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

Mary Cummins, Real Estate Appraiser, Animal Advocates, Los Angeles, California
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Showing posts with label fannie mae. Show all posts
Showing posts with label fannie mae. Show all posts

Saturday, September 7, 2024

Mandatory Cultural Competency Elimination of Bias Class for Real Estate Appraisers by Mary Cummins


I completed my California real estate appraisal continuing education "3-hour Cultural Competency and Elimination of Bias in Appraisals" class last month. While I agree all humans have implicit bias I don't believe that many, most or all appraisers act on it. Appraising is a math formula. 2+2=4. You could be the most evil racist unhinged person on earth and 2+2=4. 2+2 ≠ 3 or 5. You would have to intentionally work extremely hard to contort hard data and a basic math formula. The review robots, AMC, Lender would catch your error and reject your report before a client saw it. And for what? To lose your license, career, go broke, get sued, have all your colleagues and everyone else despise your racist behind...?

I was upset to see the course falsely promote some of the false cases in the media about bias as fact. The cases were mainly the false Maryland and Florida cases which I covered in this blog. There was no lowballing at all. I also didn't like being forced to view racist propaganda videos. One included known "research" fraud Andre Perry and his fake paper. It's a fact that whites make more money than blacks, Latinos. If you make more money, you have more money and you're more likely to buy a more expensive home in a more expensive area. That's why white owned homes are worth more than black, Latino. No one lowballed the appraisals. Those appraisals were done by robots, AVMs and not appraisers.

The class even promoted the hugely misinterpreted Fannie Mae anecdotal data on race, contract price and appraisal values as true. AEI debunked it with research. There are more concessions in lower priced areas which are more likely to be black, Latino because of lower income, wealth. This is why appraisal values are lower than contract price in those areas. This means blacks, Latinos were paying over market value because they were conned by real estate agents. They should have made up fake case studies as examples without using color, race and real cases that have not been settled on the merits. Using these frivolous cases was actually bias and racism. 

The class also included false information on the term "redlining." I wrote an article about redlining here with facts and dates. The class itself was biased, racist and promoted false narratives about appraisers and the appraisal industry. It could have easily explained bias in a more neutral manner without involving specific people, races, colors, lawsuits and organizations. I'm assuming promoting the false narrative is the only way the courses would be approved by the powers that be. So ironic that the government deals with the issue of bias, racism, and discrimination by actually being biased, racist and discriminatory. There's enough real bias, racism and discrimination in this country that we need to fight. Ridiculous to waste time, energy and money fighting nonexistent racism. I believe the government does this so people won't look at the real cause of income inequality and the wealth gap among white, black and Latinos. It's easier to blame appraisers than to fix the income gap.

Home appraisal is a math formula. Robots, AVMs can do a home appraisal of an average home if they had all the data which they don't. That's how exact the math formula can be. In fact I pull my comps based on math formula alone which I've posted here a million times. I then type those comps into a form. I choose adjustments based on more match i.e. matched pairs analysis and regression theory. My software then adds/subtracts the adjustments and that's the value. I don't control the value. 

Some may say why not just use robots and AVMs. The problem is they don't see or inspect the property. They don't have all the data. GIGO, garbage in garbage out. They don't know if it exists, actual size, permitted number of bedrooms, condition, upgrades, actual age, view type, topography, lot type, home style.... They only know what's on the tax roll which isn't always accurate. Some like Zillow also include MLS data which is generally incorrect. Most MLS sizes, bed counts are larger than actual. Zillow and others also let the public edit the data which makes it even more inaccurate. Zillow also doesn't do a proper comp search or adjustments. If Zillow can't find similar recent comps, it goes so wide that it's in a totally different neighborhood which could be worth twice as much. In fact most of the false media cases about lowballing fell into that category. Zillow is probably the reason appraisers were frivolously sued for bias, racial discrimination and alleged lowballing. 

Appraisers use numbers, facts and data. We're aren't interpreting the finer possible meaning of ancient translated words in poetry or the Constitution. There is no interpretation. It's basic math! You'd have to work harder than Justices Samuel Alito or Clarence Thomas when they twist, contort and misinterpret the words of the 1788 Constitution. There is no room to twist number of square feet, number of bedrooms, number of garages, location, recent local sales... Facts are facts. 

This class is now mandatory because of recent regulatory changes caused by the false narrative of the "racist appraisers." So far no lawsuit has shown or proven any bias, racism or discrimination in appraisals. "Those applying for appraisal license renewal in California must complete at least one hour of Cultural Competency and two hours of Elimination of Bias, which can be combined into a single three-hour course. These changes to the education requirements are key components of California Assembly Bill 948."


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


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

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

Monday, August 5, 2024

National Fair Housing Alliance NFHA and HUD Promote False Racist Narrative About Real Estate Appraisers, Lenders For Money by Mary Cummins

mary cummins, real estate appraiser, real estate appraisal, aei, hud, nfha, national fair housing alliance, race, discrimination, bias, settlements,
National Fair Housing Alliance NFHA Promotes False Racist Narrative about Real Estate Appraisers for MONEY, mary cummins, real estate appraiser, real estate appraisal, aei, hud, nfha, national fair housing alliance, race, discrimination, bias, settlements,


UPDATE: Appraisal Institute just posted about this issue here.

"Recently, a HUD-funded billboard campaign stated, “Home appraisals should be based on property, not people.”

We wholeheartedly agree. Bias in appraisals is not only unethical—it’s illegal. However, this campaign unfairly targets a profession built on independence, impartiality, and consumer protection. In a powerful response, Sandra K. Adomatis, SRA, President of the Appraisal Institute, clarifies the critical role of appraisers, addresses misconceptions, and highlights the need for meaningful policy change to support housing equity.

Read Sandra’s full letter and learn why appraisers are key advocates for fair and objective valuations 👉 https://bit.ly/490vHl6 "


11/16/2024 I was in the market and picked up Essence magazine because Serena is on the cover and I love her. It's a black women's lifestyle magazine. Inside was another targeted racist ad against appraisers. I then decided to look at the white women's lifestyle magazines. No racist ads in there. This was targeted to black women. 




10/16/2024 Just found the PSA and script for the new NFHA ads. This is disgraceful! HUD, NFHA is basically defaming all real estate appraisers calling them racist. This has to be unconstitutional for the government to spend money making, promoting these "ads" to spread racist falsehoods against nonblacks, nonLatinos. It's unconstitutional for the government to give preference or money to specific races. It must be unconstitutional to harm specific races. Research based on their own data proves this is false. AEI's research showed there is no racism in appraisal values. 






Radio spot script

"Robbed" (:60)

WOMAN V/O: My husband and I were ready to sell our home of 25 years,

so we got it appraised. We thought we knew what to expect, but when our

home appraisal came back, we felt…robbed. Compared to a similar home

right around the corner, our appraisal was $80,000 less. That’s a big

difference. It was the same type of home, in the same neighborhood, in

the same condition and age.

NARRATOR V/O: A recent study found that Latino and Black

homeowners are about twice as likely as white homeowners to get low

appraisals. For example, one Black homeowner received an appraisal

more than double the original, after removing family photos, Black art, and

books from her home.

If you believe your home has been unfairly appraised because of race or

national origin, that could violate the Fair Housing Act. Contact HUD at

HUD.gov/fairhousing – that’s HUD.gov/ fairhousing. Everyone has a right

to fair housing.

A public service message from HUD in partnership with the National Fair

Housing Alliance."

Radio spot 2 "Hide" (:60)

HUSBAND V/O: After getting my promotion, the time had come to sell our

home. So we got an appraisal.

WIFE V/O: But it was much lower than we expected. Before we had it

appraised again, a friend suggested we make some changes.

HUSBAND V/O: I put my framed vintage Negro League Baseball shirt,

our African art, and family photos into storage. And that second appraisal

came back much higher!

WIFE V/O: It’s a shame we had to hide who we are to get a fair home

appraisal.

NARRATOR V/O: A recent study found that Black and Latino

homeowners are about twice as likely as white homeowners to get low

appraisals. For example, one Black homeowner received an appraisal

more than double the original, after removing family photos, Black art, and

books from her home.

If you believe your home has been unfairly appraised because of race or

national origin, that could violate the Fair Housing Act. Contact HUD at

HUD.gov/fairhousing – that’s HUD.gov/fairhousing. Everyone has a right

to fair housing.

A public service message from HUD in partnership with the National Fair

Housing Alliance"

https://causewaypsa.com/EPK/65056_HUD_Radio_EN/HUD_EPK.pdf

HUD, NFHA is basically defaming all real estate appraisers calling them racist. This has to be unconstitutional for the government to spend money on these "ads" to spread racist falsehoods. Reseach based on their own data proves this is false. AEI's research showed there is no racism in appraisal values. 

ORIGINAL: The private nonprofit group National Fair Housing Alliance NFHA  promotes the false narrative about alleged racist, biased real estate appraisers, lenders, AMCs to get donations, grants and millions in legal settlements per year. They falsely promote fake debunked papers about race and home values. Currently they're running advertisements falsely stating that real estate appraisers lowball blacks and Latinos. Private NFHA brings in $30,000,000 a year in donations and has $23,000,000 in assets in 2021. They're probably bringing in double that today in 2024 because of a recent 2022 $53,000,000 settlement from Fannie Mae and 2022 $4,000,000 settlement from Redfin. EIN 52­1676364 Phone (202) 898 ­1661

Here is their main profile in Guidestar. https://www.guidestar.org/profile/52-1676364

Here is their most recent IRS form 990 for 2021. 
https://pdf.guidestar.org/PDF_Images/2022/521/676/2022-521676364-202322239349301757-9.pdf

2023 audit shows $28M assets.
https://projects.propublica.org/nonprofits/display_audit/2023-09-GSAFAC-0000045422

They became a nonprofit in 1990. Lisa Rice is the CEO. They're headquarters are in Washington, D.C. but they're not part of the government. HUD refers people to NFHA to do their work filing complaints but they aren't a contractor. HUD runs ad campaigns about fair housing with NFHA. HUD did award over $30,000,000 in Fair Housing grants in 2024 alone to NFHA type programs. In 2021 they got a huge increase in litigation settlements i.e. $17,000,000 with legal costs of about $500,000. I wonder if they get pro bono lawyers to help them for free so they make more profit. In 2022 they got $53,000,000 from Fannie Mae racial discrimination settlement. They are clearly motivated to shake down appraisers, lenders and AMCs for money. It's been a huge financial boon to sue people to get them to cough up a settlement to end litigation, harassment, defamation and bad press caused by NFHA and their national press releases, conferences and misleading articles and videos. NFHA gets donations and press just from the press releases about their frivolous meritless lawsuits. They include a donation link in the press releases.

Nonprofit doesn't mean there are no profits or they aren't motivated by money. The main employees and sometimes board members generally get generous salaries, bonuses and perks. They are motivated by the money, power and prestige. The nonprofit sometimes donates to other groups which are generally friends of the main employees. They sometimes hire friends of the CEO, husbands, wives, children. Many nonprofits are actually just for profit businesses in disguise who don't pay taxes. A prime example is Shedd aquarium vs Sea World. They're both aquarium business with sea animals doing tricks which bring in about a billion per year. Shedd is a nonprofit and Sea World is a business doing the exact same thing. Here's an article I wrote about that. 

Lisa Rice CEO makes almost $300,000 a year. Catherine Cloud the COO makes almost the same. They spend $3,000,000 in wages. They spend $500,000 on conferences and $250,000 just at the Hyatt Hotel. They receive grants from the government after paying $500,000 to lobby the government.


Have you seen these ads which NFHA, HUD run in major magazines, websites and on TV?  They are very deceptive. American Enterprise Institute AEI proved that appraisers don't lowball anyone let alone blacks and Latinos. First time buyers in lower income areas buying lower priced homes are more likely to be black and Latino because of the income gap. The real estate purchases are more likely to have concessions for repairs and closing costs in these areas. This is why some appraisal values are sometimes 3% lower than contract value. The contracts include the concessions for repairs and closing costs which pads the sales price by about 3%. Appraisers have to adjust for concessions which lowers appraisal value by the concession amount for repairs and such.








I just realized that NFHA has done advertisement campaigns in the past with HUD. I just saw a full ad with HUD disclaimer on the bottom of one ad.




I couldn't read the fine print in the ad I originally posted above. HUD is working with NFHA on these misleading ads. The block of text after "Everyone has a right to fair housing" could say "A public service message from the U.S. Department of Housing and Urban Development in partnership with
the National Fair Housing Alliance. The federal Fair Housing Act prohibits discrimination because of race, color, religion, national origin, sex, familial status or disability. For more information, visit www.hud.gov/fairhousing." It still makes it seem that private NFHA is part of the government when it's not. 

Here is their income from settlements, shakedowns.


NFHA stated that appraisers lowball blacks and Latinos in the US. This is false. AEI proved with the government's own data that appraisers aren't lowballing anyone, see links below. The data NFHA used for this false statement was based on robot appraisals. No appraisers were involved. AEI debunked Andre Perry's false and misleading paper. It was not peer reviewed research. This is again correlation and not causation. Blacks, Latinos make less money than white people. If you make less money, you have less money and you will buy/own a lower priced home in a lower priced area. It's the income gap. Same thing happens to lower income whites, Asians ... everyone. Blacks, Latinos own lower priced cars for the same reason. Will they also blame that on real estate appraisers? If they really care about the issue, they should fix the income gap which has nothing to do with housing.

NFHA and HUD are lying to the public about appraisal bias.  FTR anyone can use the HUD logo. HUD clearly states this in their website. I could use the HUD logo in my website and falsely state all non Latino appraisers lowball Latinos so Latinos should only use me, a Latina, for their appraisal. I could probably make money lying like that but I'd never do that because it's dishonest and racist. NFHA makes money being dishonest. They know they are promoting a false racist narrative for their own agenda which is money. 

I just noticed that NFHA has different ads for different publications based on most likely race of viewer based on subscriber statistics. Some are Latinos, blacks, Asians and whites. Is this racist? Should they be sued for racism, targeted racism, colorism like they are suing lenders? They're doing the same exact thing they are accusing others for money. The ad in Sports Illustrated showed white people. The one in a mainly a black magazine showed black people. Who is the racist here?




Just found one of the ads blown up so I can see the text. It is from NFHA and HUD. Click to view larger to read the text. 


Great article by Jeremy Bagott on this same issue. He shows the bigger picture which is the use of the false narrative of the racist biased appraiser to get rid of appraisers to make lenders, AMCs more money. Lenders have lobbied the government to use AVMs, appraisal waivers, value acceptance, hybrid appraisals, desktop appraisals to get rid of appraisers in favor of free robots. These robots are more biased than any appraiser because they don't know or consider all factors in appraisal. Robots don't know condition, view, lot type, actual size, actual bed/bath count, permitted size, upgrades, amenities, specific location...which are main factors in valuation. https://mailchi.mp/c5f09f56ce7f/regulatory-capture-hud-and-a-crony-nonprofit-9382139

References

How Common is Appraiser Bias?
https://www.aei.org/wp-content/uploads/2022/06/How-Common-is-Appraiser-Racial-Bias-An-Update-May-2022-FINAL-corrected-1.pdf?x91208

Exploring Alternative Explanations for Appraisal Under-Valuation
https://www.aei.org/research-products/report/exploring-alternative-explanations-for-appraisal-under-valuation/

The Impact of Race and Socio-Economic Status on the Value of Homes by Neighborhood A Critique of the Brookings Institution’s “The Devaluation of Assets in Black Neighborhoods”
https://www.aei.org/wp-content/uploads/2021/08/Impact-of-Race-and-Socio-Economic-Status-on-the-Value-of-Homes-by-Neighborhood-Presentation-8.5.21-FINAL-v4.pdf?x85095

Racial Bias in Appraisals: New Research
https://www.aei.org/wp-content/uploads/2023/11/Racial-Bias-in-Appraisals-New-Research-FINAL_revised.pdf?x91208

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


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

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

Monday, May 20, 2024

Privacy, Security in Real Estate Appraisals by Mary Cummins Real Estate Appraiser

I was asked to comment about Fannie and Freddie allegedly testing AI image scanning by a foreign business. A previous article stated "Fannie Mae and Freddie Mac’s plan to implement photo recognition AI to analyze appraisal photos. This technology can scan a single photo and extract over 100 data points related to quality, condition, and repairs. For example, it can identify flooring types, appliance models, and even assess light levels in a room." I was told recently "Mortgage giants Fannie Mae and Freddie Mac are reportedly “bench-testing” an arrangement with a foreign AI firm in which the offshore firm will data-mine millions of images showing the personal spaces of U.S. homeowners and tenants." The article is linked below.

https://appraisersblogs.com/fannie-n-freddies-offshore-gambit-imperils-privacy-of-millions/

My comment is at the end here.

“Interior photos show the location of valuables, safes, guns, security systems, security cameras, power main, children’s rooms, entrances and exits,” said Mary Cummins, a Los Angeles-based real estate appraiser and expert witness. “Appraisers blur out people, photos of people and similar items. Property inspectors do not.

“You could end up having someone in another country looking at photos of your baby in a crib,” said Cummins. “The layout of the home is included in the [report]. Sometimes there is even a 3D photo layout which shows the exact location of the baby’s room and valuables in relation to entrances and exits. This data could end up in the wrong hands directly or through security breaches and pose a threat to the people living in the home.”

A few years ago a couple of AMCs stated that appraisers were not allowed to use appraisal assistants or report writers in foreign countries. The purpose was security of the appraisal data. I have not used any assistants in over 20 years so no worries here. Currently many people allegedly from India offer to write entire reports for appraisers for a couple of bucks. They email all appraisers. I agree that I wouldn't want someone being paid $1 an hour looking at the private personal property and family members of clients. I could see that data being sold directly or shared via a security breach and used for nefarious purpose such as robberies. 

I've appraised homes of celebrities. My photos, diagram, layout show the location of the bedrooms. Most people keep valuables such as jewelry, money, guns, drugs in the main bedroom closet. I've taken photos of safes, jewelry cases, guns, babies sleeping in homes. I would never want those photos shared.

Our reports include information about the security system, video surveillance cameras, security gates, fences, main power box. A criminal could use that data to disable the power, over ride the security system and enter the home. That information should never be shared.

I keep my reports extra secure. I also digitally shred and get rid of them the second I am legally allowed. I don't want to possess any of the reports but I legally must maintain them for a set number of years. This is another reason why I have no paper files. 

If Freddie and Fannie ultimately do this, I think we should be concerned. You'd think a US AI company could probably do this work and add to the US job market. There would at least be some culpability, liability, notification if a US company had a data breach. Generally the real estate appraiser is the one who states there are granite counter tops, marble floors, Saltillo patio tiles and their overall condition. The bank's loan underwriter can clearly see these items and their condition in the photos. They make the ultimate decision. An external identifier is really not needed in order to make the loan. Not only that but you can't tell if granite, marble, tile or wood is fake by a photo. You have to see it up close at an angle and sometimes feel it in person to determine fake from real.

The main value of a home is its location, size, bed/bath count and overall condition. The report doesn't even ask us the C1-C6 condition of individual elements. It doesn't ask us for the model, age of all the appliances. We are only asked for the overall condition of the home rated C1 for new never lived in; C2 virtually new/no repairs or grades needed; C3 normal wear and tear, no deferred maintenance; C4 minor deferred maintenance, some upgrades needed; C5 significant deferred maintenance and C6 severe deferred maintenance. If the property is C5, C6, they are probably not getting a conventional or any loan anyway.

When, if Freddie and Fannie implement such a program, I'll be sure to update the article. In the meantime I feel they should review all appraisals in the US with properly licensed people with full background checks such as real estate appraisers and lenders.

Article by Jeremy Bagott - Certified General Real Estate Appraiser at Bender Rosenthal Inc

Jeremy Bagott is a real estate appraiser and former newspaperman. His most recent book, “The Ichthyologist’s Guide to the Subprime Meltdown,” is a concise almanac that distills the cataclysmic financial crisis of 2007-2008 to its essence. This pithy guide to the upheaval includes essays, chronologies, roundups and key lists, weaving together the stories of the politics-infused Freddie and Fannie; the doomed Wall Street investment banks Lehman and Bear Stearns; the dereliction of duty by the Big Three credit-rating services; the mayhem caused by the shadowy nonbank lenders; and the massive government bailouts. It provides a rapid-fire succession of “ah-hah” moments as it lays out the meltdown, convulsion by convulsion.


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


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

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

Sunday, June 25, 2023

Quality Control Standards for Automated Valuation Models, AVMs, Comment by Mary Cummins

RIN-2590-AA62, fannie mae, freddie mac,mary cummins,real estate appraiser, appraisal,avm, automated valuation method, dodd frank act,1125,los angeles,california
RIN-2590-AA62, fannie mae, freddie mac,mary cummins,real estate appraiser, appraisal,avm, automated valuation method, dodd frank act,1125,los angeles,california


Type:Notice of Proposed Rulemaking

Number:RIN-2590-AA62

Group:Fannie Mae; Freddie Mac

Comment: Quality Control Standards for Automated Valuation Models

Comment: Quality Control Standards for Automated Valuation Models RIN-2590-AA62

This is a comment letter about the proposed change in the Dodd Frank Act section 1125. 

I'm a certified and licensed real estate appraiser with over 40 years of experience. Automated Valuation Models (AVMs) should NOT be used by mortgage originators and secondary market issuers in determining the collateral worth of a mortgage secured by a consumer’s principal residence or any real property. The main reasons are because they are not reliable indicators of market value, the data can be manipulated and there are conflicts of interest.

AVMs are not accurate because the AVM never sees the actual property and doesn't know all its attributes. The actual size, effective age, condition, amenities, view, lot type, specific location in a neighborhood ... are not known or considered. These factors can affect the value by up to 100%. There is no quality control that can account for vital missing data which can only be known by a live licensed appraiser. AVMs are GIGO, i.e., Garbage In Garbage Out. In this case there just isn't enough data going into the valuation to make it accurate.

Dodd-Frank Act added section 1125 to the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA); that section requires that AVMs meet quality control standards designed to: (1) ensure a high level of confidence in the estimates produced by automated valuation models; (2) protect against the manipulation of data; (3) seek to avoid conflicts of interest; (4) require random sample testing and reviews; and (5) account for any other such factor that the agencies determine to be appropriate. This letter is a comment on the change in section 1125.

AVMs don't ensure a high level of confidence in the home value estimates produced. They don't protect against the manipulation of data. There is a conflict of interest. AVMs currently can only consider address, tax size, tax bed/bath count, original tax age, pool/no pool and site size at most. Sometimes not all of this information is available. AVMs don't know if the property still exists or was burned down and demolished last year. AVMs don't know if it's in original 100 year condition with deferred maintenance or if the property was fully renovated, upgraded and expanded. AVMs don't know if the property is next to a water tower, power line, dump site or major freeway.

AVMs are even less accurate if the property is older, over/under improved, fair C5 or very good C1 condition, has a view or no view, is in an area with few recent sales or varies from the average home. Even the AVMs owners such as CoreLogic, Zillow,... state the AVMs are flawed and no substitute for a real estate appraisal by a licensed appraiser. Below is the disclaimer of Zillow.

"The Zestimate® home valuation model is Zillow’s estimate of a home’s market value. A Zestimate incorporates public, MLS and user-submitted data into Zillow’s proprietary formula, also taking into account home facts, location and market trends. It is not an appraisal and can’t be used in place of an appraisal."

As a real estate appraiser with over 40 years of experience I look at the different AVM values after I have finished an appraisal just for comparison. I can definitely state that AVMs are not a reliable indicator of value. I've seen AVMs state $2,000,000 value when the home just sold for $35,000,000 and appraised at $34,500,000. I've also seen AVMs state $1,500,000 value when the home just appraised at $500,000. The only time I've seen AVMs be close to accurate is when they are for average newer tract homes in average condition near median neighborhood values in an area with a sufficient number of recent sales. Even then they don't match actual market value.

Here is but one example. There are two identical homes on the same block in a development built in 1950. One is in original condition with deferred maintenance and no view. The other has been fully renovated, upgraded with an addition and has an ocean view. The difference in value would easily be 50% using an experienced appraiser. For a good measurement system, the accuracy error should be within 5%. AVMs are not accurate. There is no confidence in their valuations.

The data used in the AVMs can be easily manipulated. Zillow and other AVMs allow the homeowner, anyone, disgruntled ex tenant to edit the data for a property. If you edit the size, condition or other characteristics of the home, you can drastically change the value. The data can also be manipulated by Multiple Listing Service (MLS) data. Some AVMs consider MLS size, bed/bath count, view... As a real estate appraiser and past broker I can definitely state that MLS data is not accurate. Agents want to sell homes so they make them appear larger and newer. They Photoshop out power lines, water towers, freeways from the photos. They digitally stage them with pools, new lawns, new kitchens...which don't exist. 

The AVM doesn't see the home or view so it values them the same if they are the same size in the same area. The person who owns the home in original condition will be happy because it will appraise over market value. The person who owns the upgraded home with the ocean view will not be happy because now they have to apply for a different loan with a full appraisal in order to get a higher loan or lower rate. I've been in this exact situation many times. The owner ends up paying two "appraisal" fees even though the first was just an AVM. They also waste time.

The ability to manipulate the data creates huge conflicts of interest. Sellers, agents want to sell home for the highest price. AMCs, Lenders want the highest value so they can easily make the loan to make money. Zillow is both an AVM and seller, agent. CoreLogic sells AVM data to Lenders and others. They want to make the deal to make money. The independent real estate appraiser only cares about actual market value. They don't make money on the transaction besides a small appraisal fee which is paid if they hit the value desired by the borrower or not.

Have we learned nothing from the Zillow fiasco? "The evidence is there for anyone wishing to look. In a disastrous bet made by Zillow – one in which the company staked its future on investing in residential real estate based on its own algorithms – the company lost $32 billion in market capitalization from February to November 2021. What did Zillow learn about its “Zestimates” when its own money was at stake?" (https://appraisersblogs.com/dazzled-by-wizardry-federal-mortgage-regulators-ignore-zillow-debacle )

I've studied AVMs in depth as have others. There is a lot of research already done on the inaccuracy of AVMs. Here's an article I wrote about AVMs which cites some of that research. https://mary--cummins.blogspot.com/2022/03/what-is-avm-automated-valuation-method.html 

The Dodd Frank Act is the result of the 2008 Great Recession and Financial Crisis. The purpose was to protect consumers, banking and our economy so that would never happen again. The public will lose trust in the real estate industry, mortgage market and mortgage backed investments. This will negatively affect the real estate industry, banking industry, stock market and our economy. Please, do not use AVMs to value property which will be collateralized by loans. 

Sincerely,

Mary Cummins
California Certified Real Estate Appraiser

My letter finally showed up in the comments

https://www.mortgagetranslations.gov/sites/default/files/rulemaking_comments/Attachments/16263/Mary%20Cummins%20letter%20AVM%20Comment%2006252023.pdf

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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Monday, April 10, 2023

HUD only cares about appraisals UNDER contract price which is dangerous by Mary Cummins

appraisal value over under contract sales price, mary cummins, real estate appraiser, real estate appraisal, fannie mae, percent sales price, contract price, appraisal, value
appraisal value over under contract sales price, mary cummins, real estate appraiser, real estate appraisal, fannie mae, percent sales price, contract price, appraisal, value

Dave Towne sent out this linked article about bias and appraisal gap.

"The article below was in the Inside Mortgage Finance Publications e-newsletter on 4/06/23:

"FHFA Data Fueling Looks into Appraisal Bias

dhollier@imfpubs.com

The Federal Housing Finance Agency is a is a critical provider of the data necessary for oversight, enforcement and research, FHFA Director Sandra Thompson noted during a discussion in late March.

According to aggregate statistics from the Uniform Appraisal Dataset released by the FHFA, roughly 57% of appraisals were above the contract price in 2021. Just 15.2% were below the eventual sale price, but these are the under-valuations that could possibly reflect bias.

And the important datum here is that this percentage is growing. In 2013, only 8.4% of appraisals came in under the contract price.

In addition to providing data, Thompson noted that FHFA has coordinated with the Department of Housing and Urban Development, the Consumer Financial Protection Bureau and the Department of Justice “to provide additional information for fair lending enforcement and oversight.”

If this actually reflects the true thinking of Ms. Thompson, she has aligned with so many others who believe SALE PRICE is immutable, and is the ultimate indicator of Value, and apparently, of bias, when not accepted as gospel by the appraiser.  My gosh, what a misguided opinion!

Apparently Ms. Thompson didn’t see, experience or understand what happened during the ‘pandemic era’ in mid-2020-early ‘22, when overly emotional, and irrationally exuberant buyers paid astronomical prices for homes way above what their actual value was.  The same thing happened in 2006-2008.....but it wasn’t considered ‘bias’ then due to the different political climate and attitude at that time.

Conversely, how can it be said that valuing a property lower than its eventual sale price based on current market evidence is tantamount to BIAS?  And, if 57% of the appraised values were ABOVE the sales price, couldn’t that also reflect BIAS?  Seems to me that if one comparison in one direction is considered bias, the other in the opposite direction can be equally judged the same.

To better understand this concept, look up the definition of bias.

The political drumbeat of appraisal bias just because an appraisal Value doesn’t reflect Sales Price is blatantly wrong-headed.  In fact, it reflects internal personal bias at worst, and exhibits a definite lack of understanding of the appraisal process, by the person promoting such falsehoods.

More appraisers should stand up and challenge Ms. Thompson’s assertions."

I agree that we should be looking at the over valuations. That is probably where most of any alleged "bias" would be. In the major media cases of alleged bias the first lower appraisal is considered the wrong one when it was actually the higher second appraisal that was wrong and above market value. 

The second higher appraisals were influenced, biased by the AMC, Lender and borrowers who stated the first appraisal was too low. The second appraiser knew there'd be a complaint or lawsuit if they didn't come in high. Clearly the second appraiser was influenced to come in over market value. In the appraiser's eyes he has much to lose coming in at market and much to gain by coming in above market. That's all fine until the borrower goes under and the gov reviews the appraisal in default which they stated they will do. This is a concern because the current economy and real estate market is going down. People are losing jobs as interest rates rise. More homeowners could end up under water and in default. 

Things are a little similar to the beginning of the Great Recession. We all know what happened after the Great Recession. The gov pushed appraisers to come in high to meet higher values. After values dropped the government blamed appraisers! We report values. We don't set them. The gov caused the huge run up with reduced financial regulations and programs which helped lower income people take on loans they couldn't easily afford. The gov caused great financial damage to the people they said they were helping.

Image above came from this article
https://www.fanniemae.com/research-and-insights/perspectives/opportunities-improve-value-appraisals

Nice quote from the above linked article, "Reforms following the 2008 housing crisis attempted to improve the independence and accuracy of appraisals, and some early research indicated these reforms were marginally successful, with the percent of transactions confirmed falling from a high of 98 percent in 2007 to 94 percent in 2009. Confirmation rates, however, have since drifted back up as we have moved further away from the financial crisis."

So was it the financial crisis or reforms which caused change in % of appraisals meeting contract price?

What's interesting is there were appraisals done pre and post contract. When the appraiser knew the contract price, the value was more likely to meet or exceed that contract price. Maybe appraisers shouldn't know the contract price because it clearly influences them. Fannie Mae even makes that suggestion in their article.

Fannie Mae knows the industry and what's really happening. They can't speak freely because they are dependent upon HUD and the government no matter how "independent" they claim to be. For this reason they kiss HUD's ass and support all this false alleged appraisal bias. AEI's research has shown there is no appraisal bias based on race in the government's own data. HUD still falsely insists there is for political reasons. 2024 elections are coming. I bet Dem candidates will still be hawking racial appraisal bias in their campaigns to get the black, brown vote. They will claim they already solved most of the alleged bias but will continue to do more.


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.


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Monday, August 22, 2022

Resources for Appraisers to Legally Complete Appraisal Assignments, Mary Cummins Real Estate Appraiser

hud, fannie mae, freddie mac, uspap, appraisal foundation, gse, fha, mary cummins, real estate appraiser, real estate appraisal, los angeles, california
hud, fannie mae, freddie mac, uspap, appraisal foundation, gse, fha, mary cummins, real estate appraiser, real estate appraisal, los angeles, california


Below are links to resources to help appraisers legally complete appraisal assignments. They are statutes, rules, regulations and the law related to appraisal practice from HUD/FHA, GSE's Fannie Mae and Freddie Mac and other resources. 

The Appraisal Foundation – Appraisal Standards Board (ASB), USPAP, Valuation Advisory Statements.

Appraiser Resource Pages

Guides and Handbooks

Appraisal and Property FAQ

Uniform Appraisal Dataset (UAD) – Appendix D and other resources

Unacceptable Appraisal Practices and Fair Housing

House Price Indices

Internal Revenue Service

*Links and linked data are subject to change. This article is as of the date of posting. 


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


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

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