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 low income. Show all posts
Showing posts with label low income. Show all posts

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
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/

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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Wednesday, September 18, 2024

California Bill CA AB3068 Adaptive reuse: streamlining: incentives. Commercial Adaptive Reuse to Residential by Mary Cummins Real Estate Appraiser


UPDATE 09/27/2024 Governor Gavin Newsom vetoed the bill. Will they try again next legislative session or just give up? We really need a streamlined adaptive reuse process to build more housing without all these extra limiting requirements. And this is exactly why we have a housing crisis. Frustrating.

"While I strongly support efforts to address California's housing crisis by promoting adaptive reuse projects, this bill raises several concerns. The proposed compliance and enforcement mechanisms for labor standards, including the issuance of stop-work orders for any violations, represent a significant expansion beyond existing law, which limits this remedy to a narrow subset of violations, such as those posing immediate threats to health and safety. Moreover, the bill lacks clear procedures for contesting violations or addressing noncompliance, creating considerable uncertainty that could lead to delays, and increased costs, potentially making projects financially unviable - ultimately undermining the bill's goal of increasing housing production."  

I agree the bill as written would not have encouraged reuse because there were so many restrictions.

 https://www.gov.ca.gov/wp-content/uploads/2024/09/AB-3068-Veto-Message.pdf

ORIGINAL 09/18/2024 : AB 3068 would allegedly encourage and expedite the process of converting office space to mixed-use housing projects in city centers like downtown Los Angeles, California. This bill encourages counties and cities to have a plan to streamline the process under certain specific conditions with lots of caveats. In reality it appears to add more red tape making it ineffective and pointless.

This looks like "concepts of a plan" to me. In fact there are so many restrictions and requirements that I think the bill makes it financially unfeasible so it may not help at all. I also don't see a time table or enforcement procedures so this may be worthless. It may just improve the politician's image ala "we're solving the housing crisis!" 

These silly bills and all this red tape are the reason we have a housing crisis in California. Developers are hobbled by the restrictions. They'd lose millions if they built a building that complied with all the restrictions so it'll never happen. The notion of the bill starts out okay but by the time it reaches the Governor's desk you need to jump through a million impossible hoops, every planet in the universe must align and you must agree to lose millions of dollars for the next 100 years. 

From KRON4 “California’s downtowns are desperate for ways to inject vitality into their streetscape,” said Haney, who serves as chair of the Select Committee on Downtown Recovery. “While the demand for living downtown is at an all-time high, many urban centers simply lack the available housing. If we are serious about jump-starting the economic engine of our cities, we need to remove the red tape that makes office to housing conversions nearly impossible.” 

From the actual bill  My summary: Building must be less than 50 years old, must use Union labor, must preserve street facing facades, cannot be subject to a Conditional Use Permit CUP, must have low and mid income housing...

"The Planning and Zoning Law requires each county and city to adopt a comprehensive, long-term general plan for its physical development, and the development of certain lands outside its boundaries, that includes, among other mandatory elements, a housing element. That law allows a development proponent to submit an application for a development that is subject to a specified streamlined, ministerial approval process not subject to a conditional use permit, if the development satisfies certain objective planning standards, including that the development is a multifamily housing development that contains two or more residential units.

This bill would deem an adaptive reuse project a use by right in all zones, regardless of the zoning of the site, and subject to a streamlined, ministerial review process if the project meets specified requirements. requirements, subject to specified exceptions. In this regard, an adaptive reuse project, in order to qualify for the streamlined, ministerial review process, would be required to be proposed for an existing building that is less than 50 years old or meets certain requirements regarding the preservation of historic resources, including the signing of an affidavit declaring that the project will comply with the United States Secretary of the Interior’s Standards for Rehabilitation for, among other things, the preservation of exterior facades of a building that face a street, or receive federal or state historic rehabilitation tax credits, as specified. The bill would require an adaptive reuse project to meet specified affordability criteria. In this regard, the bill would require an adaptive reuse project for rental housing to include either 8% of the unit for very low income households and 5% of the units for extremely low income households or 15% of the units for lower income households. For an adaptive reuse project for owner-occupied housing, the bill would require the development to offer either 30% of the units at an affordable housing cost to moderate-income households or 15% of the units at an affordable housing cost to lower income households. The bill would require at least one-half of the square footage of the adaptive reuse project to be dedicated to residential uses. The bill would provide, among other things relating to projects involving adaptive reuse, that parking is not required for the portion of a project consisting of a building subject to adaptive reuse that does not have existing onsite parking. The bill would authorize an adaptive reuse project subject to these provisions to include the development of new residential or mixed-use structures on undeveloped areas and parking areas located on the same parcel as the proposed repurposed building, or on the parcels adjacent to the proposed adaptive reuse project site if certain conditions are met."


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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Thursday, April 25, 2024

California Bill ACA 10 - "Housing is a Human Right" - Depends on who is Paying for it , by Mary Cummins


Bill Assembly Constitutional Amendment ACA 10 has been proposed to state that housing is a human right in California. Below is from the bill.

"Article  XXV Right to Housing

SECTION 1. The state hereby recognizes the fundamental human right to adequate housing for everyone in California. It is the shared obligation of state and local jurisdictions to respect, protect, and fulfill this right, on a non-discriminatory and equitable basis, with a view to progressively achieve the full realization of the right, by all appropriate means, including the adoption and amendment of legislative measures, to the maximum of available resources."

Below is from supporters of the bill.

"California, a safe, affordable home is currently a privilege reserved for those who can afford the state’s skyrocketing housing costs. Our state is home to a quarter of all unhoused people in the nation, and more than half of all unsheltered people. Due to generations of racist housing policy, these burdens of housing insecurity fall hardest on Black Californians.

Assembly Constitutional Amendment (ACA) 10 will recognize that every Californian has the fundamental human right to adequate housing. Here is what this would mean in our state:

An obligation on the part of the local and state governments to ensure that all Californians have access to adequate housing;

A commitment to ensuring equitable access to housing that is not subject to any form of discrimination; and

A recognition that the right to housing is not merely a roof over one’s head, but rather adequate housing is permanent, habitable, affordable, and close to employment, healthcare, and schools."

My issue with this bill is who will be paying for it? Are they talking about government housing? We all know the government got away from public housing because they turned into slums in some areas. They are more expensive to run than regular apartments because of government administrative fees of at least 15%. They were rife with corruption because of the government bidding system. They concentrated lower income, disabled, elderly people, POC into specific high density areas which ended up becoming high crime with limited services. Some even said it was segregation and discrimination which it was indirectly because blacks, Latinos, elderly, disabled make less money than whites, younger people and able bodied.

If they are talking about forcing private landlords to subsidize public housing, I'm totally against this. Rent control has harmed the economy. If we didn't have rent control in Los Angeles, the city would have billions in property, income, transfer tax which they could use to subsidize housing for homeless. I fully support fair and legal eviction control. I support all rental housing to be safe and legal. I don't support forcing private individuals paying most of the rent of anyone who happens to score a rent control unit. I've seen people paying $216/month for a two bedroom in Santa Monica. The renters aren't even low income but high income. They don't give rent control units to low income so the program doesn't even serve a purpose. Generally people would move to a cheaper area when they can't afford the rent. That's what commercial and regular tenants have done for years. I'm sure if private homeowners were forced to allow homeless people to live in their homes, they would also oppose the forced taking of private real estate for public use without proper compensation.

What the government needs to do is allow developers to build housing. This means not allowing NIMBYs to stop projects that benefit the community. If the government hadn't stopped housing development for the last 50 years, we'd have enough affordable housing today. Any housing we build today costs too much because of today's high cost of land and construction. If they were built 50 years ago, they'd be affordable today because they'd be a B, C class building.

Government decided to force developers to build expensive units then forced them to rent some or all to low income earners. This makes no sense. It's not sustainable because there is no profit or incentive to build those units. It's unconstitutional for the government to force only one industry to subsidize lower income people. You don't see the government forcing grocery stores, water vendors, doctors, dentists, car dealers, clothing retailers to sell for a loss. We all fundamentally need food, water, medical care, cars sometimes and clothes.

If the bill passes, I believe it'd probably just be lip service. I see no way they can figure out a fair way to build affordable or free housing today in California. All the ways they've tried so far haven't worked. You can't have rent control, NIMBY power, forced private low income housing and affordable housing for all. Something has to give.

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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