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.

Monday, February 20, 2023

Rebuttal to Marcia Fudge's Misleading 2022 CNN Interview by Mary Cummins Real Estate Appraiser

Marica Fudge, HUD, Laura Coates, CNN, interview,Mary Cummins real estate appraiser, bias, discrimination, racism,white, black, Latino, home value,

Marcia Fudge of the Housing and Urban Development Department (HUD) was on CNN August 22, 2022 with Laura Coates discussing alleged appraisal bias. "Housing and Urban Development Sec. Marcia Fudge says her department is examining the process in which home appraisers collect data, which she says is systemically biased against people of color." "HUD Secretary On Battle Against Racism In Real Estate."

Here is a link to the show: https://www.cnn.com/videos/business/2022/08/22/hud-sec-fudge-racism-in-home-appraisal-process-coates-intv-ctn-vpx.cnn

Here is a link to the transcript: https://transcripts.cnn.com/show/se/date/2022-08-22/segment/01

Marcia Fudge continues to promote the false narrative of the alleged "racist appraiser" "devaluing black owned homes." Marcia Fudge has the facts and independent research yet actively intentionally promotes the false narrative to promote her own agenda. Fudge's agenda is to get media attention for herself and more money for her department. Fudge and politicians have created this problem so they can state they alone can fix it. In fact based on what Fudge said in the interview the problem has already been fixed just by doing the same thing they've done for years.

The real issue is the income gap. White owned homes are valued more than black, Latino owned homes because of the income gap. Whites make more money than blacks, Latinos. The more money you make, the more money you have. The more money you have, the more expensive home you can buy and own. The more expensive home you have, the more generational wealth is created. If you want to fix the home value gap, fix the income gap. Fudge won't admit to that because then the problem is not in the jurisdiction of her department HUD and she won't get more money.

Below are some very misleading quotes by Marcia Fudge.

"Because what we know is that it used to be that these things happen only in redlined

communities. But now it is pervasive, it is happening everywhere. And we determined that part of the problem was how appraisers are trained, who was in the appraisal industry, and how they are governed. And so, what we did, in March, was to present a report that showed how deeply, this whole bias situation, is across this country. It is systemic, and it is intentional to some degree."

Marcia Fudge doesn't understand redlining. Here's an article I wrote about it. Those risk maps were made by her own government agency HUD FHA and no longer exist. Government made risk maps were a way to determine loan risk. They included many factors. We still use all of these factors except we don't use race or country of origin. If you took race and country of origin out of the old maps, they were 100% as effective in determining risk. Obviously race and nation of origin have nothing to do with loan risk. Correlation is not causation. Not all maps even included those factors.

"That's part of the problem, Laura, it's the data. So, they collect data, and the data is not what it should be. They then use the data, in a way that it should not be used. And so, they come up with these biased appraisals. But as well, when you look at an industry, that is more than 95 percent White, you find that people of color, are treated differently, because there is an inherent bias with a lot of them. And because they collect the data, the data is not good data."

Appraisers don't collect data. The data is home sale prices. It's just data. HUD collects this data. Zillow has and uses the same data. MLS, Title collect data. Appraisers use the public data according to the law and well established, accepted economic theory. HUD is one of the government agencies which told appraisers what data to use and how to use it. Appraisers are doing what HUD told us to do.

95% of all appraisers aren't white. I've gone over the misleading statistics in previous articles. Almost the same amount of appraisers are white as real estate agents. If most agents are white, does that mean they are also all racists? Most people in the US are white. Does that mean every white person is racist? Of course not.

"If those homes are appraised the way that they should be Laura, then we look at being able to pass down, significantly, more resources, and more wealth, to generations that follow." "And if we are

constantly being discriminated against - and that is really what this is. We can call it bias, if you want. But it is systemic racism, and it is built within most federal agencies, and those agencies that we oversee."

This is the result of the income gap and not appraisers. Here is AEI's response to the PAVE Task Force. Fudge knows this. She has the facts, data and research. If she truly believes this, she should be fired because she's incompetent. Fudge is just lying to the public.

"So, we're tackling it. We are now advising first-time homebuyers, on their rights, if they get low appraisals. We are doing it to people, who sell properties. We are going to train all of the appraisers through fair housing and lending laws. We're going to make sure that the data is collected properly. And we're going to make sure that the right people have the data."

Fudge's solution is to do what we've already been doing for years. Fudge created a "horrible" problem then instantly fixed it by doing nothing. All these things have already been done years before she was the head of HUD. This proves she knows the problem doesn't really exist. She hasn't made any real changes and now it's "fixed."

Marcia Fudge stated that her own home is worth less than white owned homes down the street because she is black. This is of course false. I did a valuation of her much older home on a busy highway. It's worth less than the homes up the street because they are new luxury homes off of the highway. If Fudge doesn't understand this, she doesn't understand the basics of home appraisal and should resign as head of HUD. She states this falsehood for effect every time she speaks.

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 40 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

Tuesday, February 14, 2023

Real Reasons Appraisers Come in Below Contract Price by AEI. It's not Racism, by Mary Cummins

AEI just released a report about appraisers coming in below contract price in areas with lower income buyers, lower priced homes and more blacks and Latinos. This is exactly what I've been talking about. Again, AEI proves it with science and facts. Just FYI AEI is considered a "conservative" source.

"Our critique points out some significant shortcomings of these studies. Notably, they focus on entire
neighborhoods, when they should study the actions of individual appraisers. They use the greater share
of under-valuations as evidence of racial bias, when they should consider explanations unrelated to bias
that might account for under-valuations, including for example the greater share of first-time
homebuyers, who tend to overbid, or the greater presence of seller concessions, which will reduce the
appraisal amount when they are properly accounted for. They also fail to note the size of these undervaluations. Using the Aggregate Statistics Data File and Dashboards, our analysis indicates they are relatively small, averaging about $1,100 to $1,900.5 These levels are too high if they are in fact due to racial bias. However, our analysis finds multiple other plausible explanations for under valuations of this magnitude such as the greater presence of first-time homebuyers or seller concessions. We also note
that under valuations of this magnitude of are unlikely to depress entire neighborhoods and, they may
in fact provide a disproportionate consumer benefit to minority homebuyers.

We conclude with a renewed call on Fannie Mae, Freddie Mac, and regulators such as the FHFA to mass screen individual appraisers for racial bias and inaccuracies. We have already laid the groundwork for this research with a published working methodology."

The most important issue which I've stated previously is they focus on appraisal value and contract price for purchases and no refinances. When doing an appraisal for purchase the appraiser NEVER sees, meets the borrower, buyer. We may see the seller or the seller's agent but never the borrower. The government study also doesn't know the race or color of the borrower, buyer AND appraiser. What if it's only black appraisers coming in low with black borrowers? A recent horrible unreliable "study" showed that the appraiser who came in the lowest for black people was themselves black.

More important observations from AEI's study. Contract price does not equal market value. First time home buyers which are more likely in these lower priced areas are more likely to over bid. They don't always know they can negotiate. These same areas tend to have homes in lower condition. The appraiser adds more comps to appraisals which are below contract price. I do this to fully back up my work so everyone can understand the value. An appraisal that comes in below the contract price would not endear you to the AMC or lender. Appraisers HATE coming in below contract price but we do it because it's the right legal fair thing to do. The appraisal is to secure the loan not help a buyer or seller.

Some good snippets though you should read the entire report.

Fist time buyers offer over market value. "Shui and Murthy (2019) conclude that first-time homebuyers using Fannie Mae or Freddie Mac financing overbid for a home by approximately $3,000, or about 1% of the contract price for the average home compared to repeat buyers. They also find that FTBs with higher LTVs tend to overpay by more compared those with lower LTVs. FHA borrowers, who are disproportionally concentrated in minority census tracts and largely FTBs, typically have higher LTVs and lower credit scores and may thus be more likely to overpay than other buyers."

There are more seller concessions in these first time buyers, buyers using gov funding and these areas. If a home sells for $100,000 and has a $3,000 seller concession, appraisers subtract $3,000 from $100,000 in the adjustments. The net price is $97,000 which is under contract price now by 3%. There are more concessions to help buyers buy the property and because of condition.

There are more buyers for lower priced homes. This causes buyers to over bid for homes based on supply and demand. We saw this during the recent Covid runup. Buyers bid and paid over list price. They had to make up the difference in loan amount with a larger down payment.

First time buyers aren't just competing against other buyers but also against their rent. Many only compare what they are paying in rent to what their mortgage will be. Quick story. Friend of mine was buying a cheap mobile home. She wanted to buy a cheap home because the mortgage is less than her rent. She was buying it to save monthly expenses. Appraisal came in $20,000 below contract price of $85,000. She asked me for help. I told her appraisal value looked correct. I told her to ask seller to reduce price. She said "but it's actually worth $85,000! It's almost the cheapest house on the market! I will lose the home to someone else! I have to buy this home because the monthly payments are cheaper than my cheap rent!" She didn't care about the price but the monthly payment being less than rent. She only wanted to find a way to get $20,000 more cash for the down payment. Thankfully seller reduced the price. The appraisal gap prevented her from over paying for her first home. Many first time buyers in less expensive areas feel the same way.

Buyers using government funding tend to overbid. They're buying the home with someone else's money because of lower down payment requirements.They just want the home at any price believing it will instantly go up in value and they will have thousands in equity to take eventually. The government told them this is the American dream.

The actual appraisal gap is small. There is almost no gap in Latino areas and 1% in black areas. The government made this huge stink about appraisal gap and there barely is one! "In our prior critique of Freddie Mac’s research note, we find that “there appears to be no gap [in home purchase appraisals] relative to White tracts for Latino tracts and a relatively small gap [in home purchase appraisals] of 1-2% for Black tracts.” They mean predominantly white, Latino or black census tracts. None are 100% white, black or brown. That means whites are having the same issues in those areas as blacks and Latinos. The gap is not a color issue because the same things happens to whites in the same area.

AEI again debunks Andre Perry's "paper." Perry stated appraisers devalue black owned property by $48,000 per home. That's much more than the difference in contract price and appraised value of 1%. AEI pointed out that homes owned by poor whites are also valued less than homes owned by wealthier whites. It's not because of skin color but income, wealth and location.

Appraisals coming in below contract price can help lower income Latino, black buyers. They can renegotiate with the seller. The government didn't say the buyers never closed on the properties and the deals died. They're prevented from overpaying and ending up upside down. AEI state that the government is part of the problem. They help and allow buyers to over pay for homes at the top of the market only to lose those homes later when the market tanks or they have a financial emergency. And you know who the government falsely blames for that? Appraisers!

This kind of reminds me of the destroyed apartment buildings in the Turkey earthquake. Their President bragged that he reduced earthquake requirements to allow the construction of 300,000+ homes for lower income people. That is one of the major causes of the high fatalities in the earthquake. The President basically killed people. FHA and the government like to brag that they helped low income people buy homes. Then they lose their homes because they over paid at the peak of the market and couldn't easily pay the mortgage. Also reminds me of our student loan problems. Latinos, blacks are the ones stuck with huge student loans while the government brags they helped them get an education. Most didn't even finish their education and get the degree or certificate. Most of the ones that did didn't even get the better paying promised job. Governments just want to brag that they "helped" people not caring that they actually destroyed them financially. If the government helped them find a way to earn more money, they could buy a home on their own and afford to stay in it.

AEI suggest mass screening of appraisers to check for racial bias. I support this. If any appraiser knew of a racist appraiser who came in low on a black, Latino owned home because of their racial bias, they would love to take that appraiser back behind the wood shed. All appraisers are being attacked, vilified, defamed based on this false narrative of the "racist old white male appraiser." While racism sure as hell exists, not all appraisers are racists who lowball Latinos and blacks. If there are appraisers doing this, other appraisers would be the first to hold them accountable and strip them of their license.

FTR Dan Wiley of Freddie Mac stated this about their appraisal gap research. "We have not reached any conclusion for cause of the gaps or correlation. Our research showed that further studies are warranted." Danny Wiley and Freddie Mac are doing further research into the possible causes of the appraisal gap. They are looking at all the new data and reviewing all appraisals involved in the appraisal gap research. Of course that hasn't stopped Marcia Fudge, HUD, media... from running with Freddie Mac and other's inconclusive data about appraisal gap from stating it's allegedly caused by racial discrimination by appraisers.

https://www.aei.org/research-products/report/exploring-alternative-explanations-for-appraisal-under-valuation/?utm_source=newsletter&utm_medium=email&utm_campaign=exploring_alternative_explanations_for_appraisal_under_valuation&utm_term=2023-02-14

Mary Cummins

Wednesday, February 8, 2023

Mary Cummins Comment to ASC Bias Committee February 8, 2023, Real Estate Appraiser

Mary Cummins, ASC, appraisal subcommittee, appraisal bias hearing, @asc.gov, real estate appraiser,real estate appraisal, los angeles, california, hud, marcia fudge, appraisal institute, aei, american enterprise institute, bias, discrimination, junia howell, paul austin, tenisha tate austin, craig steinley, Michael Fratantoni, Mortgage Bankers Association

02/26/2024 I never got a reply about my comment. It is not public anywhere except here. I doubt anyone read my comment letter. They definitely didn't respond to any issue. If you send in a comment, post it publicly on your own. Otherwise it just ends up in a black hole. They tell you to send comments just to make it appear they are listening to you. They are not listening to appraisers. They are only listening to what fits their agenda which is the promotion of the false narrative of the old male male racist appraiser. Research by AEI has shown there is no racism in appraisals, see below.

ORIGINAL: Below is the comment letter I sent to the Appraisal Subcommittee in regard to the January 24, 2023 Appraisal Bias Hearing. It was confirmed as received. "Appraisal Bias Hearing via appsubcomm.onmicrosoft.com 2:07 PM (1 hour ago) We are in receipt of your message. Thank you for contacting the Appraisal Subcommittee." While they probably won't read it, it's now part of the Federal record for ASC and HUD.

Mary Cummins

February 7, 2023

Appraisal Subcommittee

Appraisal Bias Hearing Comment Letter

AppraisalBiasHearing@asc.gov

I watched the January 24, 2023 ASC Appraisal Bias hearing. Comments were requested after the hearing. This letter is my comment.

I've been a real estate appraiser in Los Angeles, California for 40 years. I've been a licensed California Certified Residential Appraiser since licenses were first offered in 1993/1994. I'm a Latino woman who speaks English and Spanish. I appraise property in the diverse county of Los Angeles and state of California.

There is no denying that racism exists in our country. We must do all we can to stop racism, sexism, ageism and all the other isms. As an appraiser I support fair, unbiased appraisal practices and valuations. I support using the scientific method and facts in order to identify the real problem in order to solve it.

I witnessed a lot of misinformation and disinformation during the hearing. Marcia Fudge the head of HUD and some of the specifically chosen speakers made racist and other statements which are not supported by facts and evidence. While there is an income, wealth and home value gap among whites, blacks and Latinos it's not caused by real estate appraisers. It's caused by the income gap. That is the real problem which must be solved. Blaming appraisers for the income gap will never solve the real underlying problem.

Government research has shown that there is an income gap between whites, blacks and Latinos ( AEI Housing Center Response to Perry and Rothwell, 2021, https://www.aei.org/research-products/report/aei-housing-center-response-to-perry-and-rothwell-2021/ ). Whites make and have more money than blacks and Latinos. Men make more than women. Married couples make more than singles. The income gap is the cause of the wealth gap including the generational wealth gap. It's the cause of the difference in value among white and black, Latino owned homes.

Research has shown that people who make more money have more money and buy more expensive homes (see link above). People buy homes they can afford in areas they can afford. People who make more money also buy more expensive cars. The difference in value of the cars is also not caused by real estate appraisers.

If the race and color of the homeowners were the cause of the differences in home valuations, why do identical white owned homes in the same areas of black, Latino owned homes have the same value as black, Latino owned homes? The value has nothing to do with race or skin color but location. Everyone knows the three main indicators of value are LOCATION, LOCATION, LOCATION. A home in a small town in Ohio with few amenities is generally worth less than a home of the same size in prime Beverly Hills, California. The value is mainly in the dirt.

Fudge and some of the others spent their time attacking and blaming "old white male" real estate appraisers for the home value gap. Appraisers report market value based on the sound economic theory of matched pairs analysis. This same theory has been used since the beginning of time to value all assets. This is set by the concepts of the free market and willing and able buyers and sellers. Fudge's promotion of the false narrative of the "racist appraiser" will never solve the real problem which is the income gap.

I will now reply to the individual instances of misinformation by the speakers in order starting with Marcia Fudge.

I. Marcia Fudge, HUD

Marcia Fudge is one of the heads of the PAVE Task Force. American Enterprise Institute (AEI) provided research, data and information to the Task Force ( AEI Comments on PAVE, March 2022 https://www.aei.org/research-products/report/comments-on-the-pave-report/ ) which proved the real cause of the home value gap is the income gap. Fudge knows this yet instead irresponsibly promotes the false narrative of the "racist appraiser" as the cause of the home value gap. Fudge promotes Andre Perry's false, misleading and debunked "paper" instead of independent verifiable research and facts. Perry's paper was based on robot valuations and not appraisers.

While Fudge states she hates and fights racism Fudge's multiple comments against white people reflect her own racism. It appears that Fudge prefers to falsely state that the problem is (white) real estate appraisers because her department HUD oversees those issues. HUD has received extra funding for this issue even though the real cause of the problem is not within control of her department. Government funding should be provided to the Departments that can actually solve the income gap problem. This is why we must first determine and state the problem which is the income gap.

Fudge stated that property tax paying for police, fire and schools was unconstitutional. It's inconceivable that the head of a major US government department would make this statement which is a violation of her oath. When Fudge became the head of HUD she took an oath March 2021 stating "I will support and defend the Constitution of the United States (snip), that I will bear true faith and allegiance to the same; I will well and faithfully discharge the duties of the office on which I am about to enter. So help me God."

Fudge inferred that she wanted property tax assessment values to rise so people would pay more property tax so they could get more police, fire protection and money for local schools. She doesn't realize that most older retired disabled people can't afford to pay more taxes and keep their homes. They'd be forced to sell with higher taxes. Appraisers don't even make property value assessments. Those are made by Tax Assessors.

Fudge stated that black people remove personal photos, items to increase home value. That is false. All real estate agents tell all home owners of every color to remove personal articles such as photos, collectibles from their home. It shows the home bigger and better. Buyers don't want to see any other person reflected in the home. They want to envision themselves in a blank slate of a home. It's not about race.

Fudge stated she started the appraisal appeal process for racial bias. Appraisal appeal, Reconsideration of Value (ROV) have ALWAYS been available to borrowers of all types. They can appeal based on any reason. A difference in appraised value and contract price is not about bias. It happens more in black, Latino areas based on the home values and not the race. Research by AEI based on government loan documents proved there is no effect of race on home value ( AEI, How Common is Appraiser Racial Bias https://www.aei.org/how-common-is-appraiser-racial-bias/ ). AEI presented this to the government in the meeting about the PAVE task force yet Fudge keeps denying these facts.

Fudge brought up her home value previously. She said her older home is worth less (than a white person's home up the street) BECAUSE SHE IS BLACK. I included a valuation of her home and of the NEW, LUXURY homes up, across the street from her in a past article. It's a private development of new luxury homes tucked away off the main street. I have no idea if the home owners are all white. I doubt Fudge does either. 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 highway... Not all homes of the same size in the same county are worth the same. An old run down home in South Los Angeles is worth less than a new one of the same size in Beverly Hills. If Fudge doesn't know this basic appraisal theory, she should resign because she's clearly unqualified to run the Department of Housing and Urban Development.

II. Dr. Junia Howell

Howell prefaced her research by basically stating without any proof that appraisers are racist and appraise homes in black, Latino areas for less than areas with more white owned homes. Howell promotes the false narrative of the racist appraiser. Howell states she did research on property values in white, black and Latino areas in Texas. Howell supports this with a chart showing the difference in home values of predominantly white vs black, Latino owned homes. We're back to the income gap. Blacks, Latinos make less money than whites. For this reason they buy less expensive homes in less expensive areas. I can only assume they promote this falsity for their personal agenda of wanting more funding to pay them for more research.

Howell doesn't understand basic real estate cycles, i.e. Growth, Stability, Decline, Revitalization. Howell stated areas which were redlined but are now mainly white owned increased in value. Areas which were not redlined but are now mainly black, Latino have decreased in value. Howell states this proves it's based on race when it actually proves it's based on real estate cycles and income. When values go up in an area, people with more money buy and own those homes. When values go down, blacks, Latinos are more likely to buy and own the homes because they make less money. When people get pushed out of more expensive areas, they buy homes in lower priced surrounding areas. Those lower priced areas are generally more black, Latino. Some call this "gentrification" but it's just a real estate cycle called "revitalization." It's all because of the income, wealth gap.

Howell misstates "redlining" as a "map based on race of inhabitants." There were many, many factors involved in the original Federal Housing Administration (FHA) lending policies. They were based on income on inhabitants, age of buildings, condition of buildings, beds/baths, location... to determine loan risks. We still use all of those factors today EXCEPT race. It's racist and against the law to use race, religions or any other similar factor.

Howell stated that whites in the US government used these risk maps to intentionally value white owned property higher than black, POC owned property. Howell is so uneducated in this matter that she doesn't even realize that back in the 1930's most areas which were mainly inhabited by POC were actually owned by whites. The risk maps prevented white property owners from receiving lower cost Federal guaranteed loans. Howell stated "White, affluent areas were appraised as most valuable." The key here is "affluent areas." It's the income wealth gap. Correlation does not equal causation.

There are poor white areas in the US. How does Howell explain the difference in property values between wealthy and less wealthy white owned properties? She doesn't. It's not the color of their skin but the income gap. Howell made many more false and uneducated statements before stating that more research should be done. Howell wants more money to do more uneducated flawed research to promote the false narrative of the "racist appraiser."

III. Paul Austin and Tenisha Tate-Austin

I have covered this case in great detail because I'm an appraiser in California where the Tate's home is located. While the Austins may feel the difference in two home appraisals was due to racial discrimination the facts show it was not. Based on my research and experience the first appraiser used the best local comparables in Marin City and came in at market value. The second higher appraisal used dissimilar comparables in a very different more affluent area in Mill Valley much farther away from the subject. That is why it came in over market value. Marin City was built on swamp land as a Federal low income poor quality housing project built by the lowest bidder. The Tate's home was built cheaply using telephone poles on very steep previously unbuildable land. Mill Valley is an upscale community with high quality larger homes and some of the best schools and amenities in the state.

The Tates stated in their testimony and lawsuit that Marin City is basically populated by African Americans while Mill Valley is white. The Tates wanted the appraiser to only use high valued comps from Mill Valley and not lower valued comps from Marin City right next to their home. That would violate Federal appraising regulations besides being bank fraud.

The Tates believe their whitewashing of their home increased the second appraisal value. It didn't. What increased the value was another appraiser with lower ethics who was most likely pressured by maybe the AMC, Lender to come in higher. The second appraiser is the reason why the first appraiser was falsely sued for coming in "low." The second appraiser should be sued for bank fraud, appraisal violations and lose their license.

IV. Michael Fratantoni, Mortgage Bankers Association

Frantantoni basically promoted the MBA. Frantantoni suggested Automated Valuation Methods (AVMs) could reduce bias in appraisals. AVMs don't reduce but increase bias. AVMs are robots that don't actually see or inspect the home. They base their value on recently sold allegedly similar homes based on home/lot size, bed/bath count and age. They don't know if the home actually exists, its condition, upgrades, view, lot type, specific location in a neighborhood, actual size, true bed/bath count, permitted/unpermitted additions... AVMs value average homes in poor condition over market value and improved homes with views under market value. Marcia Fudge stated she also supports AVMs. Zillow's AVM actually produced the false and misleading data used in Andre Perry's "paper."

V. Craig Steinley, President, the Appraisal Institute, AI

The AI is a non-government non-profit organization. It costs about $15,000 to become an MAI AI designated appraiser. For this reason AI mainly represents wealthy older white male appraisers. It does not represent the average appraiser or most appraisers in the US.

AI wants to maintain its working relationship with the government. For that reason they support many though not all falsehoods stated by Fudge, HUD and other some government agencies. In their letter they promote their own actions as supporting the government.

That said AI makes some important points about AVMs and the Sales Comparison Approach.

AVMs are not reliable. "One thing to be noted is that a good portion of the research that has been conducted on valuation bias has evaluated automated valuation model data – not appraisal data, including the contrasting research from the Brookings Institution and the American Enterprise Institute. We cannot overlook the Zillow CEO’s statement in the 4th quarter of 2021 concerning the “difficulty of accurately estimating market value” as a concern for AVM reliability."

Sales Comparison Approach is reliable. Some have called for the "elimination of the sales comparison approach in appraisal. The BRSPT suggests those recommendations be ignored, and we will go on record as being outright opposed to such efforts. The sales comparison approach is grounded in economic theory, and it is universally accepted throughout the world." Some in government have suggested getting rid of the sales comparison approach which would destroy our economy. No bank would give a loan and no investor would buy a loan that is not based on an appraisal using the sales comparison approach.

In conclusion the cause of the difference in home valuations between whites and blacks, Latinos is the direct result of the income gap. The government needs to recognize and state the real problem so it can be solved. Blaming real estate appraisers will never solve the income gap or the home value gap. Blaming appraisers for the income gap is as ridiculous as blaming appraisers for gun violence and gas prices.

Please, rely on qualified independent scientific research and facts. Promoting the false narrative and attacking appraisers instead of trying to solve the real issue hurts everyone. Throwing money at HUD won't fix the income gap. Please, fix the income gap and all its causes so we all may experience the American Dream of owning a valuable home.

Mary Cummins

California Certified Residential Appraiser

License # AR010207

Los Angeles, California

http://www.MaryCummins.com

https://www.facebook.com/CumminsRealEstateServices

Mary Cummins

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

Los Angeles' Changing Areas, Downtown Salvage in LA's Arts District by Mary Cummins

downtown salvage, mary cummins, arts district, 7th st, anderson, los angeles, california, el salvador, industrial, warehouse, real estate, 2251 e 7th st, leonard rubin, construction salvage

Los Angeles has really changed especially the industrial area in downtown Los Angeles' Arts District. Industrial, manufacturing buildings have been converted into residential lofts and "creative spaces." The old 6th Street bridge was demolished and the new Ribbon of Light bridge replaced it. A new park is being finished under the bridge. There are fancy cafes and restaurants and million dollar loft conversions nearby.

As an example of the many changes in the area is the story of an old salvage yard. My family used to own Downtown Salvage at 2251 E 7th Street in Los Angeles, California. It was where the 5, 10, 101 freeways met. It encompassed almost the entire block of lots including all the ones facing 7th Street and half of the ones facing Anderson near the new 6th St bridge, see plat map below. We later owned the Mexican restaurant pool hall on the corner I believe or maybe we were thinking of buying it. We took over the alley and the railroad tracks that ran through the property by prescription and adverse possession. We owned it during the '80's then sold it to File Savers which stored paper records for businesses. It's since changed hands a few times.

downtown salvage, mary cummins, arts district, 7th st, anderson, los angeles, california, el salvador, industrial, warehouse, real estate, 2251 e 7th st, leonard rubin, construction salvage

The salvage business was run by Leonard "Lenny" S. Rubin and my family. Lenny used to own three separate salvage yard lots with various names, i.e. SALVAGE MASTERS INCORPORATED, L & S LAND CLEARING, INC, DOWNTOWN SALVAGE INC and EASTSIDE SALVAGE, INC. I think he was being evicted from one lot and wanted to combine the lots into one location which is how my family was involved.

My grandmother Mary R Cummins aka Maria Rivera Cummins bought and owned the property. Lenny moved his yards to the site paying rent. At the time there was a two story newer office building on the corner of 7th and Anderson, a Mexican restaurant pool hall on the corner of 7th and Rio, vacant lots in between them and huge warehouses behind them for half of a long warehouse block.

Back in the 1980's we'd get the demolition permits to tear down homes and buildings in Los Angeles especially Beverly Hills. We tore down Bela Lugosi's house and kept the hand painted Mexican beam ceiling for our own home. We also kept this antique hand painted Mexican fold out bar. We tore down Ships restaurant and all the apartment buildings at 10877 Wilshire Blvd in Westwood. We found a mint condition Packard car on the lot which we were going to auction off after proper legal notice but the workmen came and stripped it clean one night. We tore down a famous Ribs restaurant RJ's The Rib Joint at 252 N Beverly Drive in Beverly Hills. We ended up keeping the gaudy huge long wood and brass bar with mirrored slats in our house.

The salvage yard had stacks of used solid wood doors, wrought iron railings, old bathtubs, old toilets, old sinks, lots of used bricks, copper tubing, marble slabs, ornate fireplace mantles... We saved absolutely everything from every demolition job. It was recycling at its best. There were lots of antique door fixtures, wood windows, built-in cabinets, chandeliers, marble tiles... some really beautiful items. Everything was organized by section, lined up in easy to find rows and categorized on an overhead hanging map because the place was so huge. People also left personal items which we sold after proper notice.

Most of the workers on the site were young men from El Salvador. My grandmother, myself and Lenny all spoke English and Spanish. The kids aged 18 plus used to show me photos of them in their military uniforms from El Salvador holding machine guns during mandatory military service. Most couldn't speak or read English but they did read Mexican comic books. Some of them lived out of need in the top floor of the office building or another area of the site.

The workers would get their paychecks on Friday and we'd cash them for them. Then they'd get dressed up in their fancy cowboy boots, big belt buckles, hats, nice shirts and go have a few drinks or more at the local bars including the Mexican restaurant pool hall on the corner. For some reason there were multiple gun shootouts at the office building on the lot. I'm not really sure the cause but some was gang activity and some were late night drunken fights. I just remember the police complaints and bullet holes in the building.

We were open from 7:00 am to 6:00 pm. Then we had issues with people living on the lot selling items off the lot before and after work hours. We changed the work hours to 6:00 am to 8:00 pm. There were also guard dogs and locked gates that had car or truck access.

One time we had a huge electrical bill and tried to figure out the cause. We finally figured out that one of the El Salvadorian security guys would leave the lights on all night in the warehouses because he got scared doing his rounds. He told me he thought he saw the vision of the Virgin Mary a few times and thought it was an omen that something bad would happen to him. We replaced him with someone else who was not so superstitious though it was a common theme among some workers. Most of the workers were very Catholic and very superstitious.

For some reason there were a lot of immigrant Latino men who would dress in wild drag and offer themselves on the sidewalks next to the Mexican restaurant late at night. They were regular looking El Salvadoran men wearing very short skirts, tube tops and high heels. They didn't try to look like women so no one was fooled. I continued to see those men there at night until at least 2000.

We sold the property in the late 1980's to File Savers and moved the salvage business to another location. They since sold the property and groups of lots separately. We never legally combined all the lots into one parcel because of the alley, railroad tracks and the time and expense involved. It also made sense to keep them separate for value. They were worth more individually than combined.

Today there are a few different businesses there. The office building was torn down. There's a "State of the Art Cannabis Dispensary & Grow Facility" on the front portion facing 7th Street at 2235 7th St. The corner restaurant pool hall is now a "Creative Building" at 2231 7th St. The long row of industrial buildings facing Anderson at 679-691 S Anderson is now Quasar Science which sells lighting. They rebuilt the building over the old railroad tracks which we took by prescriptive easement.

I'm glad to see the changes in this area. It used to be very rough when I'd go to the lot in the '80's. I lived in downtown Los Angeles for a while around 2008 and used to go to the Toy Factory lofts and the Edwardian-goth pub Royal Clayton's which is now the Little Bear at 1855 Industrial. That was about it at the time. Now there are a lot of nice little restaurants in the area, much less crime and it's a lot cleaner. There's even a pricey market in the area. I'm pretty sure the male street walkers near the old restaurant pool hall are gone as well.

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Mary Cummins

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

Monday, February 20, 2023

Rebuttal to Marcia Fudge's Misleading 2022 CNN Interview by Mary Cummins Real Estate Appraiser

Tuesday, February 14, 2023

Real Reasons Appraisers Come in Below Contract Price by AEI. It's not Racism, by Mary Cummins

Wednesday, February 8, 2023

Mary Cummins Comment to ASC Bias Committee February 8, 2023, Real Estate Appraiser

Wednesday, February 1, 2023

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

Los Angeles' Changing Areas, Downtown Salvage in LA's Arts District by Mary Cummins