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

Tuesday, November 9, 2021

ASC Roundtable Event: Building a More Equitable Appraisal System - 2021 by Mary Cummins

"On November 9, 2021, the Appraisal Subcommittee (ASC) will convene its second ASC 2021 Roundtable: Building a More Equitable Appraisal System, to build upon the success of the first roundtable and address historical and contemporary factors that have contributed to the inequities challenging the appraisal system today. Please join us for the second event of this groundbreaking series, which will bring together leaders in government, finance, real estate, non-profits, and communities impacted by the appraisal system."


November 09, 2021
10:30 AM - 01:00 PM

Main Session (Keynotes)

Please join us in the main session to hear keynote presentations and remarks from our featured speakers!


Danny Wiley
Senior Director of Single-Family Valuation, Freddie Mac

Vivian Li
Quantitative Analytics Director, Freddie Mac

Erika Poethig
Special Assistant to the President for Housing and Urban Policy

Melody Taylor
Executive Director, Task Force on Property Appraisal and Valuation Equity

Congresswoman Maxine Waters
Chairwoman of the House Financial Services Committee

Jim Park ASC

11:30 AM - 12:30 PM

Sessions Area PAVE Listening Session


Melody Taylor
Executive Director, Task Force on Property Appraisal and Valuation Equity

11:30 AM - 12:30 PM

Sessions Area Freddie Mac Report


Vivian Li
Quantitative Analytics Director, Freddie Mac

Danny Wiley
Senior Director of Single-Family Valuation, Freddie Mac


Jevin Hodge a politician running for office
Michael Akin a professional webinar organizer at Link Strategic Partners

My comments are in parenthesis "(  )." All of the speakers read their opening remarks. There was a lot of happy positive speak and pats on the back for other members of the task force and government. A few said that they aren't saying appraisers are racist or appraise in a racist manner. A few others said "it's been shown that appraisers are racist and appraise in a racist, biased manner against black people. There have been media articles." 

FreddieMac speakers went over the recent research on appraisal gap. Other speakers talked about the goals of the PAVE Task Force. There were quite a few appraisers attending asking good questions. Some of those questions were about some of the crazy ideas floated around about using comps from a different location, neighborhood than the subject. There were many comments about Practical Applications of Real Estate Appraisal PAREA and making it easier for trainees to become full appraisers. 

At the previous ASC Roundtable Event black Cy Richardson stated to white host Michael Akin "Pale, male and stale. That's what appraisers are." The general consensus is that "pale, male and stale" is racism, sexism and ageism. Akin replied that he wasn't "stale." It appears he didn't want to be name called again so he had black Arizona politician named Jevin Hodge who is running for office on an equality platform be the second host today. 

Jevin Hodge introduced the speakers to the main session in a very positive upbeat manner. 

Speaker: Jim Park of ASC: I'm a certified general appraiser. I've been with ASC since 2009. Bias is not due to racist appraisers. The definition of "implicit bias" per ADL (Anti Defamation League ) is assumptions, stereotypes we make towards others, positive or negative, that is stored in our unconscious (subconscious). 

We need to change the recruitment training model. We don't want to alienate people (appraisers) to solve this problem.  We must be careful not to blame dedicated professionals who perform this work day to day. 

Speaker: Danny Wiley of FreddieMac. I've been an appraiser for 40 years. We (at FreddieMac) looked at 12 million reports from 2015 to 2020 (during a time of appreciating values when there is more likely to be an appraisal gap) to see how often the appraisal value came in below the contract. We call this the appraisal gap. We compared appraisals of homes in census tracts with mainly white occupants against those with mainly blacks and Latinos. We have not reached any conclusion for cause of the gaps or correlation. Our research showed that further studies are warranted. (They only used purchases and not refinances. The borrowers for purchases are the buyers. Appraisers NEVER see or meet the buyers. It's impossible for us to be biased against the buyers. In fact their research showed there was no difference in the gaps if they only looked at race of the borrower. Gaps happen in quickly appreciating markets such as mainly minority areas which are revitalizing or as others say gentrifying. Appraisal values are based on sold comps which means the value could be two months behind the market from contract date to escrow closing to recording time.).

Speaker: Vivian Li also of FreddieMac: (It was difficult to understand her accent. Wiley and Li basically just talked about this research here) Media articles have shown appraiser, appraisal bias against blacks. (So much for not blaming appraisers) There were appraisal gaps from many appraisers (47%). We worked with BetterMortgage (a private for profit mortgage broker with a pro racism agenda and Jillian White. They worked with Andre Perry who released the early results of their study July 15, 2021. They also worked with Urban League. All of these people, groups publicly state and support the false narrative that appraisers are racist) to better understand them. 

Speaker Erika Poethig: The Federal Government had a role in discrimination. The government reinforced housing segregation with redlining and discrimination against people of color. Blacks, Latinos rely more heavily on their home for their wealth. The great recession caused POC to lose their homes. The black home ownership rate is the same as it was in 1968. 

The first goal of the current government is to stop foreclosures caused by the pandemic. The second goal is to expand access to credit more broadly. There will be more credit options for 2-4 units. We hope to root out discrimination in housing. 

Speaker Melody Taylor with HUD: Joe Biden started PAVE task force to deal with racial inequity. PAVE has four core objectives... (she read this list
We will also focus on the ROV Reconsideration of Value and lack of diversity in the appraisal profession. Your voice matters. Thanks.

Congress person Maxine Waters: When black families leave portraits of their black family members up in their house they get a lower appraisal. They have to put up photos of white people to get a higher value and the appraisal jumps. These are not just anecdotes. The appraisal gap is real. People of color have been locked out of low rates and being able to buy homes due to appraisal bias. There is unequal values of homes in black areas. Discussions haven't solved the problems. 2019 had the lowest black home ownership rate ever. 76% of whites own a home. That's over 27% more than black or latino homeowners. The Build Back Better Act will increase the supply of housing. We must help more POC become homeowners. The big boy appraiser companies run the  show. Smaller appraisal businesses are locked out. We must break up the big boys. Thank you. (I like Maxine Waters. I'm near her district. Someone has filled her head with nonsense and false, misinterpreted information on this issue. She needs some education by someone who knows the issues. Who are the big boy appraisers?)

Breakout Sessions. I went to FreddieMac first then PAVE.

FreddieMac with Dan Wiley, Vivian Li.

Wiley: We only used purchases for our research because there is a "true north." 99% of the time the contract price will reflect the true value. (Assumption) We didn't use refinances for this reason.

We didn't consider any contracts with concession 3% or more. We got rid of other outliers such as a home having five stories, ten bedrooms...

Li: We excluded distress sales and non arms-length sales.

Wiley read my question which was "To Lee, Wyley: Did you compare the appraisal gap and price of the homes? Based on my experience I've seen more gaps in lower priced properties which correlates w/ Black, Latino area."

Li: Great question. We looked at it. We broke it into five brackets. We saw similar patterns overall. (but similar amounts, %? It would have been good for them to post that information even if it showed no effect. I appraise in these areas and others because I speak Spanish. I see more of a gap in these areas. It could be because these areas are being revitalized or as some say gentrified. Homes are appreciating quickly which always causes a gap like the common current appraisal gap. Others pushed out of more expensive areas into more minority areas also tend to over pay as do first time buyers desperate for homes in these areas. They looked at sales 2015-2020 which is during a time of faster appreciation when there is more likely to be a gap. They're also only looking at FreddieMac loans and not all loans. FreddieMac only buys conforming loans under a certain amount so this doesn't effect all loans.)

Wiley: We only considered appraisal reports. We didn't consider everything like whether the area had potable water or not.

Li: Potable water may affect valuation. We didn't look into it. I can look into it further. 
Wiley: We didn't check to see if the appraisals were accurate or not. (That would have been the better test). We just compared it to contract price. We know if the appraisal comes in low the contract gets renegotiated so we only looked at the appraisal and first contract not later contracts.

Joseph Mier: I've been an appraiser for 30 years. We all know location, location, location when it comes to value. I'm concerned the discussions could harm consumers and the profession if don't use local comps. If appraisers are using local comps, that is the proper data.

Wiley: You haven't heard that from us. We need to know what we can actually sell the property for. We're in the collateral business. We look at risk.
Mier: We must be careful to not leave data behind. There is a risk if you're not using certain comps. 

Wiley: Agreed. It gets dangerously close to crossing the line to advocacy. We are supposed to measure bias in the market. Bias is just preference. Buyers prefer some areas over others by being willing to pay more. The job of the appraiser is to be an objective observer of market bias and not driving it. We're not exploring that. 

Question: Why not use a comp in a white area to appraise a home in a black area instead of using a comp in the same black area?

Wiley: We are only concerned with what we can sell the property for today. We should use the most similar comp sales in the subject neighborhood.  There is no reason to go to another area. We are concerned with two things, the objective measurement of current value. The other is the long term effect of discriminatory policies from the past and how to rectify that. We support that. We don't believe the answer to that problem is to tweak the appraisal in some way. We need to affect long term change. We don't think the appraiser is the engineer of that process. 

Question: Why did you only look at, report about white, black and latino groups?

Li: Most data is for black, latinx groups. The gaps for these two groups stand out the most. (How would she know unless she looked at the other groups?) 

I moved to the PAVE breakout session

John Brenan of Clear Capital: PIREA, we support it. It must be approved by all states. We need diversity among appraisers. That is what we're trying to do, recruit more diverse appraisers.

Joseph Mier: Trainees can't do site inspections. Using trainees will bring more professionals into the profession. We should use local comps because value is based on location, location, location. We shouldn't use comps from outside of the area. 

Melody: If you want to send a comment, information, email

David Bunton: Appraisers must now take two hours on bias in the seven hour USPAP update. It would be good to know how many bias complaints there are and what are the results of investigations. (I sent in a FOIA request for the results of the two most well known recent complaints. I'll post them when I get them.)

Melody: We were given 180 days to formulate and write a response with an action plan for the PAVE task force. (Task force announced June 1, 2021. First meeting was August 5, 2021. December 1, 2021 the reply is due?)

Summary end of meeting.

Jim Park: This is not about how to get rid of appraisers but how to make appraisals more reliable, credit worthy and to diversify the profession. The bureau of labor statistics showed that appraisers are last (when it comes to diversity with 96% white).(The statistics are based on someone calling someone's house, asking one person about the professions of all the different people in the house and their different races. They're calling land lines. Not very reliable stats. Per AI 76% of appraisers are white. That's very close to the same percentage as real estate agents which is 75% and the general population overall which is 72%). We will do a third roundtable by ASC but not this year. It'll be first quarter next year. 

The video should be posted here. I still haven't found the video from the last meeting. I even emailed twice asking where it was and no reply.


Some screen grabs from the session.

Some questions asked in the chat.

Fontana Pete

Congresswomen Watters mentioned getting rid of the "big boys" in the appraisal process! Can you elaborate on who she is referring to as the big boys? AMC's, banks, GSE's? Thanks kindly

Kennedy Chester

Question 3: What areas of regulation and policy could be improved to have an impact on eliminating bias in property valuations?

Kennedy Chester

Question 2: What role can private sector and the appraisal regulatory system play in advancing equity and diversity in the appraiser workforce?

Kennedy Chester

Question 1: How do lenders, regulatory agencies, GSE, HUD and VA policy affect the frequency and outcomes of ROV cases, and how might these regs and policies be improved? 

Sergio Johnson

In regards to the range option. Who would make the decision on the point of value being used for the lending decision in the range? (You probably still need a point of value to determine LTV etc)

Tanya Bates

Building relationships = A better understanding of the appraisal profession and in turn relevant ROV. Falls in line with what Bill is discussing.

Sergio Johnson

Bill, the problem there would be that in the lending world, many UW's report to folks who are part of the originations side. You'd have to revise the laws for that piece of it.

Lori Noble

With millions spent toward PARREA and alternatives while small businesses dedicated to mentorship are paying the price. The anti-competitive practices are prevalent and obvious in our regulations.

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


  1. Mary, here is a link to the first ASC Roundtable

  2. ASC YouTube Channel