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

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

Friday, June 18, 2021

False statement by President Joe Biden on home valuation and race - by Mary Cummins

Home Valuation is not related to race, President Joe Biden


I'm glad that on June 17, 2021 President Joe Biden made Juneteenth a Federal holiday. It's been a holiday in most states including California for years. Unfortunately during that presentation President Joe Biden made a totally false statement about home valuation and race when he stated the following (sic),

"...it belongs to an aggressive effort to combat racial discrimination in housing. Finally address the cruel fact home owned to this day by a black American family is usually appraised at a low rate for a similar home owned by a white family in a similar area."


Someone repeated a misleading statement related to the misleading Brookings report to Joe Biden. A paper was written by Andre Perry who is promoting and selling a book on the subject. The "report" misstates an alleged relationship between home valuation and race. The report only showed that all people of color including Latinos, Native Americans, Alaskans ... tend to buy and own less expensive homes in less expensive areas. The home values were determined by Zillow robots who didn't see the homeowners or the homes and the actual homeowners. Race and color were not a factor in the calculation of home values. 

The mathematical formula used to determine value is the most used asset valuation formula used worldwide for thousands of years. That formula compares one item to another similar item. It's also called matched pairs analysis. Homes of the same size, bed/bath count, condition, amenities were compared to other similar homes which recently sold in the SAME EXACT AREA. Homes in certain geographical areas are worth less than others in more desirable geographical areas with different characteristics. The mathematical calculation has absolutely nothing to do with race or color. In this instance they used Zillow listing prices per square foot. All appraisers know the "a" in "Zillow" stands for "accuracy." Zillow "zestimates" are not accurate at all. They also used ACS data which is the value the actual homeowner thinks their own home is worth. 

A home in South Los Angeles is worth less than a home of the same size, condition and features in Beverly Hills. The main difference is the value of the land and not the house. Here in California the land makes up over 70% of the total value. A vacant lot in South Los Angeles is worth less than a vacant lot of the same size in Beverly Hills. Everyone knows home value is based on three main factors, i.e. location, location, location.

There is a correlation between all people of color, new immigrants, people who don't speak English, people with less education... and level of income and net financial worth. ALL OF THESE PEOPLE tend to have less income and a resulting lower net worth. Because they have less income, less financial worth they tend to buy less expensive homes which they can afford in less expensive areas. Andre Perry committed the main fatal statistical sin confusing correlation with causation. That makes his "report" totally meaningless and useless. There are even more grave errors in his analysis which will be examined below. 

In Andre Perry's paper he used the separate inaccurate Zillow home valuation listing prices per square foot and self reported home values from the American Community Survey. The ACS is sent to a sample of 3.5 million people in the nation in the mail. A response to their written questionnaire is mandatory but most people throw it away assuming it's junk or scam mail. All of the information is self reported including when the home was built, number of bedrooms, rooms... Here's a sample form. Based on my experience most homeowners don't know all of this information off the top of their head. They generally don't know what their home is worth today. I would not trust the results of the ACS to be accurate about real estate values or home characteristics. Perry refers to the ACS results as the Census results. The ACS is not part of the Census. 

Perry compared those values to the racial makeup of the areas at large. Again, Zillow valuations are not accurate and listing prices don't equal home valuations. Perry used price only per square foot which is never used in appraising because it's not accurate. We weight homes based on similarities. Self reported home values are also very inaccurate. 

Perry stated an area was "primarily black" if 50% or more of the population identify as "black." He compared that to an area with less than 1% black residents. Perry actually stated zero black residents in the report. How many places have zero black people? I find it hard to believe they are any unless they are very tiny towns in the middle of nowhere. Perry clearly intentionally chose two very extreme comparison groups in order to create the most extreme statistics possible to fit his preconceived "results." That would be like comparing only very tall people to very short people to see if there's a difference in their lives. Of course there will be a difference. This is clearly an example of "garbage in, garbage out" GIGO statistics. Perry actually stated the areas that are "primarily black" are "more segregated." If you are looking at an area that is 50% plus black of course it's more segregated. 

How much of the US fell into only those two very specific small categories? Perry states that 10% of the US falls into the category of "primarily black." An analysis of only 10% of the country does not represent the entire country, see Perry's map below. Per the map this 10% appears to only be in the East and a little in the South. This is still only the percentage of the population living in the specific area and not the percentage of all black homeowners in that area or the entire country. Most homes in less wealthy areas which tend to have more people of color are actually owned by white investors or large public and private corporations. Perry then compared those values to areas with only 1% black people. Again, that would be a very small group for comparison. Of course it will show differences when you intentionally choose two very small and  extremely different groups for comparison. This is very misleading statistical analysis. It's as bad as any Fox News "statistics" or poll.


 

What about the white, red, yellow person who lives next door to the black person in an identical home in the "primarily black" area? What about the other <50% in the area who are not black? From Perry's report "Though most residents are Black (because he chose 51%+ black areas)(14.4 million non-Hispanic Blacks) by definition, approximately 5 million non-Black Americans live in majority Black neighborhoods." The 5 million non-Black person's home is worth exactly the same as the black person's if it's the same size and condition. The white person's home value is not "caused" by being black because they're not black. They're white or other. The home was not "devalued" or valued by black skin color of the homeowner.

If you actually read the 28 page report, Perry out of one side of his mouth admits "Majority
black neighborhoods do exhibit features associated with lower property values, including higher crime rates, longer commute times, and less access to high-scoring schools and well-rated restaurants." He then states that only explains half of the alleged devaluation of homes. Those are just the characteristics of poorer areas in general. I live in a high crime area with poor schools. It's 80% Latino. The homes are valued less here but it's not because of black homeowners. 

Perry goes on to say there is a "significant correlation between the devaluation of homes in black neighborhoods and upward mobility of black children in metropolitan areas with majority black neighborhoods." The real correlation is any and all children living in poorer areas will find upward mobility very difficult. It has to do with more than just the value of the homes in the area. It has to do with the people being poorer.

Here is another example of poor data used. Perry used the EPA walkability index to determine if an area had amenities such as access to shopping, jobs and schools. The EPA index only shows the "suitability for walking as a means of travel." 

Here is yet another example of Perry selectively using statistics. He states there is a correlation between a high number of violent crimes, black areas and reduced valuations. He also stated there is a correlation between high number of property crimes in high valuation non black areas. For that reason he only included violent crimes in his analysis of black areas. Then he didn't really include "crime" in his analysis. His "conclusion" is crime doesn't explain the devaluation of homes in primarily black areas. A high violent crime area does explain a lower home valuation area. That's why all the home sites include the crime statistics. I would not live in a high crime area if I could afford to live elsewhere. 

On top of the useless statistics Perry then used the results of his limited analysis to extrapolate devaluation to 113 other metropolitan areas if they had at least one majority black area. He took very bad math from a few small extreme areas to state that many other areas he did not analyze have his same preconceived results. Andre Perry's entire paper should be dismissed because of the intentionally misleading statistics used to fit Perry's personal agenda to sell his book.

One more ridiculous comparison. Someone with less money will buy a less expensive car which they can afford. People of color tend to have less money as do some others who are not of color. Kelly Blue Book uses a computer program to calculate the value of your car. You type in make, model, year, mileage, condition and it tells you what it's worth. They will tell you the value of a Rolls Royce or a Ford Escort. They don't know the color of the person typing in the information. Is Kelly Blue Book "intentionally devaluing" cars owned by black people when they tell the owner of a 1990 Ford Escort that their car is worth less than a 2020 Rolls Royce? No. Real estate robot appraisals are the same. Land in Beverly Hills is the Rolls Royce of land and worth more than land in South Los Angeles. It's perceivable that all homes in less desirable areas could be worth $48,000 less than homes in more desirable areas per Perry's report.

A last thing to consider is that people who own homes in less expensive areas paid less for the homes originally compared to homes in more expensive areas. They bought a home they could afford. When they go to sell that home they will sell it for the same price as a similar home in the area which is market value. If they bought a home in South LA, it will sell for less than a home in Beverly Hills. Did someone "devalue" or "steal" the difference in price between their home and a home in Beverly Hills? No homes were "devalued" by $48,000 by robot appraisals, appraisers or anyone. 

Andre Perry has done very poor biased research. The report is therefore meaningless. Perry is guilty of using misleading statistics and data to prove his preconceived bias that black homes are devalued compared to white homes only because they are owned by black people. Perry used small extremely biased sample sizes. He organized the data to omit any findings that contradict the result he tried to prove. He manipulated the results to influence perception through misleading graphs and visuals. He used faulty correlations and causations to create false statistics. He committed every single statistical sin in the book. The Brookings Institute should retract his report. 

At the June 20, 2019 House Finance Committee meeting Andre Perry spoke about the alleged devaluation of black owned homes. There were real estate appraisal industry experts at the meeting. I watched the meeting and took notes, see above link. When the speakers were asked by a Committee member if they thought appraisers discriminate against black people in arriving at their home's value Perry was the only person who raised his hand in a room of real estate valuation experts. Perry was the only non expert in the room. 

Perry clearly does not understand real estate valuation. He is trying to use his report full of bad statistics to state that racist appraisers intentionally devalue the homes of black people by $48,000. He stated that in the Committee meeting. He stated the purpose of the report was to give "Black homeowners and policymakers a target price for redress." Oddly enough in the meeting Congresswoman Rashida Tlaib stated that the government should just add $48,000 to the value of all black people's homes. One doesn't have to be a real estate appraiser to realize how ridiculous that would be. 

If Joe Biden or anyone wants to tackle the real issue of the correlation between people of color and income, net worth, they need to deal with those issues.The issue is most people with less income and money are people of color including many other colors and races other than black. Those issues have nothing to do with robot home appraisal analysis or home appraisers. They would need to make sure everyone makes the same amount of money regardless of any other factor. Until that happens all people with less money will buy and own less expensive homes in less expensive areas. People with no money won't buy or own any home at all. Most people in the US don't even own a home. Some don't even rent a house but maybe rent a tiny apartment or else they're homeless. Don't forget about those people.

The point of this article was to analyze the Brookings report and prove Joe Biden's statement incorrect. No one should ever rely on this misleading report. The media and others today have been stating that white real estate appraisers are intentionally appraising homes owned by black people lower than market value because all appraisers are white racists. No appraiser appraised any home in the report. The alleged valuations came from misleading computer analyzed Zillow listing prices per square foot and the ACS which uses self reported home values from the homeowner. Any low balling would therefore be caused by Zillow or the homeowner. These attacks on appraisers must stop. While racism certainly exists and there are racist appraisers not all appraisers are racists who devalue homes owned by black people. Most of us are hard working appraisers who always provide the best appraisal possible which complies with all the laws for everyone and anyone. 

___________________

References


Perry, Andre M. (2020). Know Your Price: Valuing Black Lives and Property in America’s Black
Cities. Washington, D.C.: Brookings Institution Press



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


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Wednesday, June 16, 2021

Alleged racial discrimination case in Oakland, California, real estate appraisal, Saleem Shaheed, Sunnyside - by Mary Cummins

Saleem Shaheed, 9821 sunnyside, oakland, california, racial, discrimination, real estate, real estate appraiser, appraiser, appraisal, fha, mary cummins, los angeles, alameda, loan, lender,
Saleem Shaheed, 9821 sunnyside, oakland, california, racial, discrimination, real estate, real estate appraiser, appraiser, appraisal, fha, mary cummins, los angeles, alameda, loan, lender,

Here is another alleged case of discrimination in a real estate appraisal in Oakland, California. Saleem Shaheed purchased a Cape Cod Colonial home at 9821 Sunnyside for $430,000 Nov 26, 2019. It was listed at $475,000 for over a year and a half. It appeared to be a fixer home based on pics. At the time he got a $417,000 first loan which is a 96% loan to value ratio. He put down $23,000. Nov 2020 the home was appraised for $575K. Jan 2021 while applying for an FHA loan which has much stricter requirements for the home the value was $480K. Shaheed then ordered a third appraisal April 2021 which came in at $630,000. These values are as per Shaheed. 

Shaheed claims the second appraiser didn't give credit for the second bath. He also claims that appraiser clicked the box that said "no updates in last 15 years." Shaheed said that was incorrect because he added a new roof. A new roof is a maintenance item. It's not an update. The home per photos had roof damage and needed a new roof, see photo below. An update, upgrade would be a fully remodeled new kitchen with new appliances and new bath of higher quality. It would include new electrical system and new plumbing. I would agree with the appraiser if the kitchen, bath were the same that I saw in the 2019 listing photos. The home does not have a legal second bath, see below. Shaheed complained, appraiser didn't change value and Shaheed filed a claim of discrimination against that appraiser's license. 

I'll first deal with the actual physical home in question. Address is 9821 Sunnyside St, Oakland, California 94603 in Alameda County parcel number 46-5463-8-2. On taxes and in public government documents it's listed as a 2 bedroom 1 bathroom home with 1,343 sf. Keep in mind Saleen Shaheed stated it's a 3 bed 1.5 bath home. An extra bedroom and bathroom makes a huge difference in value.

I got comments doubting the bed, bath count. Here is an ad for the house from 1967. It's a two bed, one bath home. "2 plus" means two legal bedrooms. 




The top image came from the MLS listing. It was listed at $475,000 from at least March 12, 2018 to November 26, 2019 with agent Jasmine on the MLS. It's listed as a 2 bed, 1 bath home with 1,343 sf. Then the agent made a video where she states it's 3 beds, 2 baths with 1,609 sf. Screen shot from the video below. The agent Jasmine Sunkara is a liar which is probably why she removed her website below. She listed the real bed, bath count and size on the MLS. Based on government records this home is legally 2 beds and 1 bath. That appears to be the main issue in this case. Saleem Shaheed bought a 2 bed, 1 bath home which he is now trying to pass off as a legal 3 bed, 1.5 bath home in order to get a higher valuation. The home is also across the street from an elementary school which negatively affects value compared to homes not next to an elementary school. 

Saleem Shaheed, 9821 sunnyside, oakland, california, racial, discrimination, real estate, real estate appraiser, appraiser, appraisal, fha, mary cummins, los angeles, alameda, loan, lender,

I looked at the pics of the bedrooms in the video. They are not all bedrooms. Below are the pics of the alleged bedrooms. Two top pics are of the same bedroom. 





A legal bedroom must have a real closet and not just an armoire or clothing rod on a wall if it's not a very old home which was built without one. A legal habitable room must be legal minimum height in order to be included in the total gross living area. While older homes with sloped walls on the sides is common the angled area where it slopes under six feet is not included in the gross living area. 

You'll notice the home is listed as 1.5 floors. It's not two stories. The second floor is not a full floor with full height wall to wall. Notice the dormer windows. Notice the angled, sloped walls in rooms. A legal room must have a heat source connected to the main part of the home and should have insulated walls and ceilings. Attics generally don't. Below is a pic of the side view of the home. You can see it's not a full two story home. The two bedrooms are on top on either side of the "2nd" floor. The main part of the first floor of the home is about 23' x 32' (762') based on Google measure minus average sized roof eaves. The 2nd fl could be about 581'. You can't add area of the stairs on the second floor. 2nd fl definitely not the same size as the first floor. The rear extended part of the home looks like an unpermitted enclosed porch maybe. The one car garage is on the other side of the home. 


I'm assuming the green room is also considered a bedroom. Notice the odd closet with a window in it. It almost looks like part of the second floor was an attic-like area that was converted. See the little low door that goes to a storage area. That area in there is probably angled. 

The last turquoise blue pic is not a bedroom. That is not a third bedroom. The walls are angled, roof is low and there is barely any walking floor space. I'm going off the video and listing. 

I saw only one pic of a bathroom in the video. It was just a close shot of a toilet and window so I'm assuming the bathroom is small. Just found a pic of the full bathroom. It's the main bathroom.



I don't know what the full or half bath looks like. As the extra bed is not legal I'm sure the extra half bath isn't legal either. The problem with non legal rooms built without permits and not to code is that Building and Safety could order them removed at any time if they are reported. If you are the bank you want to make sure the loan is covered by the value of the home. A legal 2 bed 1 bath home is worth less than a legal 3 bed 2 bath home even if they are the same size. A legal 2 bed 1 bath home is worth about the same as a 3 bed 2 bath home where the extra bed and bath are not legal. Anyone can report the owner today and he'll probably have to rip out the extra bed and bath. Please, don't report the guy. 

In every day appraising we see unpermitted additions especially in areas with more affordable homes. We generally note whether or not they were built to code and built in a workmanlike manner. We also mention if they pose a health and safety hazard and include photos. Some lenders allow the appraiser to count them as beds, baths and some do not. One thing to consider is if you were offered a legal 3 bed, 2 bath home and a legal 2 bed, 1 bath home with unpermitted extra bed and bath, which home would you choose for the same price? You'd choose the legal one because someone could report the unpermitted rooms and you'd have to remove them. Clearly the home with legal beds, baths is worth more. 

Just for a wide range of values below are the three main robot appraisal values. The values are based on a mathematical formula which is the same as what real estate appraisers use. We search homes +/- 15% legal gross living area within a half a mile from the subject sold within the last 3 months or max six months if there are no recent comparable homes sold. We then choose the most similar comparables based on size, bed/bath count, amenities, condition, view... 

Everyone knows garbage in, garbage out (GIGO) with computer software. Flawed, or nonsense (garbage) input data produces nonsense output. That's what we have here with our robot values. The first two went by the false MLS information stating it's 3 bed, 2 bath. The last one is based on the tax data and is 2 bed, 1 bath. The difference today between a 3 bed, 2 bath home and a 2 bed, 1 bath home is about $130,000. These values are as of June 15, 2021 which is later than any of the appraisals. There are eight months between the first and third appraisal. I'm sure the value increased significantly in the last eight months. 

Zestimate/Trulia $666K range $619K - $764K 3+2 1343 sf

Redfn $669K 3 + 1.5 1370 sf

Real AVM $533K range $469,216 - $597,184 shows as 2 bed + 1 1343

Back to the three appraisals, i.e. November 2020 $575K, January 2021 $480K FHA appraisal, April 2021 $630,000. Shaheed has a problem with the six month old $480K appraisal which was for an FHA loan. FHA loans are very restrictive on the type and condition of homes on which they will lend. They would count legal beds, baths. The FHA appraiser did not give credit to the second bath which could be proper based on condition, permits. There can be no health, safety issues or major code violations. A regular loan might allow an appraiser to consider unpermitted beds, baths. I obviously have not seen the home. I don't know the condition or if it's changed. Shaheed states he added a new roof and redid the kids' bedrooms. The roof is a maintenance issue. Redoing bedrooms doesn't add that much value to the home. The pics of the alleged bedrooms are pretty funky. 

There is one issue most homeowners don't understand. Most underwriters, lenders will not allow the final appraised value to be higher than the highest recent sales price of a similar home in the area. It's possible there were no recent higher sales of a similar 2 bed, 1 bath home when the 2nd appraisal came in at $480,000. There are few homes on the market so there aren't that many sales. Maybe most homes in the area are newer legal 3 bed, 2 bath homes. It's also very possible that there were some recent higher sales of 3 bed, 2 bath homes when the 1st and 3rd appraisals were done. I haven't seen the appraisals. 

Based on the legal bed, bath count the second appraisal would have been within the range of value for the home at that time for an FHA appraisal. Based on 3 beds, 2 baths the first and third appraisals would have been within the range of value for the home at the time of those appraisals. That would appear to be an 8% appreciation within eight months between appraisals one and three. That sounds about right for the market. Home values have been rising quickly in that area. Cheaper areas such as Oakland have seen a larger increase. People can't afford the nicer areas so they are moving to Oakland where homes are more affordable. That is quickly driving the price up sky high. Because I haven't seen the home I can't get more specific about the value of the home. I can say there are issues with the home that would cause a wider range of values, namely the legal bed, bath count and condition. 

A last issue is that most loans are declined due to credit worthiness of the borrower, their income, assets, debts and not the appraisal. It's up to the lender to approve the loan as a package comprised of the borrower and the collateral. The appraiser has no say in the loan approval. If the last appraisal was done April 2021, any loan should have closed by now. Shaheed stated he still doesn't have a loan. Shaheed said the value of the last appraisal was "good" so one can only surmise that the borrower is the issue. If he goes ahead with the loan now, he now may have to have the appraisal updated. 

*Disclaimer. I haven't seen any of the appraisals. I do review appraisals for banks. I am not appraising this home. I haven't seen this home in person. 

**All real estate appraisals completed on the 1004 form state the appraisal is only for the use of the client. The client is the AMC or lender. The appraisal cannot be used for any other purpose by other parties. The borrower is not the client or owner of the appraisal. The purpose of the appraisal is to make sure there is sufficient equity in the property to cover the loan balance and costs to foreclose the property by the lender. The borrower is entitled to look at the appraisal. The borrower cannot use the appraisal for their own use. 

Below is the video tour of the home. Agent removed one version of it within an hour of me posting the article. I saved a copy.
 

Below is the original article.


Original real estate agent's website which was removed.


Jasmine Sunkara 916.501.3393 #calbre#01855557 #NMLS#112033

Photo of roof before sale. It needed a new roof. 

Photo of living room. You can see water damage to the wall most likely from the roof damage.


Kitchen.




Government city, county, state property record for subject. 


I just checked permits. There was no permit to add a bedroom or bathroom. There were two permits the current owner pulled to add solar but it was never completed. There was no permit for a new roof. You need a permit to replace the roof. They need to make sure people use roofing material and application methods which are up to code and fire proof. 

08/12/2020
Permit Inactive
SE2000661
Solar Electric Panels
9821 SUNNYSIDE ST, Oakland CA 94603
Install roof-mounted 3.30 kW PV solar system with 10 modules.
08/12/2020
Permit Inactive
RE2001806
Residential Electrical - Alteration
9821 SUNNYSIDE ST, Oakland CA 94603
Install 13.5 kWh Energy Storage system, 225 amp Main service panel, load center, and backup gateway.

2019 the sewer and sidewalk were repaired. 

Mary Cummins of Animal Advocates is a wildlife rehabilitator licensed by the

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


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

Thursday, June 10, 2021

Race and Racism in Real Estate Appraisals - Mary Cummins, Real Estate Appraiser, Appraisal, Los Angeles, California

Mary Cummins, real estate appraiser, appraisal, Los Angeles, California, racism in real estate, race, racism, diversity, discrimination
Mary Cummins, real estate appraiser, appraisal, Los Angeles, California, racism in real estate, race, racism, diversity, discrimination

I just read an article about racism in the real estate appraisal industry. I'm not going to link to it because it's so misleading. The author who is not an appraiser or in the industry stated that because most real estate appraisers are white per one poll that means the real estate appraisal industry is "racist" against Black people. According to the same Appraisal Institute poll they cited most real estate appraisers are male, i.e. 77% vs. 21% female, when females make up 50.8% of the population. Does that mean all male real estate appraisers are misogynists who will appraise women's homes for less than men's homes? Obviously not. That's as ridiculous as the article I just read.

A very important thing to note is the disclaimer in the Appraisal Institute race chart, i.e. "U.S. appraiser population statistics were derived from the ASC National Registry as of Dec. 31, 2018. Additional demographic statistics were derived from Appraisal Institute studies conducted in 2016-2019 that were comprised of randomly selected AI and non-AI real estate valuation professionals. In Q1 2019, the Appraisal Institute invited 15,600 valuation professionals, resulting in 750 responses."

Appraisers in the ASC National Registry are only "State certified and licensed appraisers who are eligible to perform appraisals in federally related transactions." We're talking a small subset of all appraisers in the US. This is not all appraisers in the US. The results don't reflect the racial diversity of all appraisers in the US. It probably represents more successful, wealthier appraisers who are generally white men.

Appraisers in the Appraisal Institute are a even smaller subset of long time, wealthy, successful appraisers. The reason is because it costs a lot of money to become an AI appraiser. We're talking at least $15,000. It costs $370 just to join the group without even being an AI appraiser. These people are even more wealthy than ASC appraisers. They're more likely to be white men.

The appraisers they questioned for their poll on races of appraisers is clearly biased. They only asked wealthier appraisers. We do know that wealth correlates positively with the male sex and being "white." That means poorer people, women, Blacks, Latinos, new immigrants....were most likely excluded. Of course the results would show that most appraisers are white men. 

Let's get to the AI race numbers anyway. Per the Appraisal Institute based on answers to a question on "race," the responses were as follows for licensed real estate appraisers: 

Hispanic/Latino 4.3%
American Indian/Alaska Native .4
Asian 1.1
Black or African American 1.3
Caucasian or White 85.4
Multiracial .7
Prefer not to say 5.1
Other 1.7
Total 100%

Per the US most recent US Census, the responses were as follows. Keep in mind that this represents ALL people including babies, children, retired people, disabled, incarcerated, criminals convicted of finance crimes, people in comas... people who can't be appraisers. It does not represent all the people who could physically, legally, technically be real estate appraisers. Such a subset would more likely be white men based on wealth and income.

Hispanic/Latino, alone, percent 18.5%
American Indian/Alaska Native 1.3
Asian 5.9
Black or African American, alone, percent 13.4
Caucasian or White, alone, percent 76.3
Multiracial, percent 2.8
White alone, not Hispanic or Latino, 60.1
No prefer not to say category
No other category

Total = over 100% because of multiracial and multiple categories

We're not really comparing apples to apples here because of multiple categories including "prefer not to say" and the fact that it includes all people in the US. The population sample of appraisers was also highly skewed because of the limited appraisers they questioned. There still could be more white real estate appraisers than in the general population. In this instance someone tried to state that means appraisers are racist against Black people. Oddly enough people haven't said the same thing about real estate agents. I only see articles about appraisers. Let's look at those numbers and see how they compare. 

White  74.2%
Hispanic or Latino 12.3%
Asian 6.4%
Black or African American  5.0%
Unknown 1.8%
American Indian and Alaska Native 0.3%

Those numbers look pretty similar. They also look pretty similar to the population as a whole. There are more white people in the US than Latinos, Blacks, Asians. Does this automatically mean all white people are racists against Blacks? Of course not. The racial makeup of a population does not mean one race is racist against another specific race. There are also fewer Latinos, Asians, American Indians... They are not complaining today. 

Don't get me wrong. Racism definitely exists in the US. It's a huge problem. More Black people are murdered by police. More Black people are in jail. More Black people are falsely convicted of crimes. There definitely are appraisers who are racist just like in all other professions. My issue here is articles stating that because most appraisers are white similar to the US population as a whole means they definitely are racist toward Black people and intentionally low balling their appraisals. 

Based on experience the real reason people right now are yelling racism in real estate appraisals is because buyers are not getting their loans approved for purchases and are unable to make up the difference in cash. The same goes with refinances. Properties are not just selling over list. They are going under contract over the price of the highest sales in the area for similar homes. Appraisers can't appraise a home for higher than the highest similar closed sale. A similar home is +/- 15% size, within last three months, within a 1/2 mile radius, with same condition/upgrades, amenities (e.g. pool, 2 garages)... The appraiser must use the "most similar" comparables. We must bracket size and amenities. The lender made that requirement. Not the appraiser. We are just following orders and a mathematical formula. Buyers are being forced to make up any difference between the contract and the maximum loan allowed in cash.

Buyers, homeowners don't seem to understand the purpose of a real estate appraisal in the home buying process. If you want to pay 100% cash for a property, you don't need an appraisal. Pay whatever you like. If you want to make a down payment and have a loan, you need an appraisal to get the loan. The real estate appraiser works for the lender and not the seller, buyer or borrower. The lender is willing to loan a certain loan to value ratio (amount of loan / value of property) on property for a borrower with good credit, steady job, assets, cash, investments and a down payment. The purpose is to make sure that if the owner can't make the loan payment for whatever reason that the lender can foreclose and sell the property for enough money to cover the loan balance and all costs. 

The real estate agent is involved in the same transaction yet people aren't calling them racist. The racial makeup of real estate agents is about the same as appraisers. They are going after the appraiser even though it's the lender who is denying the loan. They could pay the difference in cash but they either can't or don't want to. They would call the lender racist but there is no one individual that represents the lender. It's easier to attack the appraiser who has a name and a face so that is what they're doing. 

If Black people want more Black appraisers to feel better represented, they need to become appraisers. If they are having a problem finding a mentor to get their hours, Black appraisers should form an organization to mentor and support Black trainees. Then Black people should only hire Black appraisers to support them financially. The problem finding a mentor has nothing to do with color. It has to do with the difficult trainee process. One article blamed the problem on white people which is totally false. ALL trainees have the same problem finding a mentor. I actually wanted to start a program to help new appraisers and mentor Latinos and Black people. When I found out how much time, money and hassles it would cost me, I changed my mind. Here's an article I wrote about the mentorship issues. 

FWIW I'm Latino and speak Spanish. I appraise properties in lower priced Black, Latino areas. I understand the issues as they relate to value. 

If your loan is denied because of an appraisal value, here's an article I wrote on how to appeal the appraisal. 

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


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

Difficulties becoming a real estate appraiser trainee in California by Mary Cummins, Real Estate Appraiser, Los Angeles, California


New real estate appraisers trying to get their 1,000 to 1,500 hours of experience are having major problems finding licensed real estate appraisers willing to train them. Some trainees have said it's probably because of racism, fear of losing business to trainees or appraisers are just assholes. It's none of those things. You could be Jesus Christ himself and still no appraiser would want to train you. I will explain the problem with the trainee program and why appraisers don't want trainees. Then I'll offer some solutions. 

It takes a lot of time, money and headaches to have a trainee when there is no benefit whatsoever to the appraiser. Nothing to gain and everything to lose. The trainee has to sign the report (in addition to the appraiser) and/or be a part of the entire appraisal process. The trainee also has to have access to the work file or actually possess the work  file (photos of interiors of homes, loan documents with SSN's, drivers license numbers, passports, birth dates, full names, addresses, banking information, list of all clients, all emails, all past appraisals of the appraiser...) This causes your E&O insurance to go up. It also opens you up to more legal liability. 

The appraisals will take a lot longer to complete with a trainee. This means the appraiser makes less money while they are training the person. 

The client doesn't want another person in their private home taking photos of their possessions, their security system or being around their family. Google "home inspector" and "Elmo doll." The certified appraiser passes many advanced background checks to have their licenses, be on appraisal panels and work for clients. The trainee doesn't have the same background checks. 

The appraiser has to have the trainee in the car and office training them. Most appraisers work out of their home. There goes the appraiser's privacy and schedule. Can't pick up the kids between comp photos with a trainee in the car.

The appraiser has to pay extra for appraisal software with a trainee because they have to sign the report. That could be at least $1,000 per year for software. The appraiser also has to pay more for MLS access and other online comparable sources. That could be $600 per year. Even car insurance goes up with a trainee in the car. It all adds up. 

The trainee can never do an inspection or sign an appraisal by themselves. No AMC or bank would ever allow that. The client paid top dollar and hired a licensed, certified experienced appraiser and not a trainee. The work assignments clearly state that only the appraiser in the order can do the appraisal. 

"As of January 1, 2015 Trainees and supervisors must now take a four-hour course on the responsibilities and requirements of each role. The course must be completed by trainees before receiving their Trainee (AT) credential and by supervisors prior to beginning supervision." The class costs $100.  

While I'm sure an appraiser would first train a trainee on a fake appraisal assignment the trainee must do their actual hours on real appraisals for real government backed loans. They can't get hours on practice or fake appraisals. The licensed appraiser must work with them side by side on the entire appraisal process and report. 

Some trainees falsely think they will eventually be doing free work for the appraiser. They think they'll do appraisals totally on their own eventually and the appraiser will make more money so they're an asset. That can never happen per the law or clients' orders. Appraisers don't get anything from trainees. They cost them money.

I have a couple of suggestions. The only trainees I've seen find a mentor are relatives of real estate appraisers or very good friends. Find a relative or very good friend who would be willing to help you out. If you just call up an appraiser from a Google search whom you don't know, don't expect a call back. If you were the appraiser, would you want a trainee after what you just read? No.

My other suggestion is to petition the government to allow trainees after so many hours to do the property inspection, take the comp pics and write up the reports by themselves. Obviously the licensed appraiser still has to review and sign it as the supervisory appraiser. That would help appraisers save time and maybe eventually make more money. Lenders would have to be forced to accept a government mandate if they are government backed loans. Nothing the government can do with other types of loans.

Find an organization or person willing to give money to an appraiser to train trainees. Some appraisers might be willing to train people if they were paid. Otherwise you're basically asking an appraiser to give you free education on their dime. Trade schools charge money as do universities with hands on work experience. 

If POC want more representation in the appraisal field, they should form appraisal organizations for POC and do that. Offer grants for education for new appraisers. Recruit members who will agree to train and mentor trainees. I actually wanted to do this for Latino and Black people. When I did my research and figured out the time, cost and headaches involved I changed my mind. If I were wealthy or semi-retired, I would start such an organization. I just don't have the time or money today. 

If you want to verify any of this information, take a look at some online real estate appraisser forums and Facebook groups. You'll see no one wants trainees and why. The only ones I see are relatives of appraisers. FWIW I am not looking for a trainee. 

Requirements for a real estate appraiser trainee to get their hours to become a licensed appraiser from brea.ca.gov. 

A trainee needs 1000 to 1500 hours over six to 12 months of actual appraisal experience. They must be real appraisals on real government backed loan transactions. They can't be practice appraisals. Each appraisal takes me about three hours with inspection though large, complex properties take more time. If traffic is bad, it could take a while to drive and photograph the comparable properties. 1500/3 is 500 appraisals if the trainee does all the work with the appraiser. That would be 37 40 hour weeks theoretically. It would most likely happen over a year or so.

"Earning Acceptable Experience as a Trainee Appraiser

General

To earn acceptable hours of experience, a Trainee Appraiser must work under the direct technical supervision of a Certified Residential or Certified General licensed appraiser in good standing who meets the Supervisory Appraiser criteria outlined previously in this handbook. The Supervisory Appraiser must be licensed at the appropriate level for the type of property being appraised. In addition, a Trainee Appraiser may work for more than one Supervisory Appraiser. For hours to be included on the Log of Appraisal Experience (REA 3004 sample log here), the Trainee Appraiser must either:

Sign the appraisal report as the appraiser; or
Be identified by name and Bureau license number with the extent of the real property appraisal assistance clearly and conspicuously described in the report.
In addition, work experience and the appraisal report must fully conform to both the requirements of USPAP and Title 10, Chapter 6.5, California Code of Regulations (commencing with Section 3500).

Trainee Appraiser's Duties

Trainees must:

Maintain custody of the work file, or make appropriate work file retention, access and retrieval arrangements with the party having custody of the work file in accordance with the Record Keeping Rule of USPAP. Since the Bureau will examine work samples when a Trainee wishes to upgrade his or her license, all appraisals included on the log must be available for review by the Bureau regardless of USPAP minimum retention requirements; and
Maintain an appraisal log. A separate Log of Appraisal Experience (REA 3004) must be maintained for each Supervisory Appraiser.

Supervisory Appraiser's Duties

The Supervisory Appraiser must do all of the following:

Personally inspect the property with the Trainee Appraiser until the Supervisory Appraiser determines the Trainee Appraiser is competent to make unsupervised inspections, in accordance with the Competency Rule of USPAP for the type of property being appraised.
Review the Trainee Appraiser's appraisal report.
Accept responsibility for the appraisal report by signing and certifying that the report is in compliance with USPAP.
Review and initial each page of the Trainee Appraiser's Log of Appraisal Experience (REA 3004) to verify that the work was completed under his/her supervision.
Sign the certification of the Log of Appraisal Experience (REA 3004) current as of the date the certification was signed.
Maintain records of the appraisals in accordance with USPAP.
Include the Trainee Appraiser's name and Bureau license number (if licensed) and identification of assistance in appraisal report."


Mary Cummins of Animal Advocates is a wildlife rehabilitator licensed by the

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


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

Tuesday, May 18, 2021

Redlining in home loan financing - Mary Cummins, Real Estate Appraiser, Los Angeles, California


Redlining - Definition: To refuse (a loan or insurance) to someone because they live in an area deemed to be a poor financial risk.
The National Housing Act of 1934 created the Federal Housing Administration FHA to help revive the US economy after the Great Depression. The purpose of the FHA was to provide affordable loans so people could buy homes. Private lenders would make the loans and the federal government would insure them for losses. The new loans would have lower down payments, smaller monthly payments and were more affordable.
President Roosevelt's New Deal created the Home Owners Loan Corporation to help process the home loans. "To facilitate private investment through the FHA, the HOLC, and the Federal Home Loan Board Bank (FHLBB), the federal government crafted a national set of standards for assessing mortgage risk. Through its 1935 City Survey Program, the HOLC gathered data about neighborhoods from approximately 239 cities and compiled the results into a rating system ranging from A to D. Communities with A ratings represented the best investments for homeowners and banks alike; B, neighborhoods that were still desirable, C, those in decline, and D, areas considered hazardous. "A" communities generally had access to better amenities such as better schools, parks, shopping, transportation and were therefore more desirable. "D" communities generally were located near less desirable features such as industrial properties and they had fewer and lower quality amenities." To visually capture these rankings, the HOLC then turned these ratings into color-coded maps, using green for A, blue for B, yellow for C, and red for D – the origin of the term “redlining.”

Many researchers have stated the HOLC maps were more a consequence of existing ordinary and discriminatory lending practices as opposed to being a cause for them. Still, the spatial isolation could make it a self-fulfilling prophecy over time. Many have stated the ratings were just a description of the current state of the real estate cycle for each neighborhood. A "D" area could be revitalized, redeveloped into a "B" area. If that area improved with the addition of more public transportation, parks, schools, shopping, it could become an "A" area. This is what has happened in downtown Los Angeles and other areas such as Boyle Heights which some refer to as gentrification. Others have shown how the HOLC grades were more a function of factors such as housing condition, residential density, and housing type, as opposed to solely ethnic and racial composition. Over time some of these ratings became more associated with race and immigration status than unbiased risk. Generally poorer people, people of color and immigrants lived in the C, D areas because it was less expensive. Over time the redlining caused less investment in C, D areas and more in A, B areas causing a greater divide between the areas.

It must be noted that the actual HOLC maps never stated "D is a black area" or "D is an immigrant area." There were worksheets prepared by individuals which were used to determine the risk of each specific area. Those worksheets included many factors and descriptions including the following from top to bottom (see worksheet for an area of Los Angeles below), population, class and occupation, nationalities, income, "negro" %, building type, size, age, condition, owner/tenant % occupancy, home price bracket, sales demand, predicted price trend, sales demand, new construction, rate of sale of new construction, overhang of HOLC properties, description and characteristic of area.

Today in real estate appraisal and analysis we use all of the above factors except race and nationality. It's a violation of the Fair Housing Act to consider or mention race or nationality because it would be discrimination. All of the other factors are good indicators of value and trends. Now the US Census does include race and whether or not someone is "foreign born." The census has nothing to do with real estate sales or loans. It's more a population study.

That said the areas ended up correlating with higher populations of POC, immigrants and poor people based on affordability. If one were to note today property in the four distinct phases or life cycles of real estate, one would probably find POC, immigrants and poor people in those same areas because hazardous, run down, less desirable areas have lower rent, have cheaper homes to buy.
The Fair Housing Act of 1968 made redlining illegal. It became "unlawful to discriminate in the terms, conditions, or privileges of sale of a dwelling because of race or national origin." A bank could no longer refuse to make loans in certain areas. Banks can only refuse loans based on the credit, credit history, income, assets, debts, expenses of the buyer, borrower.

I am using this example below because it specifically mentions race, nationalities. Not all of the worksheets noted it. It was up to the individual filling in the form. We don't know how much weight the race, nationality had on the rating. We do know that race, immigrant status, being poor correlated with the lower C and D ratings because they correlated with lower income, lower net financial worth, lower credit ratings which affects affordability. This is not to say one caused the other. This also doesn't say one didn't cause the other. This is just to aid in the explanation of what "redlining" was.



Mary Cummins of Animal Advocates is a wildlife rehabilitator licensed by the

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


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

Saturday, May 15, 2021

Se habla Español. We speak Spanish. Mary Cummins Real Estate Appraiser Appraisal Los Angeles California

Se habla Español. We speak Spanish. Mary Cummins Real Estate Appraiser Appraisal Los Angeles California Se habla Español. We speak Spanish. Mary Cummins Real Estate Appraiser Appraisal Los Angeles California
Se habla Español. We speak Spanish.
My grandmother Maria "Mary" Rivera Cummins was born in Mexico City, Mexico. She was a real estate broker and lender. She also bought and sold trust deeds in Los Angles, California. My "Nana" raised me and my sister. That is why I speak Spanish with my family and in my profession.
Mi abuela María Rivera Cummins nació en la Ciudad de México, México. Ella era agente inmobiliaria y prestamista. También compró y vendió escrituras de fideicomiso en Los Angles, California. Mi "Nana" nos crió a mí ya mi hermana. Por eso hablo español con mi familia y en mi profesión.
Below is a helpful English/Spanish GLOSSARY OF REAL ESTATE INDUSTRY TERMS - TÉRMINOS DE LA
INDUSTRIA INMOBILIARIA from National Association of Hispanic Real Estate Professionals (NAHREP) and REMAX.

Se habla Español. We speak Spanish. Mary Cummins Real Estate Appraiser Appraisal Los Angeles California Se habla Español. We speak Spanish. Mary Cummins Real Estate Appraiser Appraisal Los Angeles California



Mary Cummins of Animal Advocates is a wildlife rehabilitator licensed by the

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


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

Discrimination in Real Estate Appraisals - Fair Housing Act - Mary Cummins Real Estate Appraiser Appraisal Los Angeles California

Mary Cummins real estate appraiser appraisal Los Angeles California Fair Housing Act anti-discrimination Mary Cummins real estate appraiser appraisal Los Angeles California Fair Housing Act anti-discrimination

Title VIII of the Civil Rights Act of 1968 is commonly referred to as the Fair Housing Act of 1968. Since 1968 its protections have been expanded significantly by amendment. The Office of Fair Housing and Equal Opportunity within the U.S. Department of Housing and Urban Development is charged with administering and enforcing this law.
The Civil Rights Act of 1968 prohibited the following forms of housing discrimination:
Refusal to sell or rent a dwelling to any person because of their race, color, religion or national origin. Discrimination on the basis of sex was added in 1974, and people with disabilities and families with children were added to the list of protected classes in 1988.
Discrimination against a person in the terms, conditions or privilege of the sale or rental of a dwelling.
Advertising the sale or rental of a dwelling indicating preference of discrimination based on race, color, religion or national origin. This provision was also amended to include sex, disability, and having children.
Coercing, threatening, intimidating, or interfering with a person's enjoyment or exercise of housing rights based on discriminatory reasons or retaliating against a person or organization that aids or encourages the exercise or enjoyment of [fair housing] rights.
Neglecting maintenance and repairs of the units rented by people based on race, religion, sex, or any other discriminatory demographic.
Restricting access to services and amenities on the basis of the renter's race, gender, religion, or nationality.
In 2012, the United States Department of Housing and Urban Development's Office of Fair Housing and Equal Opportunity issued a regulation prohibiting LGBT discrimination in federally assisted housing programs. The Supreme Court ruled in 2020 that discrimination on the basis of "sex" includes discrimination on the basis of sexual orientation and gender identity. It was not until February 2021 that Housing and Urban Development issued a rule change under President Joe Biden to implement this decision. In addition, many states, cities and towns have passed laws prohibiting discrimination in housing based on sexual orientation and gender identity.
Types of allowed discrimination
Only certain kinds of discrimination are covered by fair housing laws. Landlords are not required by law to rent to any tenant who applies for a property. Landlords can select tenants based on objective business criteria, such as the applicant's ability to pay the rent and take care of the property. Landlords can lawfully discriminate against tenants with bad credit histories or low incomes, and (except in some areas) do not have to rent to tenants who will be receiving Section 8 vouchers. Landlords must be consistent in the screening, treat tenants who are inside and outside the protected classes in the same manner, and should document any legitimate business reason for not renting to a prospective tenant. As of 2010, no federal protection against discrimination based on sexual orientation or gender identity is provided, but protections exist in some localities.
The United States Department of Housing and Urban Development has stated that buyers and renters may discriminate and may request real estate agents representing them to limit home searches to parameters that are discriminatory. The primary purpose of the Fair Housing Act is to protect the buyer's (and renter's) right to seek a dwelling anywhere they choose. It protects the buyer's right to discriminate by prohibiting certain discriminatory acts by sellers, landlords, and real estate agents.

Mary Cummins real estate appraiser appraisal Los Angeles California Fair Housing Act anti-discrimination Mary Cummins real estate appraiser appraisal Los Angeles California Fair Housing Act anti-discrimination



Mary Cummins of Animal Advocates is a wildlife rehabilitator licensed by the

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


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