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.

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Friday, November 1, 2024

Assessor Jeff Prang Speaks at Appraisal Institute Women's Initiative Committee November 1, 2024 by Mary Cummins Real Estate Appraiser

jeff prang, los angeles county, assessor, property, real estate, mary cummins, california, appraisal institute, boe, board equalization, brea, real estate appraiser, appraisal

Speaker: Los Angeles County Assessor Jeff Prang

Date: November 1, 2024 via ZOOM

Great presentation by Jeff Prang the head of the Los Angeles County Assessor's Office. The slides below show his presentation. There were some good questions after his presentation.

Questions (These aren't complete.)

1. How are property tax assessment appeals processed?

He explained the process which is outlined in the assessor website. He said their backlog was 40,000 cases when he took over the department. It's down to 20,000. One issue is there are appeal agent who contact new home buyers and state they paid too much for the property. They offer to appeal the tax basis to reduce property taxes for a % of the reduction. These appraisers, attorneys file 50% of the cases a year or about 5,000 cases. They don't proceed with most cases filed. There is now a $47 application fee to reduce these frivolous appeals.

2. What is the cause of appraiser attrition in your office?

Retirement, Covid and high cost of living in Los Angeles.

3. Are the assessor appraisers licensed by BREA?

No, they are approved by BOE, Board of Equalization.

4. How do you know the current size of properties?

Building and Safety sends over the permits for additions.

5. What do you need to be an assessor appraiser?

Four year college degree but it can be waived if you pass the test.

6. How did Prop 19 affect your office?

We were not given instructions, tools or a program to follow. We had to create the program on our own from scratch. We are processing the requests which cover many counties.

7. Why aren't guest houses, pool houses in the assessor records?

They are but they're not public or online. You have to go to the office to see them. You can look at the pictometry view in the assessor site to see the outline of buildings. We have records for patios, balconies, guest houses, pool houses.

My comment: In my experience they generally only show the first building on a property. Generally second units are added later and they're not in the records. I do see them sometimes by MLS sources that include size of all buildings on the site but not always. Maybe that was in the past when they sold the data. Maybe some services saved the data they bought. This is so important especially for 2-4 units or SFR with ADU. Many have assumed the buildings weren't permitted or legal for this reason. This means AVMs are extremely inaccurate for these properties with one building in front and say extra units, ADU, guest house in rear. You may only see 1/3 or 1/4 of the true size.

"The Southern California Chapter of the Appraisal Institute is proud to announce the launch of its Women's Initiative Committee (WIN).

The purpose and objective of this newly formed committee is to promote the advancement of women within the appraisal profession. In monthly Zoom meetings, we will host discussions of relevant topics, invite special guest speakers, network, and assess the unique challenges and opportunities we face. All are welcome to attend. Appraisal Institute membership is not required, and the Zoom meetings are free of charge."

Ariana Arredondo, MAI

Linda Whittlesey, SRA

Jennifer Hsu, MAI

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

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

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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, October 29, 2024

FHFA Allows Alternative Valuations with Higher LTV Ratios by Mary Cummins Real Estate Appraiser Los Angeles California

mary cummins, real estate appraiser, los angeles, california, real estate appraisal, fhfa, ltv, avm, appraisal, real estate,low income, poc, great recession, foreclosure

The Federal Housing Finance Agency FHFA has expanded the eligibility for alternative appraisal methods on purchase loans by increasing the allowable maximum loan-to-value (LTV) requirements. The maximum LTV ratios will increase from 80% to 90% for appraisal waivers and from 80% to 97% for inspection-based appraisal waivers.

“To be clear, the expanded eligibility of appraisal waivers does not constitute an expansion of a credit box, but rather it will allow more first-time home buyers, and particularly low- and moderate-income first-time homebuyers, to recognize the benefits associated with appraisal waivers,” Naa Awaa Tagoe, deputy director of the division of housing mission and goals at the FHFA, said on stage."

More purchase loans will not utilize a regular inspection appraisal by a licensed real estate appraiser. They will be using non-licensed non-appraiser property inspectors and AVMs Automated Valuation Methods similar to Zillow. This means lenders can use their AVMs, in house approval departments to get higher values so they can approve more loans so they can make more money. These loans will be riskier to new buyers, investors and the government. The housing industry players have been directly lobbying the government to do this for years now under the guise of helping lower income "save money" and fighting nonexistent "appraiser bias."

Never forget the Great Recession. Real estate prices were booming and fewer lower to mid-income, first time buyers could afford to buy a home. The people complained it was discrimination against lower income and POC. There is a correlation between lower income and POC. The correlation is based on socioeconomic factors and not race. There are also plenty of lower income non POC.

The government stepped in to "help" by lowering credit and loan requirements. More lower income first time buyers were then able to buy a home at the peak of the market for almost no money down. They had very little to no savings and were spending most of their income on home expenses. They were set up for failure by the government while lenders made lots of money. Lenders support relaxing requirements so more will qualify so they can make more money. Lenders lobby the government to reduce requirements while saying they just want to help poor people. This actually helps wealthy people at the expense of poor people just like payday loans.

The real estate bubble of course burst and those people ended up underwater. Low teaser rate loans adjusted, some had financial emergencies and they couldn't pay their sky high mortgage, insurance, property taxes and property maintenance. It was cheaper to rent than own. The real estate market collapsed and people lost their homes in foreclosure. They lost more than just the cost of the home due to associated costs and fees. The psychological effect on the families was devastating. Oddly enough the people and government blamed appraisers even though it was the fault of the government and the bubble bust real estate market driven by buyer demand. Appraisers just report the market. We don't set it.

Today we're in a similar though slightly different situation. We're in another real estate upswing caused by previous lower interest rates and severely restricted supply due to rate lock. Everyone wants to buy a home that will appreciate 50% like they have in the last few years. They are again complaining to the government that it's discrimination against lower income and POC because they can't afford to buy a home today.

People are blaming the government for the wealth gap which they say is mainly caused by the home ownership gap. The wealth gap is mainly caused by the income gap. Owning a home alone is not the cause of the wealth gap. You need to be able to first afford to buy and own a home by having higher income, more savings and good credit. Higher income, savings, good credit must come first otherwise you just saddle yourself with debt and higher monthly costs you can't afford. You'll lose your home if you have one financial emergency.

Government did the same thing with student loans. "If you get a college degree, you'll make more money. Here are loans so you can afford to go to college." You'll also end up with $100,000 high interest debt which make it impossible to pay bills, have children, start a business or save to own a home. The correlation between having a degree and higher income is related to first being able to afford to pay for and go to college. It's not the degree itself as many people have realized. Same with owning a home.

The government again responds by lowering loan requirements. Now you can put almost nothing down and get stuck with hefty mortgage payments, rising insurance costs, high property maintenance costs and rising property taxes at the top of the market. Property taxes, insurance increase as property value increases. Insurance costs are through the roof today due to natural disasters exacerbated by climate change. The appraisal waivers and use of value acceptance, AVMs make the loans even riskier for buyers and investors. It's even riskier today as we are at the peak of the market. Two to five years ago and it would have made a little sense. The government always reduces regulations at the peak of the market because of lack of affordability and politics.

AVMs will over value lower priced properties which are generally in inferior condition, inferior locations, smaller than average, have deferred maintenance, include buyer concessions for repairs/costs... These are the properties lower income people are buying because they can afford them because they cost less. The government is again setting these people up for failure. They always do this at the peak of the market.

I was screaming from the rooftops about this issue before the Great Recession. I'm now screaming from the mountain tops. Nothing will change. The government is hurting the people they claim they want to help.The election year campaign promises to get votes is making it worse. You know they will again blame real estate appraisers for a downswing even though we didn't appraise the properties that are most likely to be foreclosed. It's déjà vu all over again.

https://www.fhfa.gov/news/news-release/fhfa-announces-updates-to-enterprise-policies-on-appraisals-loan-repurchase-alternatives-and-pricing-notifications

November 1 Jeremy Bagott just wrote a good piece on this.

https://mailchi.mp/257006d81c5f/days-from-election-agencies-make-good-on-final-sop-to-housing-lobby-10896727

https://www.housingwire.com/articles/fhfa-to-allow-alternative-appraisal-methods-on-purchases-up-to-97-ltv/

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Mary Cummins

Wednesday, October 2, 2024

Chicago Urban League, Chicago Association of Realtors, Preparing for An Appraisal, Comments by Mary Cummins, Real Estate Appraiser

I attended Chicago Urban League, Chicago Association of Realtors Zoom webinar today on Preparing for an Appraisal. Good questions and answers. Below is the summary. My notes, comments below that. I'll post link to video if, when they release it.

"Preparing for An Appraisal.On October 2nd from 7:00-9:00 PM, join the Chicago Urban League's House and Wealth Committee for part one of a three-part virtual series. During the event, you will gain valuable insights into the appraisal process and learn how to advocate for fair valuations.

Learn from top experts in the real estate field on how to prepare for an appraisal and advocate for your property’s value. Whether you’re a Realtor, Realist, or a homeowner, this virtual event is packed with valuable insights.

Moderated by the Chicago Association of Realtors President Elect and Chair of the Chicago Urban League’s Housing and Wealth Committee, Lutalo McGee, our esteemed panelists include,

President Sanina Jones of the Dearborn Realtist Board (DRB),

President Erika Villegas of the Chicago Association of Realtors (CAR) and

Tiffany Jimenez of the National Association of Hispanic Real Estate Professionals (NAHREP) Chicago

Tom Schurer of Real Valuation Services

This 3 part series represents a joint effort of the CUL, CAR, DRB, NAHREP, NHS, RAINBOW PUSH AND NAACP- South Side to empower real estate professionals and consumers about the appraisal process and how best to advocate for home buyers and sellers to ensure they receive a fair valuation based on industry best practices."

Mary Cummins notes and comments on the meeting.

Question: Can I advocate for my value, for what I think it's worth?

Answer: Panelists said yes. Some said you can offer comps, contract. Appraiser said "Nobody knows a home better than the homeowner. It's a matter of pride."

Question: Why do consumers think they can't talk to the appraiser?

The panelists said you can and should talk to the appraiser about your value and what you think it's worth.

I sent in this comment: "Borrower can give comps, contract, list of improvements ....but can't try to influence the value. "1090.5. (a) No person with an interest in a real estate transaction involving an appraisal shall improperly influence or attempt to improperly influence, through coercion, extortion, or bribery, the development, reporting, result, or review of a real estate appraisal sought in connection with a mortgage loan."

My comment: It's a crime and you will be denied your loan if the appraiser feels you tried to influence their value. Don't say "I need $xxx,000 to get the loan," "the house is easily worth $xxx,000." Feel free to give list of similar homes of the same size, condition which have recently sold in the same area. Don't state a dollar value for fear appraiser may think you are trying to influence.

Question: Can I ask appraiser if they know the area, are competent?

Answer: Yes, but be nice and polite.

Question: Should I communicate with the appraiser in writing or on the phone?

Answer: Put things in writing so it will be included in the work file. Send it to them before the inspection. (My comment. Be polite and factual. Don't try to influence the dollar value).

Roberto Interiano, Lender, then read my comment and others agreed.

Question: Can I order my own appraisal if it doesn't have to do with a loan?

Yes, if you just want to know the value. The bank has to order their own appraiser for their appraisal for a loan.

Question: What should I have ready for the appraisal?

If you are selling, make sure your house is in show ready condition. Have any documents ready for inspection such as the survey, list of improvements.

Question: Should I remove photos from my home?

Answer: Erika Villegas: Yes, remove religious and political items. Remove personal photos because the listing photos could end up on the internet. Remove photos of people because there have been media articles which show some didn't get the "proper value" because of photos of some people.

My comment: All real estate agents tell all sellers to remove personal items, clutter and make sure home is clean and presentable. This is especially important for listing photos, showings. There are a lot of media articles out there about people white/black washing their homes to remove any trace that the owner may be black, Latino... Some articles say the value went up because of, after white/black washing. That is probably not the cause of the value change. It's a false narrative caused by the media, politicians and others.

Lutalo McGee: What about removing personal photos?

Sanina Ellisa Jones: An appraisal is subjective. It's problematic and why appraisals come in lower in our (POC) economy, community. It's because of racism, redlining, discrimination from early 1900's. The maps said risk is equal to blacks. African Americans were marked red, hazardous. It's no longer legal but still subjectivity exists from that practice. Take down religious, political items. I shouldn't have to remove my face because the value could be lower. Homes are devalued based on who lives there. We shouldn't have to do it but we should do it for the value. Values shouldn't be based on photos.

My comment: Appraisers value the home and not the occupants. Home appraisal is a math formula. AVMs use the same formula but appraisers have all the data needed to ascertain value. We generally don't even know race, color of owner, borrower or of the comp homes that sold, are listed. It's a false narrative. That said I agree that you should remove personal items, photos, religious, political items for the listing photos, showings. Buyers want to imagine themselves in the home and not you. They want a blank slate. Homes look bigger without clutter. There are many articles about this online. Appraisers blur all photos that include people, religious items, political items, things such as gun collections, "personal" items... Even if you don't remove your photos, items, we will blur them.

Her definition of redlining is also incorrect. 70% property in HOLC map area D or red were owned by white people. While blacks, Latinos ... lived there whites owned most of the property. Whites were the main ones who had to pay higher interest rates to get the loans. Race wasn't included in all maps. Race was one of many, many factors included in the maps. We use all those same factors today except race. The factors i.e. property age, condition, value, predicted depreciation, income of residents, location near hazardous sites, freeways...are still used today. If you removed race from those maps, they were still just as accurate for risk. Race had NOTHING TO DO with the value or risk. 1935 HOLC program brought lots of money to those areas. Before this there were no loans or they were small and super expensive. Most areas in D zones are now totally refurbished and many are affluent areas. The HOLC program money actually helped. There is a lot of research which proves this but everyone likes to repeat the false stories. I remember when I first heard about redlining around 1983. I also believed that false shit until I did some research and educated myself. Here's an article I wrote about redlining citing the research.
https://mary--cummins.blogspot.com/2021/05/redlining-in-home-loan-financing-mary.html

Lutalo: Should people put an appraisal pkg together?

Sanina: The listing agent advocates for the home value. Have a CMA, floor plan, survey, size, neighborhood details, upgrades, remodel, energy features to show appraiser how listing agent determined the list price.

My comment: The listing agent should already have a property package. Appraisers are open to receiving data. A list of similar sold, listed comparables is good. List of improvements, floor plan if available, survey, energy features... A list of maintenance items is fine but appraisers assume properties are maintained. Maintaining your property doesn't give you extra value.

Appraiser Tom Schurer: Tell the appraiser if there are multiple offers. Let the appraiser know what's happening in the community, developments.

Lutalo McGee: What about new rehabs in area where there aren't any new rehabs sold.

Schurer: You make time adjustments on closed sales, use pending sales.

Lutalo: What do appraisers look at when determining value? What should homeowners do to their homes to prepare?

Schurer: Paint it. It gives a good clean feel. Kitchen, baths drive home values, school district, neighborhood. Nice curb appeal.

My comment: If your home desperately needs a paint job, do it. Just don't expect 100% return on investment. Appraisers look mainly at location, size, bed/bath count, kitchen/bath condition in that order. Don't add a new kitchen/bath for an appraisal. You won't get 100% return on investment in terms of value. It's good to do it anyway if most homes have renovated kitchens, baths and you can enjoy it while you live there.

Question: What if appraiser asks for Tidewater?

Answer: Schurer: It means the appraiser needs help. They can't get value needed. They ask agent for help. Reconsideration Of Value ROV process. The new program looks good. Should be done by end of October and we can talk about it.

My comment: Tidewater: If the VA appraiser believes that the actual home value will be lower than the listing price, they will invoke tidewater. This is simply a heads up that gives the listing agent 48 hours to support the listing price. The agent will then provide similar sold comparables which support the list or contract price. I've found most of the time someone enlists Tidewater, contract/list price was over market value.

Question: How do we navigate AI.

Answer: Schurer: AI will change our world and real estate. RE is a people business. We laughed at early AVM like Zillow. It's real good these days. My future will be reconciling data sets, not giving opinion of value. I will just say why a dataset is wrong for the value of a home (how would he know if he didn't appraise it?) We will still need our smart human brains. Play along. Don't be afraid.

My comment: AI, AVMs are only as good as the data they have. GIGO, Garbage In Garbage Out. AVMs only work with newer, median size, median priced homes in average to good C3 condition. They don't work on older custom homes in fair/vastly improved condition with no view/views on irregular lots... We will still need appraisers for those types of homes.

CEO Urban League Karen Freeman Wilson: We need to know historical context, how the past affects the present. We need to know how to eliminate barriers to home ownership.

My comment: Totally agree.

The next webinar in the series will be with appraiser Chris Posey. Posey will teach us how to read an appraisal report and spot red flags. My coment: Chris Posey is very experienced and knowledgeable. He'll be giving great advice.

Saturday, September 28, 2024

Racist Los Angeles Planning Report - "Historical Housing and Land Use Study" written by Architectural Resources Group, comments by Mary Cummins Real Estate Appraiser

mary cummins, real estate appraiser, real estate appraisal, los angeles, california, planning, zoning, architectural resources group, katie horak, elysha paluszek, morgan quirk, racist, racism, historical housing land use study

I just started reading the land use report "City of Los Angeles Historical Housing and Land Use Study" written by Architectural Resources Group, Inc., Katie E. Horak, Elysha Paluszek and Morgan Quirk which was paid for by the Los Angeles City Planning. This "report" is not only racist but it makes clear the authors don't understand real estate and basic economics. Yes, racism exists. Yes, the world, US and LA have a racist past and still deal with racism today. That doesn't mean income and wealth disparities today in LA are caused by and can be fixed by the current actions of Los Angeles City Planning and Zoning Dept. I now see why the city was reluctant to share this ridiculous report linked below. I also see why it took so long for ARG which is controlled by a 100% white leadership corporation to finish and release the report. Even they knew the report written by lower level writers was too extreme. They should have stuck to the facts instead of adding the slanted racist commentary.

https://planning.lacity.gov/odocument/3eaaa5ce-d96c-4325-a1b8-557218bbd0f5/Historic_Housing_and_Land_Use_Study.pdf

This was the alleged goal of the report. "Architectural Resources Group (ARG) was retained by the City of Los Angeles to prepare this Study as part of the update to the 2021-2029 Housing Element of the General Plan (The Plan to House LA)." "The Study aims to provide an understanding of the twentieth century policies that have contributed to Los Angeles’ housing shortage and affordability crisis, as well as those which have contributed to unequal access to housing and economic opportunity. In providing a context for the current housing landscape, the Study will help inform future efforts by the City as it seeks to provide housing for Los Angeles’ diverse and varied population."

It looks like ARG made this report starting around 2022 after George Floyd's 2020 murder during the height of the more extreme BLM, DEI actions. I support BLM, DEI but the initial reaction after Floyd's murder was an extreme pendulum swing. It corrected and now there's a backlash in the opposite direction which is also wrong but expected. This misguided "report" blames current racial income and wealth inequality on the current allegedly "racist" Los Angeles City Planning and Zoning Department. Let me provide some much needed facts.

Whites make more money than blacks, Latinos. People who make more money have more money. People who have more money can afford to buy and own more expensive homes, apartments in more expensive areas. They also have more expensive cars. This is the reason why whites tend to live in more expensive areas and their homes are worth more. It's the income gap, stupid! Low income whites live in the same area as low income blacks, Latinos. AEI research has proven time and time again that the correlation is socioeconomic factors and not race. It's money. No Planning Department can fix the income gap. It's not their jurisdiction. No one today is preventing blacks, Latinos from living in more expensive areas of LA. Economics is preventing them from being able to afford to live in those areas. Fix the income gap!

This report blames LA City Planning and Zoning department for blacks, Latinos not being able to own and live in more expensive homes in more expensive areas today. "This analysis shows that past planning and housing policies have too often prioritized the concerns of the White middle class over the marginalized, denying communities of color access to resources and excluding them from wealth-building opportunities. Exclusionary policies of the past persist today, perpetuating patterns of segregation, displacement, inequity, and exclusion." Today the cause is income inequality which isn't caused by the Planning Dept. Anyone can now buy any house, rent any apartmentn they can afford. This would be like blaming the Department of Motor Vehicles DMV because whites own more expensive cars than blacks, Latinos. The report writers would call the DMV racist.

Reading through this report I see that it's riddled with illogical reasoning. The report says that people who live in nice homes in nice areas are more successful than those who don't and it's not fair to POC. They think if low income POC could just live in those areas, they'd automatically be successful. Wrong. You have to be successful in order to make enough money to afford to live in those areas! It says this is the fault of the Planning Dept. It's economics! It affects all lower income people equally, white, black, green. You need to complain to the labor dept not Planning. This is not a peer reviewed report. It is not published research. It would never be published with all these statistical mistakes and misinterpretations.

The real reason for the Housing Crisis today is lack of a sufficient number of housing units in Los Angeles and most US cities. Another reason is of course all incomes lagging behind home values. Lack of supply drives up demand and prices. The price of homes is up 46% in last five years alone for this reason. The problem is more people living in an area which is predominantly zoned single family. It's also caused by more expensive California building requirements, increased construction costs, more development red tape, higher interest rates and NIMBYs (Not In My Back Yard). Higher housing costs also increases land costs which increases building costs.

I know that if the city of Los Angeles would allow light touch density, i.e. allow 1-4 units in SFR zones, the housing issue would be much closer to being solved. There would be more housing units which would cost less. As it is you have two to four families living in SFRs, duplexes in lower income areas illegally against zoning, Building & Safety laws. They cut up the buildings, convert garages, add additions without permits. NIMBYs are the reason we don't have light touch density. If you want to blame someone for blacks, Latinos, lower income people of all races, colors not being able to afford housing, blame NIMBYs and the income gap. It'd make more sense than blaming the LA Planning and Zoning Department. The report of course says the only goal of Zoning Dept was, is to help only white people and segregate black people into poor areas. This is false. There was never a black, Latino...zone. There were some private CC&Rs which restricted where blacks and some others could live in certain neighborhoods pre 1945. Those were made by the property owners and not the Planning Dept. In 1945 in LA the Adams Heights, Sugar Hill case outlawed those restrictions. The 1963 California Rumford Act also outlawed any restrictions. The Federal Fair Housing Act of 1968 made it national. People today live in different areas based on finances alone.

I read the intro, beginning, findings, conclusion and will read the rest later. I'm sure these people misconstrued redlining and other issues. Check back for the full report after I read it all. This report was a waste of city funds. It will just incite racism, hatred and division. AI, Google will now pick it up and repeat this bullshit as fact further stoking racism and hatred. No one should ever hire this group if they can't make sure their lower level employees can complete an assignment in a fair, unbiased, unracist manner.

Just looked at the "definition" of "redlining" in the report. "Redlining: a discriminatory practice that puts services (financial services, i.e. loans, or otherwise) out of reach for residents of certain areas based on race or ethnicity. The term “redlining” originated in the 1930s, when a government-sponsored corporation (the Home Owners’ Loan Corporation, or HOLC) assessed and categorized neighborhoods occupied by ethnic groups and people of color as “declining” or “hazardous” and therefore viewed them as investment risks; the policy discouraged investment in these neighborhoods, the legacy of which is felt to this day."

This is incorrect besides totally racist. This is what "redling" actually was. HOLC made maps of a few cities in the US in 1935 to determine loan risk so the government could loan the property owners money to improve the areas. They made maps for 239 cities out of 108,000 cities or .2%. Most of those maps never mentioned race. They mentioned % tenants, income of occupants, age of properties, values of properties, condition of properties, value forecasts...all risks factors we still use today. Some maps mentioned race. It varied based on who was doing the survey. Some high risk "red" zones had POC and some were all white occupants. The real correlation was income, condition/value of properties and not color, race. Again, lower income people live in areas that cost less because they are more likely to be older and in fairer condition near freeways, industrial property... Race was removed from the map surveys. It didn't change the risk rating at all. All the other factors are still used today.

Map areas were rated A, B, C, D with D being the riskiest for loan repayment. Some called the D zone the "red zone" because loans cost more because they were riskier because assets were worth less and were depreciating. We still charge people more for riskier loans today. Loans were given to the property owners and not the occupants or residents. Some D zones had more blacks, Latino residents because they were lower income and these areas are cheaper to rent, own. 80% of the D zone property was owned by white people. White people were the ones who got loans with higher interest rates in the "red" zones not POC. They still got loans, more loans than before the program. It was never "black residents = red zone = no loans for black people." The government programs actually brought a lot of money to all of the areas so they could improve their property or buy more property. There were no affordable loans prior to this. You mainly had to pay cash. Many old red zones are extremely affluent areas today like San Francisco, New York and Los Angeles. Research has proven it did not have a long term negative affect on those areas today. The entire report is riddled with this type of misinformation and lack of understanding. It's like the authors asked AI for summary of redlining but asked AI to make sure it was racist.

FTR I'm a Latina born and raised in Los Angeles and speak Spanish, English. I see racism every day in LA. I've been in real estate over 40 years. I specialize in single and multifamily properties in lower income areas of Los Angeles. I've appraised Section 8, low income housing projects, property in high risk areas. I'm 100% for fair housing and against racism. I know a thing or two about this issue. I'm the first to call out and fight true racism. There is so much real racism that it's ridiculous to waste time, energy and money stoking nonexistent racism against the Planning Dept and City. They should be working on the income gap. Huge waste of city funds to pay for this report.

I just sent an email to the leaders of the Planning Department.

I'm a Latina real estate appraiser, broker in Los Angeles. I've appraised real estate in LA in lower income areas for over 40 years. I've written about LA real estate for decades. I'm also involved in LA politics being nominated to the Prop F Committee by Mayor Garcetti.

I just read most of the LA Historical Housing and Land Use Study. I was upset by this inaccurate report so I wrote an article about it linked below. The authors of the "study" clearly don't understand the basics of economics or income inequality. This should have been peer reviewed before being published. People will now assume this is a true research study because the city paid for and sanctioned it.

The authors don't even understand the full history or implications of "redlining." There has been lots of peer reviewed and published research about the implications and long term effects of redlining. The authors presented a one sided view of the HOLC maps and loan program.

The worst part of this report is that it basically calls the current LA City Zoning and Planning Department racist. The authors believe that the Planning Dept can solve income and wealth inequality when the causes are under the jurisdiction of the labor department. It's as ridiculous as blaming the DMV because most white people can afford to own more expensive cars than most POC, Latinos. It's basic economics. The government needs to work on the income gap. FTR I'm Latina.

Yes, we do have racism and a housing crisis but it's not caused by past redlining. Light touch zoning, easing development red tape, reducing some building overregulation and overruling NIMBYs would make a big difference.

https://mary--cummins.blogspot.com/2024/09/racist-los-angeles-planning-report.html

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Mary Cummins

Friday, August 23, 2024

RealPage YieldStar Sued by Justice Department for Alleged "Price Fixing" - Doesn't Really Make Sense, by Mary Cummins

RealPage was sued by the Department of Justice for alleged "price fixing" of apartment rents. DOJ stated RealPage was "attempting to illegally decrease pricing competition between landlords and deprive renters the benefits of that competition." I find it hard to believe that a rental database is "price fixing." What about Zillow, MLS, stock market, Kelly Blue Book...? They all show list and sales prices which people use to set prices for similar goods. An an appraiser I do sales and rental analysis all the time with MLS, CoreLogic, Realty, Google... data. Is that price fixing? People hire me to find out what the market rate sales price or rent is for their home or apartment. Am I a "price fixer?"

RealPage offers a host of software and services to help property managers. One of those services is a software called YieldStar. YieldStar uses rental data from software users and more to suggest list rent prices for apartment building owners. Apartment owners have been using rental data to set prices since the beginning of time. Sometimes the rental prices are public and sometimes you have to do some research to find out the list and sales rent. Back in the day we had to get on the phone and call people. Some do the research and sell the reports. In this case property owners were submitting their own rents anonymously into the database. They don't want to do it publicly because then tenants could see their bottom rent, max rent concessions and only offer to pay rock bottom rent. Car dealerships do the same. Do we even know if they were inputting real rental rates? Doubt it was verified. RealPage said managers only used the data half of the time. Only 10% of some markets use their software. You would need 70% of apartment managers using the data and recommendations to affect the market. Here at most you had 5% considering market rate rent based on the data. They were given market rent data and not an inflated agreed upon value by all apartment building owners. That's the big difference here.

The real issue is rents have risen and it's an election year. Rents correlate directly with home prices which have risen at the same exact rate. The underlying cause is people aren't making enough money to pay the rent because wages are stagnant and there are not enough housing units. They need to help people make more money and build more units. Because it's an election year one party has to instead blame the government's problem on private individuals and businesses. "Vote for me and I'll lower your rent by suing a data company!" Getting rid of RealPage won't lower the rent. They never want to fix the real problem because it's too big and complex.

The last election cycle Joe Biden said blacks and Latinos were being lowballed by "old white racist male" appraisers devaluing their homes. We appraisers were the scapegoat for blacks, Latinos not having as much money as whites and owning less valuable homes. Biden said if elected he'd make sweeping changes with appraisers to increase property values. He didn't change anything but increase government meetings and paperwork. Again the real problem is income. In this situation whites make more than blacks, Latinos. If you make more money you have more money and can afford to buy a more expensive home in a more expensive area. Appraisers report values. We don't set them. Guess what? Whites also own more expensive cars than blacks, Latinos. Are real estate appraisers to blame for that also?

I will try to find the lawsuits and read them closely to see if there was any real "price fixing." The timing right before the election with Kamala Harris talking about high rents and "price gougers" makes me think this is just an election year issue. I'm just glad it's not another made up problem with appraisers. We've been through enough with the false lowball narrative smeared all over the media and internet.

https://www.yahoo.com/news/justice-department-suing-realpage-over-163534773.html

This article goes more into the specifics of the lawsuit. It still doesn't make sense. What about Kelly Blue Book algorithm for car values? They suggest market rate values for cars. It's based on car sales and listings. This is feeling like election year politics. It reminds me of the DOJ, HUD getting involved in a private alleged real estate bias lawsuit in Marin, California. DOJ filed a Statement of Interest in a fake racial discrimination case in appraisal values. It was 100% political so the government can say "see, we're doing something. Vote for us!"

https://natlawreview.com/article/justice-department-sues-software-maker-realpage-enabling-rent-collusion

Below are CoreLogic and Zillow rent reports on a property. Will they and MLS be sued next? I assume the value is being pulled from MLS and Zillow rental database. Apartments.com also shows rental prices for various areas. There are so many rental databases offering suggested rents. Maybe RealPage should have made the rental database non anonymous. It could just be based on general area and not specific building addresses.

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Mary Cummins

Monday, July 8, 2024

Apprasal BuzzCast with Hal Humphreys, Peter Christensen - Two Case of Alleged Appraiser Bias, Malpractice by Mary Cummins Real Estate Appraiser

jim morrison, hal humphreys, peter christensen, appraisal, real estate appraisal, appraiser, los angeles, california, mary cummins, lawsuit, bias, discrimination, hud

Appraisal Buzz has a good video on their The Appraisal BuzzCast with real estate appraiser Hal Humphreys and lawyer Peter Christensen talking about recent real estate appraisal lawsuits. The episode is July 3, 2024.

https://www.youtube.com/watch?v=rQQ2gbWj5x0

The video discusses two recent appraisal lawsuits and Peter Christensen's upcoming class in August at Valuation Expo. Peter Christensen said right now there are about 11 real estate appraisal bias lawsuits. HUD hasn't decided on 200 plus investigations.

The first case is in Chattanooga, Tennessee. An appraiser appraised a house for a purchase borrower. The home was under renovation and not complete. The value came in below contract so the borrower couldn't buy the home. A month later after the property was complete and finished another borrower tried to buy the property. He was given a copy of the old appraisal. The new potential lender was a credit union. They ended up hiring the same appraiser who just appraised it a month earlier. That appraiser did not reinspect the now finished property. They just changed the effective date and lender. They stated they reinspected the property when they didn't. They came in at the same older value.

The borrower contacted the credit union who basically said just deal with the low value. Borrower went to another lender, got a new higher appraisal, got the loan and closed on it. That borrower then sued, complained about the appraiser and the lender. Appraiser was sued for of course lying about inspecting besides a million USPAP and other violations. The lender was sued for not reporting the appraiser to state board.

That appraiser was absolutely in the wrong and deserved to be sued. He must have been pressured by the lender. Otherwise why not go back out especially when it wasn't finished a month earlier. Of course it will look different. Stupid appraiser. I didn't know lenders could be sued for not reporting an appraiser.

The second case is in Los Angeles, California which I'd heard about. It involves a black ex football player and his wife a retired accountant. It involves four appraisers in a reverse mortgage. There were two "acceptable to the borrower" higher appraisals. Home must be valued over $1,000,000 to need two appraisals Then there were two review appraisals which came in 25% lower. Then there were two more review appraisals which also came in 25% lower. All the lower appraisers are being sued for racial discrimination and bias.

I haven't seen any appraisals but I heard about the values. Based on my experience the lower appraisals are more likely to be accurate. There is no reason to lowball an appraisal value. You could be sued for bias by the borrower. This is why appraisers are more likely to come in higher than market value. Maybe the higher appraisers were biased positively because the guy was an ex football player? Maybe they came in higher because the borrowers are black? The review appraisers don't see the people. They don't see any personal photos because they're all blurred. How would they ever know race, color, gender...of the borrower? How can they be biased based on factors they don't even know? I wish I knew more about the case.

Just found this on Peter Christensen's LinkedIn page.

"In this new case, a retired NFL player and his wife have filed fair housing discrimination legal claims. The claims involve multiple appraisals/appraisal reviews for the purpose of a proposed reverse mortgage. There are 9 appraisals/reviews performed by different appraisers from November 2020 to August 2021 identified in the case. The value opinions of the suburban home range from $1.5m to $3.15m.* The borrowers allege that the low values in that range, which prevented their reverse mortgage, stem from bias based on their race and on the predominant race in their neighborhood. As reflected in the snippet below from their court complaint, they filed a HUD complaint in January 2022 and waited for a result for more than 2 years - until finally withdrawing the HUD complaint in April 2024 to pursue a civil action in state court.

* For the curious, here are the values/dates of value in the 9 different appraisers' reports:

> 11/18/20: $3.1m

> 1/13/21 (4 reports with same date of value): $3.1m, $2.6, $2.5m, $1.5m

> 1/26/21: $2.5m

> 6/3/21: $3.15m

> 6/20/21: $3.1m

> 8/20/21: $3.1m "

That's a huge range of values. I definitely see why they were concerned. Looks like some appraisers used bad comps? I'll update this if I find out more about the case.

Hal Humphreys had some good and obvious suggestions so you don't get sued as an appraiser. Peter agreed with him. Be nice, receptive to person's input and do the absolute best and most thorough appraisal possible. Peter said sometimes if an appraiser is rude, short or rushed, it may come across as biased or racist even if the appraiser treats everyone that way. Peter said "kindness matters." If they tell you, you got the sf wrong, listen to them. Make changes if warranted. Talk to them about the process. This will eliminate a lot of problems. I absolutely agree. I must state that some AMCs instruct appraisers not to "chit chat" with borrowers, people at the property.

I've thought about how to avoid problems as an appraiser. Obviously, be nice, courteous and receptive. When I'm in a situation where I'm appraising a complex appraisal say in an area going through revitalization, near an area with much higher prices or where home values vary greatly, I explain things in layman's terms. I will state why I didn't use certain comps and why. If the home next door sold for 50% more, I will mention it and why I didn't use it, i.e. double the size, fully remodeled, pool, ADU... If the subject is on a busy highway and homes nearby on cul-de-sacs sell for 50% more, I'll mention them and state why I didn't use the comps. Not all borrowers are incredibly real estate savvy. As it is our appraisal forms are confusing even with the definitions page. There's a lot of abbreviations, codes, rating numbers/letters... Some sections like "condition" are confusing. I always tell them to call me if they have any questions. Make sure you reply to their calls.

DISCLAIMER: https://mary--cummins.blogspot.com/p/disclaimer-privacy-policy-for-blogs-by.html

Mary Cummins

Friday, June 28, 2024

Glendale Metro Station aka Southern Pacific Railroad Depot by Mary Cummins

glendale metro station, southern pacific railroad depot, mary cummins, real estate appraiser, real estate appraisal, real estate, appraisal, los angeles, california

The Glendale Metro Station was formerly known as the Southern Pacific Railroad Depot. I took these photos when I was down the street dropping off kittens to be spayed at Kitten Rescue.

On March 27, 1924, the Southern Pacific Railroad opened its eagerly anticipated Glendale passenger depot to an evening of great fanfare and community praise. The railroad contracted the San Francisco Architectural firm of MacDonald and Couchot. Architects Kenneth MacDonald Jr. and Maurice C. Couchot also designed depots for the Southern Pacific in Los Gatos and Santa Clara, but those stations no longer stand. The Spanish Colonial inspired depot features heavy "California" plaster mimicking adobe hiding its all cast concrete construction. Beautiful wrought iron grills, railings, lanterns and magnificent Churrigueresque cast stone entry portals guarded by fanciful mermen figures hold up the railroad's herald above each waiting room door. A concrete scored floor resembles old tile and the bumpy plaster finish continues inside. The crunch of decomposed gravel heard underfoot, was long ago replaced by modern concrete platforms. Native California plants and climbing roses were original landscaping. Because of the depot's proximity to the film industry in Los Angeles and Hollywood, many movies have been shot there. In the 1930s Buster Keaton filmed "College" at depot, "Horse Shoes" was another. The most well know film with the depot as a background was by director Billy Wilder, "Double Indemnity" in 1944 starring Fred MacMurray and Barbara Stanwyck. The depot has undergone minor remodels in 1943, 1954 and restored in 1999 and 2012. Today, the unstaffed depot serves 10 Pacific Surfliners, 54 Metrolinks trains weekdays, and 12 Antelope Valley Line trains Weekends and is the 37th busiest Amtrak station in the state with 100 passengers daily.

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Mary Cummins

Saturday, June 8, 2024

Details About Alleged Racial Bias Case in Allendale, Oakland, California from Civil Rights Department by Mary Cummins Real Estate Appraiser

allendale, oakland, california, mary cummins, real estate appraiser,bias, discrimination, real estate, appraiser, appraisal, real estate appraiser, fair housing,redlining,

This morning I received the results of a California State Information Act Request I made regarding an alleged case of racial bias in Allendale, Oakland, California which was settled May 2024. I requested any and all documents in the case involving the appraiser because I didn't have the complainant's name or property address. I only had the appraiser's name which I won't post in text.

Complainant stated appraiser told them they should remove security bars from windows. Complainant stated this is evidence of "racist discrimination" based on "racism/includes hairstyle and hair texture." Security bars on bedroom windows which don't release from the inside are against code in California since about 1995. All appraisers, lenders tell everyone to remove the bars because it's the law and prevents people especially children from burning to death in a fire.

Response to State Information Act Request. They redacted name and address.

https://drive.google.com/file/d/1muiicnMhbJfi7F5L2vcltoYvdw8HbIXq/view?usp=sharing

Summary of response. They redacted name and address.

https://drive.google.com/file/d/15KPOXRBORCfL9LknvGr5TiWwObqoHvRJ/view?usp=sharing

Press release from Fair Housing Advocates of Northern California about the case.

https://www.fairhousingnorcal.org/press-releases-and-statements/discrimination-complaint-alleging-race-discrimination-in-home-appraisal-process-settled-with-appraiser

I was hoping for an address or name so I could check the values by doing historical valuations. No such luck but I did get other vital information from the complaint, see below. This information shows the first appraisal probably wasn't biased but the second higher one probably was. I will say that census tract 4070, Allendale, Oakland, California is an area going through revitalization and rapid home appreciation. ( FHANC are the ones who stated the tract. Appraisers don't look at tract information. I'm looking at it now because FHANC mentioned it in their complaint. Allendale is almost exact same area as the tract) If you look at the census map linked directly above, the MacArthur Fwy 580 goes through the tract. Generally freeways are initially built through areas which had lower values because it's cheaper for the city, county, state to purchase the land. Allendale is across the bay from much higher priced San Francisco. People priced out of SanFran have been pushed over into Allendale, Oakland for years now. This is why prices in Allendale and the surrounding area have been increasing rapidly especially for fully renovated properties. Properties near freeways vary more in value based on proximity, view of the freeway. This is a map of Allendale on Google. Here is Zillow (I know, I know) chart of home appreciation in Allendale over time. Zillow is okay for trends but not for specific home values.

We do know that the subject property needed repairs. An older property in an area going through revitalization is a more complex appraisal. It will be worth less than similar properties which have been fully renovated. The cost to renovate an older home in this area can easily run $250,000. Most of these homes, duplexes were built 1900-1930.

FHANC states Allendale is a "black neighborhood" which is a racist statement. Census docs state the inhabitants are mainly Latino, Asian, White, Black in that order of percentages. "Black" is actually the smallest percentage of the population in that area. This shows a false statement and bias by FHANC. Census docs state median value of owner occupied homes in area today May 2024 is $702,200 ±$68,592. 78% of homes worth $500-$1M. Only 8% worth over $1M. The home was worth less at the time of appraisal 2021. Median prices for the area were lower then.

The owner stated she had two recent previous and one subsequent appraisal on the property. That's a red flag right there. Why did she make so many recent loan applications? Clearly the previous loans were probably denied or she wouldn't be seeking yet another loan. This would also cause more credit inquiries which make it more difficult and expensive to get a loan. A good loan agent would have explained all of these things to her before doing a credit check or appraisal. Sometimes you need to work on credit or the property before doing a credit inquiry or appraisal or you'll just get rejected and have to wait six months minimum to reapply.

The owner stated the property needed work. "Ms. Trent applied to a mortgage company to refinance her home loan and to use some of the equity to finance needed repairs and renovations." "I was relying on being approved for the loan to in order to make improvements to my heating and bathroom going into the winter." Many banks will not give a conventional loan on a property if it needs major repairs or is in less than average or fair condition. The appraisal value is not the only reason why a loan could be denied. Sometimes lenders just state that when it's not true to deflect blame, complaints and lawsuits. Even if the loan to value ratio were higher than the borrower desired, the borrower could get a higher LTV ratio loan if they had good credit and/or paid a higher rate.

One interesting note is that the complainant states she was discriminated against based on her "Race (includes hairstyle and hair texture)." She claims she was "Denied equal terms and conditions; Denied loan/home owners insurance." She claims the appraiser made racist, racially charged statements which were "critical of her and her home specifically that her security bars should be removed." Unreleasable security bars must be removed from bedroom windows because people can die in a fire. They can be replaced with bars which release from the inside so people can escape a fire. That's not racist but California Health and Safety, Building Code and the law since 1995-1998! Here is the Oakland security bar law. I've said that to everyone with security bars even when I don't see or know what the owner looks like.

She claims the appraiser adjusted sold comps down $150,000 to $200,000 based on their superior condition. She stated her home needed work. We're supposed to adjust for condition. She stated appraiser only used two comps in area with more "white people" unlike her area. She wanted "white" comps just like the last case in Oakland. Again, it's the race income home value correlation and not race home value. Whites make more money than Latinos, blacks. People who make more money have more money and buy/own more expensive homes in more expensive areas. The correlation is not race/color = home value.

She goes on to mention "redlining" maps from 1935-1968. Here's an article I wrote about redlining. The maps were made by the government's Home Owners Loan Corporation to determine property risk factors so the government could give people cheaper loans to help the economy. It included many factors which we still use today. Some maps included race, nationality of inhabitants, not owners of the properties getting the loans. Race, nationality were omitted in 1968. Race, nationality were a mere correlation to value, risk because of income. They were not a direct factor which caused the property owner to be considered high risk and be denied a loan. There were red zones which had no black people. It wasn't black=redzone=loan denied. It was high risk=redzone=loan could be denied.

She said her property was in a yellow zone almost 100 years ago. ( HOLC aka "redline" Map of Oakland 1936-39) Makes sense as it was closer to new then and there was no 580 freeway. She said appraiser cut off comp properties at the 580 freeway. 580 built 1960 after home was built. That makes total sense as that is the edge of Allendale. She wanted the appraiser to choose only certain higher comps in a circle around her. We shouldn't always choose a perfect circle around the subject because neighborhoods aren't laid out that way. She said appraiser only chose comps from specific areas. That's what we're supposed to do. She said appraiser chose comps based on 100 year old redlining map. I doubt the appraiser has even seen the redlining maps from 100 years ago. Research has also shown that redlining affected the white property owners mainly. Research has shown that redlining does not affect properties today in a negative manner. Those areas have actually appreciated the most through revitalization which some incorrectly call "gentrification."

She states appraiser lives in the Bay Area. She also I assume Googled the appraiser after the appraisal. There is allegedly a photo of the appraiser in San Francisco in front of the Gadsden flag with a caption that states "Don't tread on me! A warrior of light never accepts the unacceptable." She states that's racist. The phrase is the opposite of racist. The first part "don't tread on me" is a message to the British not to trample on the rights of Americans. The second part is from "Excerpt from Warrior of the Light: A Manual by Paulo Coelho." The phrase is against antisemitism and Hitler and other ills of the human race. The Gadsden flag flies in the Civic Center of San Francisco. "The Gadsden Flag is a historical American flag with a yellow field depicting a timber rattlesnake coiled and ready to strike, beneath which are the words “DON’T TREAD ON ME.” Its creator, Christopher Gadsden, designed it in 1775 during the American Revolution as a warning to Great Britain not to violate the liberties of its American subjects." She is clearly racist. She sees racism in everything. I realize people who have been discriminated against in the past will assume everything they don't like is racism but it's not.

First appraisal December 8, 2021 at $785,000. Second was a month or so later at $1,125,000. This sounds exactly like the other Oakland case of alleged bias. It's also directly related to an article I just wrote on why appraisal values can vary. That is a huge difference. It appears the second appraiser used properties in a more expensive neighborhood/area farther from the 580 freeway and subject which were in superior C2-C3 renovated condition. I believe the second appraiser was incompetent and trying to avoid a complaint. Higher value means happy borrower and no complaint even if the appraisal is riddled with mistakes and is bank fraud. It takes a good experienced ethical appraiser to come in at market value in these situations knowing there could be a nightmare frivolous meritless complaint like in this case.

Sadly we don't have enough information to know if there was any discrimination in the valuation process beyond what I just stated. Based on the complaint there was no discriminatory behavior. I think the differences in values were due to the second appraiser selecting comps in a different area and not properly adjusting down for inferior subject condition. They may have done that because they knew they were the second appraiser and didn't want a complaint or lawsuit. Maybe the owner told them about the first lower appraiser and said she's filing a complaint. The second appraiser should have been reported to BREA and sued for bank fraud.

Based on my experience researching these cases discrimination is not the issue. The borrower just wanted a higher value. She probably got real estate agent, Zillow postcards in the mail saying "a "similar" home just sold for $1,500,000." "Find out what your home is worth today!" She assumed her home in fair condition would be worth the same when it's not. Agents do this to drum up business. If anyone has more information on this case, please, let me know.

Below is the main three page complaint from owner/borrower. The one from FHANC is almost identical. This is also in the pdf above.

Appraiser John Dorie sent me this information about fire code.

"The International Residential Code, IRC, Section R310 dictates the MINIMUM specifications for

a Sleeping Room. The International Fire Code, IFC, Section 1031 also specifies the minimum

regulations for Emergency Escape and Resue from Sleeping Rooms. Both Codes work in concert

without disagreement.

IRC Section R310.1 and IFC Section 1031.3 require all, “Basements, habitable attics, and every

sleeping room shall have not less than one operable emergency and rescue opening.”

IRC Section 310.2.1 and IFC Section 1031.3.1 and .2 require a minimum of 5.7 sf (net clear

height min 24", net clear width min 20") for the emergency and rescue opening.

IFC Section 1031.6 focuses on “bars, grills, covers and screens” covering possible escape and

rescue windows and doors and is specific stating, “Such devices shall be releasable or

removable from the inside without the use of a key, tool or force greater than that which is

required for normal operation of the emergency escape and rescue opening.”

Below is a sample State Information Act Request, Freedom of Information Act Request. Most Government Departments have forms you can fill out and submit online. You generally request the documents from the Public Records Act contact. I've been doing this with the cases I've covered in my blog.

"Dear Custodian of Record,

Pursuant to my rights under the California Public Records Act Government Code Section 6250 et seq., (or Freedom of Information Act if federal department) I ask to obtain a copy of the following, which I understand to be held by your agency:

(List specific and general items such as all communications, documents, data, files written and otherwise concerning person, address, complaint, lawsuit....)

I ask for a determination on this request within 10 days of your receipt of it, and an even prompter reply if you can make that determination without having to review the records in question.

If you determine that any or all or the information qualifies for an exemption from disclosure, I ask you to note whether, as is normally the case under the Act, the exemption is discretionary, and if so whether it is necessary in this case to exercise your discretion to withhold the information.

If you determine that some but not all of the information is exempt from disclosure and that you intend to withhold it, I ask that you redact it for the time being and make the rest available as requested.

In any event, please provide a signed notification citing the legal authorities on which you rely if you determine that any or all of the information is exempt and will not be disclosed.

If I can provide any clarification that will help expedite your attention to my request, please contact me. I ask that you notify me of any duplication costs exceeding $50 before you duplicate the records so that I may decide which records I want copied. I would prefer to receive the records including audio by email at ***.

Thank you for your time and attention to this matter."

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Mary Cummins

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

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