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 maxine waters. Show all posts
Showing posts with label maxine waters. Show all posts

Tuesday, March 29, 2022

March 29, 2022 Hearing "Devalued, Denied, Disrespected: How Home Appraisal ... by Mary Cummins

Devalued, Denied, and Disrespected: How Home Appraisal Bias and Discrimination Are Hurting Homeowners and Communities of Color, Maxine Waters, Mary Cummins, Tobias Peter, AIE, Fannie Mae, Freddie Mac, Andre Perry, PAVE Task Force, Committee on Financial Services, bias, racism


"Devalued, Denied, and Disrespected: How Home Appraisal Bias and Discrimination Are Hurting Homeowners and Communities of Color." Tobias Peter is doing a great job hammering home facts and actual research. Sadly some politicians are ignoring the facts and running with the fake research and misleading analysis by Andre Perry, Freddie Mac and Fannie Mae cited in the PAVE report. So is private activist group Fair Housing Alliance. It's clear they know they are hurting blacks, Latinos, poor people and single mothers with their actions. Government actions based on the false research is causing financial damage to poor people. Beyond sad and heartbreaking. Appraisers see the results of this. I appraised pre-foreclosure, foreclosure homes during the great recession. 

I'm taking notes best I can as I'm sick from a vaccination. Pics from the meeting which ran 10:00 a.m to 1:30 p.m. I'll post more later. Video below.

One thing which is abundantly clear is that some of the Representatives don't even know who some of the speakers are. They keep asking private AMC Dean Kelker why he/they don't recruit people in college to automatically be appraisers. He keeps saying they need a license and experience. They think he is part of the government oversight of the industry when he's not.

Maxine Waters is also losing her judgment. She thinks "Realtists" which are just members of the minority organization National Association of Real Estate Brokers should be allowed to be "assessors," think she means appraisers, with no education, license or experience whatsoever. It would be discrimination to allow only this specific group to be appraisers automatically. It also makes no sense and would violate federal and state laws yet she says she's going to do it.

Lisa Rice from the private organization the Fair Housing Alliance keeps citing Andre Perry's false and misleading paper like the bible. She knows it's false yet she uses it to promote her personal agenda which is funds, grants for her nonprofit. She doesn't care that she's hurting poor people and POC. 

Pledger Bishop of the private organization Appraisal Institute AI is being political. He keeps saying we're working on diversity yet he has nothing to show for it. Representatives keep thinking he's part of government. He's not. He has no power to do anything. 

Many Representatives just get up there and use their five minutes to promote themselves and their political campaigns. Many cite Andre Perry's false and misleading paper even though they've been given Tobias Peter's AEI report showing the actual facts. Home values are directly related to income. Certain socio-economic factors correlate with buying power such as income, credit score, marital status, having children under 18... As I've been saying people buy the homes they can afford in the areas they can afford. Appraisers, Appraisals don't set values. The market does.We merely report it.We most certainly do not devalue homes. AEI's report shows that appraiser bias, discrimination is not a wide spread or systemic issue. Home value is a math formula. 

Pledger Bishop, The Appraisal Institute, AI


Tobias Peter, AEI, American Enterprise Institute, PAVE report, research, Andre Perry paper debunked


Video 3 hours 31 minutes starts at 4 min 30 seconds

https://www.youtube.com/watch?v=vFMs5sTOHhc

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, March 28, 2022

Significance of Maxine Waters' Bill Fair Appraisal Act 2022 by Mary Cummins Real Estate Appraiser




Maxine Water's bill is about more than discrimination. It's also about the complaint process and changing the appraisal regulatory system. The Bill would remove states as the investigatory authority and turns it over to the federal government. If a complaint is filed, the federal government can ask for 24 months of all the appraiser's appraisals. Even HUD complaints only ask for 12 months. This is clearly huge pressure to meet contract price for the borrower even though we appraisers work for the lender. 

ASC stated that TAF isn't accountable to the public. All proposed changes to Standards and Qualifications are public and open for comment. TAF answers questions from appraisers and others for clarification. They are transparent and available.

Based on the Bill ASC will be given new powers and responsibilities when they have a limited track record. For the past six years ASC was supposed to make a national list of all appraisers giving them a unique number. They have received millions of dollars to help accomplish this task yet have never done it. Some appraisers have licenses in more than one state so you can't just add up all of the state licensees. AMCs pay a fee to ASC for each appraiser on their roster. Some appraisers are on more than one roster. ASC has received millions yet has not compiled the list. It makes no sense to give them even more power and responsibility.

It's important to know how many appraisers there are because of the current arguments stating there are not enough appraisers. Most feel the shortage of appraisers is actually just a shortage of appraisers who are licensed and willing to do appraisals for lending purposes. Many don't do lender work anymore because of all the new legislation and layers of extra work.

ASC has also failed to track the national complaint hotline. Now Waters wants the ASC to be in charge of investigating 24 months of appraisals in complaints. If ASC can't do the former, they clearly can't do the later. The Dodd Frank Act put ASC in charge of developing AVM standards yet ASC has not done this within the last 12 years. There is no reason to give ASC more responsibilities when they can't even handle their current responsibilities. 

Jim Park of ASC stated in congressional testimony last Thursday in front of the US Senate that Appraisers had “…driven up service times and appraisal fees to unacceptable levels….” top of page 3 https://www.banking.senate.gov/imo/media/doc/Park%20Testimony%203-24-22.pdf 

This is false. As an appraiser I received $300 for an appraisal in 1984. 1990 it was $350. It's still just about the same amount over 30 years later. Because of the Dodd Frank Act AMCs were mandated to be the middle man between lenders and appraisers. They raised the fees and now take a huge chunk. The AMC receives about $650-$1,800 and pays the appraiser about $350. The AMCs charge whatever they like then make appraisers bid for the assignment. They take the lowest bid and pocket the rest as profit. Dodd Frank mandated AMCs is the reason why fees are higher today. The fees paid to the appraiser have not kept up with inflation even though the amount of work required today is at least twice as much. 

Mr. Park made a discriminatory, ageist statement when stating old appraisers are hard to teach new information. I'm 55 and I always instantly embrace all new technology. I used one of the first laser measuring devices in the 1980's. I use LiDAR today. I ditched the typewriter and paper forms for computer software before any other appraiser I know. I had one of the first real estate websites on the internet in 1997. I had one of the first digital cameras. I use mobile appraisal software. I've tested the new 3D home interior scanners. I made my own computer program to pull MLS data in 1004 format in the '90's. Appraisers love new technology because it can make our job faster and better. We teach ourselves new tricks. 

HUD themselves are responsible for a shortage in the number of appraisers who can complete mortgage lending appraisals. After passage of the Housing and Economic Recovery Act of 2008 (HERA), the Dept of Housing and Urban Development no longer permitted the “Licensed” category of real estate appraisers to conduct appraisals, instead only the “Certified” category of real estate appraisers could complete appraisals for the FHA Insurance program. Before HERA passed, there were 30,286 Licensed Appraisers. Today, there are only 7,321 Licensed Appraisers, because the majority of lenders moved away from hiring Licensed Appraisers after HERA was passed.

HUD has never released documentation showing the number of alleged discrimination complaints against appraisers. Why is the cause of the lack of transparency? They claim to record every complaint they receive. They even release annual reports. Those annual reports have not noted instances of discriminatory appraisals. Why are they not disclosing discrimination complaints? It is likely because, up until last year, the number of complaints has been too few and likely dismissed. It is reported they have roughly 100 allegations currently, none of which have been resolved in the mandatory 100 days. Why are they holding on to the cases?

I was forced to send in multiple FOIA requests to get the results of investigations which I'm following here on my blog, i.e Austin v Miller in Marin, California; Carlette Duffy in Indianapolis, Indiana, Sanders Horton in Jacksonville, Florida and Cora Robinson in Oakland, California. This is the standard reply to my requests. They state I must get the complainant to sign a notarized statement with their name, date of birth, nation of origin, home address ... stating they agree to the release of the documents and information. Of course they will say no. I've been making FOIA requests for over 25 years and have never had a reply like this ever. Some appraisers and I are now contemplating fundraising to hire an attorney to sue HUD to get the results of the legitimate FOIA requests. In the meantime I appealed the FOIA denials. HUD also is the first agency to ever force me to make multiple initial FOIA requests for the same information. This is unprecedented lack of transparency and a violation of the FOIA. 

The ASC study was actually made by the advocacy group the National Fair Housing Alliance NFHA. They are a private non-profit organization. They were given $250,000 to study the Standards and Qualifications for appraisers. Instead their report is on the appraisal regulatory structure and TAF's authority. The ASC is responsible for monitoring the states and their enforcement procedures. TAF sets the standards and qualifications. Blaming TAF for ASC's failure of enforcement mechanisms makes absolutely no sense. 

No member of the ASB or the AQB was contacted or interviewed for the new Bill. There are errors in the report that Jim Park (ASC) would know are obviously incorrect, yet he let the study be published to support his narrative. The NFHA Advocates who authored the study indicated they had insufficient time to complete extensive research for this study, yet were able to draw conclusions, nonetheless.

All major legislation passed that affects appraisers has had a significant negative consequence to appraisers and the appraiser’s business. The appraiser community has not had a voice at the table to provide expertise about the valuation profession. I contacted every member of the PAVE Task Force asking to be involved, to attend meetings, to receive documents and communications as a Latino woman appraiser with over 35 year of experience. I didn't even get a reply. I was blocked from even being informed about what was happening. I'm now forced to send in another FOIA request just to get public information which should have been released.

While Jim Park was an appraiser he's not actively appraising today. He has no idea what appraisers deal with on a daily basis. Prior to the Dodd Frank legislation, there were appraisers willing to function as supervisors and the trainee/supervisor model was functioning, After Dodd Frank, most appraisers had to shut down their small businesses and become individual single-owner shops. Lenders, after Dodd Frank, largely stopped allowing trainee appraisers to inspect the property without the supervisor present, yet lenders will gladly hire third-party non-appraisers to collect data on the property. The lenders do not allow the trainee model to add value to an appraisers’ work. You cannot blame the appraisers for a system that does not allow a new generation of appraisers to be trained.

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

Friday, March 25, 2022

IMPORTANT! Proposed Bill by Maxine Waters titled "Fair Act of 2022" - Meeting March 29, 2022

federal valuation agency,fair act of 2022,real estate appraiser,real estate,bill,financial services,maxine waters,firrea,HUD,mary cummins,US house committee,appraisal,discrimination,
federal valuation agency,fair act of 2022,real estate appraiser,real estate,bill,financial services,maxine waters,firrea,HUD,mary cummins,US house committee,appraisal,discrimination,

Maxine Waters is proposing a new Bill to establish a new Federal agency to oversee appraisers and the appraisal industry. Maxine Waters wants to amend the The Financial Institutions Reform, Recovery, and Enforcement Act of 1989 to basically get rid of ASB, AQB, ASC and TAF as we know them replacing them with the new "Federal Valuation Agency." The basic summary is as follows:

"To establish an independent agency to be known as the Federal Valuation Agency and real estate valuation standards and appraiser criteria, including promoting a fair, unbiased, transparent, repeatable valuation process, and for other purposes."

"This Act may be cited as the ‘‘Fair Appraisal and Inequity Reform Act of 2022’’ or the ‘‘FAIR Act of  2022’’. 

"The Financial Institutions Reform, Recovery, and Enforcement Act of 1989 is amended—(1) in section 1110(1) (12 U.S.C. 3339(1)), by striking ‘‘Appraisal Standards Board of the Appraisal Foundation’’ and inserting ‘‘Federal Valuation Agency, by rule’’; and (2) in section 1116 (12 U.S.C. 3345)—(A) in subsection (b), by striking ‘‘ or endorsed by the Appraiser Qualification Board of the Appraisal Foundation’’ and inserting ‘‘, by rule, by the Federal Valuation Agency’’;

This bill is frighteningly reckless and irrational. I can't believe I actually have supported Maxine Waters for so many years. I even fought and protected her against the person who campaigned against her and was viciously attacking her with falsehoods. I actually have been trying to meet with her because she's been posting things about appraisers and the industry which are totally false and bizarre. I spoke with her office twice but they wouldn't set a meeting. I sent an email politely correcting some of the bizarre and false things she said. 

In the documents Maxine Waters repeatedly refers to Latinos as "Latinx." She even refers to "Latinx census." I'm a Latino. Most Latinos don't like being called "Latinx." The word is an English construct for naming "others." It makes no sense relative to Spanish. "Latinx" is not in the census records. This is insulting. Clearly a non-Latino wrote this Bill for Maxine Waters. (Ref. "Many Latinos say 'Latinx" Offends them." Ref. 2021 Gallup Poll 96% Latinos do not like Latinx )

I'll be writing a letter to the Committee and sending it tomorrow. You can write one and email it to FSCDems@mail.house.gov . Use any of this information. Copy/paste. I don't care. I will also be emailing everyone individually on the Committee. I'll post the letter and email addresses tomorrow. This bill is totally crazy. 

Memorandum about meeting "Devalued, Denied, and Disrespected: How Home Appraisal Bias and Discrimination Are Hurting Homeowners and Communities of Color" US House Committee on Financial Services.

https://docs.house.gov/meetings/BA/BA00/20220329/114561/HHRG-117-BA00-20220329-SD002-U2.pdf

My comments on the falsities in this document in order. This was clearly written by someone with a personal agenda who intentionally did not use independent research or any legitimate research for that matter. 

First some real facts. Whites make and have more money than blacks, Latinos. For this reason whites buy and own more expensive homes than blacks, Latinos. People buy what they can afford. For this reason homes owned by whites are worth more than homes owned by blacks, Latinos. This is the actual cause of the wealth gap. It has nothing to do with appraisers and appraisals. If the government wants to close the wealth gap between whites, blacks and Latinos, they need to close the income gap. 

These two statements in the report are true. Currently, the "White homeownership rate is 74.1%, compared to 44.2% for Black families and 48.4% for Latinx families." "White families held 10 times more wealth than Black families and 7 times more than Latinx families in 2016." Waters intentionally doesn't include the cause of these gaps which is the difference in income. White families make almost double at $76,000 and black families only $45,000. When you are only making $45,000 a year there is no disposable income to save to buy a house. You are living hand to mouth. "The disparity is another reason why it's more difficult for Black families to save and build wealth than it is for White households."  https://www.cnn.com/2021/06/01/politics/black-white-racial-wealth-gap/index.html If you can't save money to buy a house, you won't own one. You won't benefit from home appreciation if you don't own a house. If a poorer person does buy a house, it'll be a less expensive home appreciating at the lower rate and amount.

Appraisers do not appraise homes of certain types of people less than other people's homes. Appraising is a math formula. That's how the Automated Valuation Methods (AVMs) function. Appraisers use the same exact formula except we have better data because we actually inspect the subject property, neighborhood and see the sold comparables. AVMs don't see any of the properties. They don't even know if they exist. 

Appraisers don't know the color, race, ethnicity ... of the neighborhood, owners/buyers of sold comparables and most of the time even the owner or buyer of the subject property. We don't have color, race, ethnicity ... info in our databases. We wouldn't use it if we did as it doesn't matter when it comes to home value. Buyers, sellers set market value. Appraisers just report it. 

1. Background

A. Waters mischaracterized a paper written by Andre Perry, i.e. "The Devaluation of Assets in Black Neighborhoods: The Case of Residential Property." This paper is not published or peer reviewed "research." It is a personal paper written by Perry to promote his book by the same title. Perry intentionally chose two very different groups to compare. He compared small extremely different samples of areas with 0-1% black people and over 50% black people. Perry then used Zillow zestimate AVM values. We all know how inaccurate Zillow is based on their recent failures. No appraisers or appraisals were involved in the data. Perry committed major statistical areas in his analysis. He never controlled for location. Everyone knows the three main factors in real estate valuation are LOCATION, LOCATION, LOCATION. Many other grave statistical errors were committed. Perry has never posted his data because he doesn't want anyone to review it. The only thing the paper may show is the fact that whites make and have more money than blacks. This goes back to income equality. "Perry conflates race with socio-economic status. When adjusted for SES, the gaps disappear. (Ref. https://www.aei.org/research-products/report/comments-on-the-pave-report )(Ref. This articles shows other major errors in the paper. "

B. Waters misread a Freddie Mac study i.e. Freddie Mac, Racial and Ethnic Valuation Gaps in Home Purchase Appraisals.  Freddie Mac actually stated "First, our analysis has not yet determined the full root cause of the gap." Danny Wiley of Freddie Mac stated "We have not reached any conclusion for cause of the gaps or correlation." The gap could have many causes such as revitalizing areas and condition. AVMs assume average condition, average everything. Perhaps the homes appraised by appraisers over AVM values were in better condition than average, better than average location, better than average view, upgrades... AVMs do not see the property. They don't know the condition or if it even exists. 

AEI replied to Freddie Mac's study.

https://www.aei.org/research-products/report/aei-housing-center-critique-of-freddie-macs-note-on-racial-and-ethnic-valuation-gaps-in-home-purchase-appraisals/

2. Appraisers: Industry Diversity and Alternative Methodologies

Waters again selectively chooses information. While it's true that most appraisers are white the same is true for the US population as a whole and even real estate agents. The spotlight today is only real estate appraisers because of a very misleading paper promoted by Joe Biden, Marcia Fudge and now Maxine Waters. 

3. Appraisals: Evidence of Racial Home Devaluation

A. Waters again mischaracterizes Perry's paper. This is a false interpretation of the skewed data. "A 2018 study by the Brookings Institute (Andre Perry) found that in the average metropolitan area, homes in neighborhoods where the share of the population is 50% Black are valued at roughly half the price as homes in neighborhoods with no Black residents. Further, the study found that differences in home and neighborhood quality do not fully explain the disparities in property values.23 Specifically, the study found that “homes of similar quality in neighborhoods with similar amenities are worth 23 percent less in majority black neighborhoods, compared to those with very few or no black residents” and “across all majority black neighborhoods, owner-occupied homes are undervalued by $48,000 per home on average, amounting to $156 billion in cumulative losses.”

Perry did not control for location which is the most important factor in home value. This is a case of correlation. Blacks make and have less money than whites so they buy less expensive homes in less expensive areas. The home values came from Zillow. Zillow states their zestimates are not appraisals or home valuations. No home was "undervalued" by any amount. There are no "losses." 

B. Waters misstates the results of the Freddie Mac study. "Freddie Mac in 2021 analyzed what share of appraisers produced a significant Black-White and Latinx-White appraisal gap where homes in Black and Latinx census tracts are valued below the contract price compared to those in White census tracts." As stated above Freddie Mac stated they came to no conclusion for the cause of appraisal gaps. This article explains "appraisal gap." This was a comparison in appraisal gaps between two census tract areas and not different races, colors, ethnicities of the buyers, sellers, owners. 

C. Waters misstates the results of the Fannie Mae study. "Fannie Mae found that White homes in both majority-White and majority-Black neighborhoods were overvalued compared against both AVMs while Black homes in each neighborhood type were devalued." Fannie Mae made it's own proprietary AVM and will not disclose their algorithm. There is no "overvalued" in the study. There is only over or under the AVM. AVMs are not accurate. They only consider the most average home in average condition. They do not include views, upgrades, location in a neighborhood, added amenities... This article explains the problems with AVMs. The most likely cause of the differences is again the income, wealth gap between white, black. Whites have more money and buy more expensive homes. They are most likely buying the more improved, upgraded homes with views in the same neighborhood as blacks. 

D. Waters misstates the results of another study. "Federal Housing Finance Agency (FHFA) conducted a key word search for millions of appraisals for transactions backed by Fannie Mae and Freddie Mac and found that individual appraisers included overt references to race, ethnicity, and other prohibited bases under federal fair lending laws in their appraisal reports." From the actual report, "From millions of appraisals submitted annually, a keyword search resulted in thousands of potential race-related flags." That is 1,000/1,000,000 = .001% or 1/1,000th of 1%. This is a minuscule amount. While there should be no such references they did not say or show the references affected the value. One of the alleged race-related words was "gentrification" which the government itself and Maxine Waters use all the time. The correct term is "revitalization" which is a normal real estate cycle.

4. Industry Regulation

Appraisers and the appraisal industry are controlled by Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 about 33 years. ASC is a federal government agency which govern and control the industry. TAF is authorized by Congress as the source for appraisal standards and qualifications. ASB and ASQ are under TAF. Previously Maxine Waters incorrectly stated that the Appraisal Institute controls appraisers and the industry. I had tried to meet with Waters to correct this and many other false statements she's repeatedly made about appraisers and appraising. AI is a private non-profit organization which promotes the appraisal profession. It costs up to $15,000 to become an AI MAI appraiser. AI does not speak for all appraisers but a few. I am not a member.

Waters now wants to start a new federal agency to replace ASC, ASB, AQB and TAF because she doesn't understand how these agencies work. They have been working together since 1989. Now Waters wants to disrupt an entire industry to cater to her friends at the private non-profit Fair Housing Alliance.

5. Administrative Action

A. PAVE Task Force Report

The PAVE Task Force Report was just released. 

https://mary--cummins.blogspot.com/2022/03/pave-task-force-action-plan-from-white.html

B. ASC report

The private non-profit Fair Housing Alliance released their report. They included false and mischaracterized information including Andre Perry's paper. Here is my reply.

https://mary--cummins.blogspot.com/2022/01/identifying-bias-and-barriers-promoting.html

C. DOJ Statement of Interest in case Austin v Miller

DOJ filed a Statement of Interest in the case. That case has been covered extensively in this article linked below. Per black Plaintiffs' Reply they wanted the white real estate appraiser to only use sold comparables from Mill Valley and Sausalito two "white" areas which are worth about twice as much as their home, area in a "black" area in Marin City. Mill Valley is over a mile away and has one of the best school systems in the state. Austins stated it's "racist" to use sold comparables from their own neighborhood because it's "black" just like they are. These are actual quotes from their legal filing. Appraisers must use the most similar homes in the same area by law. Home values are based on LOCATION, LOCATION, LOCATION. Every home owner would love to use Beverly Hills comps to appraise their home in South Los Angeles but you can't. I wanted to speak to Waters about her false misrepresentation of this case but Waters office would never set the meeting. I sent a letter which I will post later. Waters is clearly just listening to summaries by people with their own agenda. 

https://mary--cummins.blogspot.com/2021/02/alleged-discrimination-home-appraisal.html

6. Legislative Proposal

This new agency is demanding to know the race, ethnicity, gender of all licensed appraisers. This information is not mandatory in California but the federal government will now demand it. AMCs will have to turn over the race, ethnicity and gender of all their appraisers. 

On page nine it appears Maxine Waters wants actual appraisals and all information from appraisers publicly available online. Only personally identifiable information may be redacted like their name. Your home appraisal will be available with photos of the interior of your home, where your security system is located, how to break into your home, where you keep your valuables, where your safe is located, where your little kids sleep, what is the best way to break in and rob you, gun collections, religious items, family photos, where you keep your purse, home layout...?

It appears that appraisers race, ethnicity and gender information will be publicly available online as well. 

Funding for fair housing testing must be provided. I will bet that the main Fair Housing nonprofit organizations National Fair Housing Alliance want money for their sting operations. The government will be funding non profits' personal agenda. They are also behind the false and frivolous alleged discrimination lawsuit Austin v Miller. They're asking for money in that lawsuit even though they were not a party to the transaction and there was no discrimination. 

All state complaints must be referred to the federal government within 48 hours. The appraiser who is the subject of the complaint must hand over 24 months of appraisals of other people's homes in the investigation of any complaint. Invasion of privacy of other people. Can they get these docs in a FOIA request? Complaints must be resolved within 100 days. 

If someone complains about an appraiser, the appraiser must give the borrower, owner the difference between their appraisal and another higher appraisal even if there were no damages or loss. Talk about undue influence to come in over market value. You know some borrowers will be getting their friends to make over market appraisals. What if the value is lower? The market may soon be changing. The person who doesn't like their appraisal now has up to five years to file a lawsuit against the appraiser instead of the usual 1-2 years statute of limitations. 

Racism is a big problem in our country. Wasting time on issues which are not racism detracts from the real issues of racism. 

Link to actual proposed new Bill.

https://docs.house.gov/meetings/BA/BA00/20220329/114561/BILLS-117pih-EndingAppraisalDiscriminationActof2022.pdf

Video of the meeting for new bill

https://financialservices.house.gov/events/eventsingle.aspx?EventID=409150

Proposed testimony for the meeting

https://docs.house.gov/Committee/Calendar/ByEvent.aspx?EventID=114561

Peter Tobias of AEI sent in testimony "Faulty Evidence and Misdiagnosed Solutions." 

https://docs.house.gov/meetings/BA/BA00/20220329/114561/HHRG-117-BA00-Wstate-PeterT-20220329.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 DISCLAIMER: https://mary--cummins.blogspot.com/p/disclaimer-privacy-policy-for-blogs-by.html