammy agents will sell these people homes they can't afford.

Homes in higher minority areas generally have issues. The lower the home value the more issues they have. The correlation again is race and income. Government needs to fix the income gap between white and black, brown. They also need to fix the gender income gap. Lower valued homes are generally located in inferior locations with close proximity to freeways, dump sites, oil fields, industrial property, run down areas... I drive these areas and see it. If the property has a lot of issues, is in fair condition, needs work, it won't meet requirements for a regular loan. It will end up under contract price. A flipper, developer, speculator would need to buy it for cash or with subprime mortgage, fix it up then sell it for a higher price on the regular market with a regular loan.

Doug thinks the lower value appraisals are "prices crushes." He thinks it's just unfair racism. He thinks if there is a 1,000 sf home in South LA on a 5,000 sf lot built in 1920, it should appraise for the same price as a 1,000 sf home in Beverly Hills on a 5,000 sf lot built in 1920. Doug should lose his license. The main value of a home is the LAND and not the STRUCTURE. You are paying for the dirt. LOCATION, LOCATION, LOCATION.

This reminds me of 20 Pacheco, Marin, CA. The owners of that home wanted appraisers to ONLY use comps in Mill Valley 1-2 miles away. Mill Valley homes are worth twice as much as Marin. If you actually look at the two cities, they are very very different and not comparable. There's a reason why Mill Valley is worth twice as much as Marin. Doug thinks appraisers should widen their comp search to intentionally include other HIGHER priced comps. He said higher only and not lower. He thinks it's especially important in lower valued areas which generally have fewer sales for this reason.This was the same issue in Marin. Zillow stupidly widened their AVM search and used Mill Valley comps. More trustworthy Corelogic AVM only used Marin comps and came in at market value.

Doug Potts says his St Louis project "deprioritizes location." It can be used to "restore value." Doug says we can use the new data to cherry pick higher comps outside GSE selling defined rules. He said we can change the algorithm to change the numeric outcome. We can make 1+1=3 when it should be 1+1=2. He admits that it goes beyond assignment conditions. Hey, why not just add $1,000,000 to the appraisal of black owned homes. They can get huge loans, pay huge property taxes, huge monthly mortgage payment then lose their home in foreclosure because no one will buy it for $1,000,000.Doug spoke to 1:06 in the video.

Clearly Doug is out of his mind. What he is suggesting is called bank fraud. Bank fraud is punishable by at least 20 years in prison besides loss of license. No thanks. No one should do what he suggests. If his St Louis Project wants to give money, loans, houses to poor people, he can do that privately. Just don't expect the government, banks, public to pay to subsidize his personal project. No appraiser should lie about value to help a low income person over pay for a house. They end up with a bigger loan they can't afford to pay. No one would pay the higher appraisal value for the home. It's in the same less valuable location. An appraised value doesn't change the real market value. They'll be foreclosed upon and lose everything. You would be doing a disservice to these people. This happened right before the Great Recession. It also happened with student loans. They tell them they can make more money with a degree. Instead they only end up with tons of expensive debt and no new job or increase in pay. That is just plain cruel! They are hurting the people they claim they want to help. Fix the income gap and they can afford more expensive homes on their own.

In the past I've worked for nonprofits that help poor people buy homes. They never asked me to pump the value. They ask for market value. Sometimes they give 110% loans. They can do that as it's private money. Based on my experience giving people homes with no down payment is not the best way to help them. Help them make more money and buy their own home with a safe down payment and low mortgage payment.

It's a shame or a sham that the Appraisal Institute has jumped on the false narrative of the racist appraiser. They're doing it to protect themselves. They are mainly older, white, more affluent male appraisers. It costs $15,000 in fees, classes to become an MAI appraiser. What better way to deflect negative attention than to offer a webinar with mainly black speakers pointing the finger at others. If they really cared about diversity, they would make all their classes, educational material and literature free. Then all who take the classes could become MAI appraisers for free. They're a nonprofit but they won't do that because it's basically an old white affluent male elitist club that protects itself. They let a few women, minorities in, on the board for their image. They don't really care about promoting the industry or appraisers but themselves. They are actively attacking the industry and other appraisers with their positions in order to protect themselves.

Below are some comments on the YouTube video, see link above.

Carolyn Nuccio - 7PTC

"It's disgraceful that the Institute would be promoting using data that would result in misleading assignment results to resolve this finance issue, which at it's core is about "wealth creation"; and using appraisers to create that wealth. The FHFA should be focused on understanding market dynamics, and creating Federal Loan Guarantee programs that will lend above appraised value rather than trying to pressure appraisers into using data that will result in artificially inflated values. There's not enough data available about these statistics presented as to why the contract prices aren't appraising out. Jumping to the conclusion that appraisers are racially biased just because contract prices aren't being met is a huge jump. Perhaps the contracts need to be analyzed. Who are the sellers? Are they largely flipped properties owned by investors? Were the properties listed prior to contract? What's the List to Sale Price ratio in the market? This market derived data is all available on the URAR and should be included in the analysis. Perhaps some of the presenters could enhance their knowledge of how predatory lending works in disadvantaged neighborhoods. I would point to the Atlanta market back in 2004 - 2008 as an excellent example of how borrowers and homeowners were tricked into applying for, and qualifying for, over-valued homes and loans. Many of the appraisals did just as suggested in this presentation. The appraisers went outside of the competitive market for their comp selections in developing an opinion of value. As a result, when the borrower needed to sell their home, they were unable to sell it. Why? Because the original appraisal inflated the value and they couldn't find buyers to buy their home. The suggestions in this presentation are a sure fire way to create artificially inflated values; and a pretty good way for those involved in the transactions to be looking at jail time for mortgage fraud."

Pablo

"we have been taught location, location, location because that the the main and predominant factor when a buyer purchases the home. If there are two identical homes and one resides in an area that has more crime, lower rated school, you name it, they don't give a damn that it is the same house as they want. They won't consider it. There always needs to be lower income properties. What would happen to some of the economically struggling families that no longer can afford housing because of this ridiculous` method? This method would be discriminating against low income people because you are forcing the market up based on poor comp selection and MARKET MANIPULATION. If you did this with stocks, you would have the SEC knocking on your door."

Christopher Posey is a successful and experienced real estate appraiser in Chicago, Illinois. He watched the video and sent good questions to the moderator. His question was about appraiser liability related to this new value. Their reply is below along with his question. It's a closed real estate appraiser group so I can't share it publicly.

https://www.facebook.com/groups/appraiserforum/permalink/5779904935459009

Someone made a good comment stating these inflated appraisals would hurt poor people. If you artificially inflate the values then poor people can't afford to buy the homes. You aren't helping but hurting.

Below are some slides from the presentation.

DR RASHIDA JOHNSON-FORSEY

JILLIAN WHITE

DOUG POTTS

Mary Cummins

Thursday, January 19, 2023

Reply to NCRC "Faulty Foundations: Mystery-Shopper Testing In Home Appraisals," Mary Cummins

NCRC, national community reinvestment coalition, faulty foundations: mystery-shopper testing in home appraisals exposes racial bias undermining black wealth, comment by Mary Cummins, real estate appraiser, appraisal, los angeles, california, racial, bias,discrimination, black,white,brown,asian

UPDATE: WorkingRE just wrote an article about this research. It's more flawed than even I realized!

https://www.workingre.com/appraisal-bias-this-report-fails-scrutiny/

Two of the wildest appraisal values came from one appraiser...who is black.

If you removed the two wild appraisals by the black appraiser, values were HIGHER for blacks and not lower. Makes you wonder if the black appraiser was a plant.

The service issue mentioned turned out to be as I'd speculated. One appraiser was sick and didn't finish any appraisals for anyone while he was sick. It wasn't because the homeowner was black.

The total variance among reports was 1.7%. Less than 5% variance is acceptable.

NCRC filed complaints against the appraisers they used in their fake appraisal test. JFC!

NCRC states they're well respected with years of research. They're ever worse than the Fair Housing nonprofits who do the same fake research and file the same false complaints. People will do anything for money. Disgusting!

ORIGINAL: NCRC the non-profit organization National Community Reinvestment Coalition released a paper October 2022 titled "Faulty Foundations: Mystery-shopper testing in home appraisalsexposes racial bias undermining black wealth." Here is the link https://ncrc.org/wp-content/uploads/2022/10/Faulty-Foundations-Mystery-Shopper-Testing-In-Home-Appraisals-v5.pdf .

Racism exists. Racist appraisers exist. I don't know if racism affected the values in the reports in this paper because the research was flawed. Their methodology was flawed as are some of their conclusions. Even NCRC states there were flaws and better research is needed. I have some comments.

NCRC is a non-profit organization. Their stated purpose is to fight discrimination in housing, banking and employment. They do this by offering "research" and media articles about discrimination in order to get donations to their cause. I agree with their cause by not necessarily their means. They are like some of the fair housing groups and their frivolous lawsuits like the Oakland and Marin lawsuits and complaints. They use the media to attack individuals and incite the public to get donations and force settlements to stop attacks as businesses. They file lawsuits, complaints then release press releases about the lawsuits to get donations and put media pressure on their targets.

They start off the report by stating incorrect facts about Andre Perry's "paper." Brookings Institute Andre Perry's report was debunked. See below,

https://www.aei.org/wp-content/uploads/2021/03/Impact-of-Race-and-Socio-Economic-Status-on-the-Valuation-of-Homes-by-Neighborhood-3.18.21-final-revised-1.pdf

https://www.aei.org/research-products/report/aei-housing-center-response-to-perry-and-rothwell-2021/

So were the other papers cited in their intro. The conclusions were proven false by AEI and others. Their entire intro says "appraisers have been proven to be racist" before they get to their own research. Perry's paper didn't even involve appraisers. The report was biased from the first sentence. It's not an independent paper or true research. NCRC knows than Perry's paper and the others were proven false by AEI yet still told the lie. This makes it difficult to believe anything NCRC says.

The real cause of the difference in values of white and black owned homes is the income gap. Whites make more money than blacks, Latinos. Men make more money than women.The more money you make the more money you have. The more money you have the more expensive home you can buy. That's why white owned homes are worth more than black, Latino owned homes. Fix the income gap! Real estate appraisers aren't "stripping the wealth" of blacks and Latinos. Most of the data came from Automated Valuation Methods which don't involve real estate appraisers but robots.

The appraiser, appraisal sample was too small to be meaningful. It wasn't blind or double blind research. They should have had each appraiser appraise one of each type. Some appraisers could just be unpleasant. Maybe they treat everyone poorly white, black or brown. Some appraisers may always come in conservative or the opposite. They should have used white, black appraisers and not just white. Maybe the results would have been the same then it's not related to color of appraiser but another factor or factors.

It would have been better if the appraiser knew the race of owner, borrower but never met them. Maybe the contacts treated the people differently. They could appraise vacant with a lockbox or key under mat to control for that. Communicate with same worded email only. Even better have another group where they don't know color of owner, borrower. Compare that group to the group who did know.

The appraiser who ghosted the client probably got wind of something which is why they just left. I've had that experience when I thought the contact was insane or had unrealistic expectations or they treated me poorly. I've never done that because of race... Of course maybe the appraiser died, got sick, had a mental health issue, was arrested... They never found out why they disappeared so they can't assume it was racism.

"Most of the Baltimore homes used in the study were located in areas where the population is at least 75% Black." Should have been 50/50 or 75/25, 50/50 and 25/75.

"Another limitation of this study was that six of the seven tests involved couples consisting of a Black woman and a White man." Should have been a mix. Maybe the appraiser doesn't like women. You could control for that with a mix. I had male contractors come to my house and ask to speak to my husband when I owned the house and paid all the bills. They treated my husband nicer than me because it was a guy guy thing.

If we assume all appraisers are white racists that will give low appraisal values to blacks, Latinos, what is their suggestion? AVMs? AVMs are much more biased than real estate appraisers. They don't consider condition, upgrades, additions, view, lot type, lot location in neighborhood, neighboring properties, location next to dump/freeway/busy street... If you have a very run down house, you'll get a higher valuation than market value. If you have an improved home in good condition, you'll get a lower valuation than market value. There would be even more complaints!

Mary Cummins

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

Wednesday, February 1, 2023

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

Monday, January 30, 2023

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

Wednesday, January 25, 2023

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

Saturday, January 21, 2023

FHFA Uniform Appraisal Dataset Aggregate Statistics and How it Impacts You, by Mary Cummins Real Estate Appraier

Thursday, January 19, 2023

Reply to NCRC "Faulty Foundations: Mystery-Shopper Testing In Home Appraisals," Mary Cummins