Mary Cummins, Real Estate Appraiser, Real Estate Appraisal, Los Angeles, California, Mary Cummins.

Mary Cummins is a real estate appraiser in Los Angeles, California with 38+ years of experience. Cummins provides real estate appraisals for banks, lenders, mortgage brokers, Appraisal Management Companies (AMCs), lawyers, Courts, factors and private parties for lending, lawsuits, probate, estate planning, divorce and all types of litigation. Cummins provides 1004, 1073, 1025 and other form reports, narrative reports and historical appraisals besides real estate research and appraisal advice.

Wednesday, August 2, 2023

Appraisers Can't Use Demographic Census Tract Data Yet Government Uses it to Attack Appraisers by David Towne

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Another great article by real estate appraisal expert Dave Towne cited below. He states what many have noted since the government started mentioning census tracts and appraisal values. Appraisers can't and don't use census tract report data in selecting comparables or valuing properties. We are not allowed to consider personal demographics. We can only consider properties in a market area similar to the subject property. Neighborhoods, market areas do not correlate with census tracts! Census tracts were made by the government to gather personal demographics of the inhabitants in specific tiny areas to compare changes over time. They are a more recent artificial constructs of government which have nothing to do with determining appraisal values.

The first census tracts in the US were made in 1906 in New York. In 1934 they were standardized and expanded to a few major cities. "The goal of the criteria has remained unchanged; that is, to assure comparability and data reliability through the standardization of the population thresholds for census tracts, as well as requiring that their boundaries follow specific types of geographic features that do not change frequently. The Census Bureau began publishing census tract data as part of its standard tabulations beginning with the 1940 Census."

For all we know the original tracts may have included some type of "redlining" based on race, nation of origin, primary language spoken, income levels... The "redlining" may have just been a correlation of less wealthy people living near the railroad tracks, polluted industrial areas and wealthier people living near the city center or a beautiful lake. Income, wealth correlate with race but race is not the cause.

The 1934 tracts have not changed but neighborhood boundaries, home values and real estate have definitely changed. Sometimes even the physical boundaries have changed with new freeways, aqueducts, dams, large government projects, dedicated parks, removal of train tracks... These areas also change as different areas go through the real estate cycles of growth, stabilization, decline and revitalization. Home values go up and down. Different people move in and out.

Appraisers use market areas sometimes called neighborhoods to selected comparables to value a subject property. WE DO NOT USE CENSUS TRACTS! The census tract number is auto-filled by a software program in the report. That's the only mention and use of census tracts. The government is the one who requested that data for their own loan use which is why it's in the form. Now they are misusing it to mischaracterize appraisers as alleged "racists" who "lowball" blacks and Latinos. Independent research by AEI has proven that race is not a factor in appraisal values. Whites make more money than Latinos and Blacks. If you make more money, you have more money and wealth. If you have more money, you will buy a more expensive home in a more expensive area. The main value of real estate is LOCATION, LOCATION, LOCATION.

When we search for comparables for a subject property some use a half mile radius from subject. Some go one mile. In rural areas they go a few miles. For a high density condo area you might just use 1/4 mile radius. Some appraisers use known neighborhood boundaries which could be two streets, railroad crossing, major boulevard, freeway or the ocean. It depends upon the subject property. If I were appraising a home in the N 600 block in the flats of Beverly Hills, I would search N 500-700 then probably go two blocks east and west of the subject for starters. If I needed to go wider, I'd only go east or west and not north or south. North is much more expensive because they are larger estates. South is much smaller tract homes on much smaller lots. I don't look at or search census tracts. I'd have to figure out how to do that if my MLS could even do that. In fact this census tract of Beverly Hills is the first one I've ever looked at in my life just now. There are ten census tract maps in the map below.

Below is the census map which includes Beverly Hills, zoning map of Beverly Hills and zip code map. They're all different. I'm using this because I grew up here and know all the different market areas very well. Some of the areas in the census maps are commercial only and worth trillions of dollars. People don't live in those areas. They are stores, offices, medical centers in the golden triangle. Some of the areas in the census map are Beverly Hills and some are the city of Los Angeles. Beverly Hills property is easily worth twice Los Angeles property even if it's just across the street for many reasons yet they're in the same census tract.

There's a thick line running down the middle of two census tracts. That's Sunset Blvd. Properties north of Sunset are worth 2-3x as much as properties south of Sunset. I could go on and on. The purpose is to show you that census tracts have nothing to do with real estate appraisal values. Three homes in the same tract could easily be worth $300,000 (small studio condo in Los Angeles), $2,000,000 small tract house south of the long gone rail road tracts on Santa Monica Blvd or $50,000,000 home above Sunset. Census tracts don't correlate with value. They should only be used to talk about people.

I think the problem with census tracts and home values first started with fraud Andre Perry. He used Zillow Zestimate home values in different census tracts and compared them with the predominant race of people in the census tract area. His goal, agenda was to show that black owned homes are worth less than white owned home due to "old white racist male" appraisers intentionally low balling black people. No appraiser appraised any homes in his paper. He used only inaccurate Zillow values. He also just used the majority percentage of blacks in each area. He then cherry picked and twisted the results to fit his agenda. The results of his fraudulent study showed that whites make and have more money than blacks, latinos. Whites can afford to buy more expensive homes in more expensive areas. We've known about the income and wealth gap for years. It's caused by income and socioeconomic factors but not race or real estate appraisers. AEI research which disproves Andre Perry's fraudulent paper.

Census map of Beverly Hills. Ten maps which include Century City, Sherman Oaks and Los Angeles cities.

Map of the city of Beverly Hills broken up by zip codes just so you can see the outline of the city.

Below is Dave Towne's article. I asked his permission to share it. I'd link to it but he posts it in an appraisal group which is not public.

"Not to gloat, but I seem to be the only appraiser in the US who has observed and reported how people-oriented DEMOGRAPHIC CENSUS TRACT DATA reported by FHFA, the GSE’s and other entities is being used to tar and feather appraisers. I have written about this topic at least 2x in the past.

The latest is this 8/01/23 INSIGHTS newsletter, in the link, from FHFA ...... the ‘conservator’ of Fannie Mae and Freddie Mac:

Blog | Federal Housing Finance Agency New Measures in the UAD Aggregate Statistics: Opportunities to Explore Data on Comparable Properties and Structural, Lot, and Neighborhood Characteristics (fhfa.gov)

Here’s what’s in that (screen shots of the document):

Appraisers don’t appraise properties with CENSUS TRACTS as a paramount data point. Most of us don’t even know where the tract boundaries are.

The Census Tract Number on the appraisal form is only there so that the LENDER and their regulators can track loans made in Tracts.

Because the ‘researchers’ cannot get into the minds of appraisers to determine how comps are selected, all the ‘researchers’ can do is fall back on this DEMOGRAPHIC metric. That’s unfair to appraisers. “We” appraisers are not allowed to use or consider people-oriented DEMOGRAPHICS in reports.

But what’s conveniently overlooked in this metric is the econometric status and other factors that play into where people choose to live and how baseline property valuations are done, starting with the local jurisdiction Assessor. Those baseline factors started decades ago, long before most appraisers got into the business.

Buyers also don’t use Census Tracts as a determining factor on where to buy their home, unless magically the Tract corresponds with other geographic or personal factors the buyer considers important. Builders/developers in most cases don’t purposely put up new housing based on Census Tract demographic info.

What’s been happening since 2018 or before is the likes of Andre Perry and Elizabeth Corver-Glenn, Ph.D, etc., have incorrectly used Census Tract people-oriented DEMOGRAPHIC info to inform Congress and others that “We” appraisers are valuing properties all wrong and it must be stopped.

Because of this, Census Tracts are becoming the de facto element “We” must acknowledge and that other people think is proper.

In short, using only this people-oriented DEMOGRAPHIC based data item to judge appraisers is just plain wrong.

Dave Towne, MNAA, AVAA, AGA "

About David Towne

Certified Residential RE Appraiser at Towne Appraisals

AGA, MNAA, Accredited Green Appraiser - Licensed in WA State since 2003

https://www.linkedin.com/in/dave-towne-4a65226/
https://www.towneappraisals.com/

http://www.e-appraisersdirectory.com/Washington_Appraisers:Towne_Appraisals-48-2989-0-0-1864.html

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

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

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Mary Cummins

Mary Cummins of Cummins Real Estate Services has been in real estate since 1983, over 35 years. She is licensed by the Bureau of Real Estate Appraisers. Mary Cummins was an agent and broker licensed with the California Department of Real Estate selling residential income, commercial buildings, raw land and homes for Merrill Lynch Realty in Beverly Hills and Westside Properties in Los Angeles before concentrating on appraisals. Mary Cummins currently provides real estate appraisals, expert witness testimony, historical research, legal real estate research for mortgage brokers, banks, lawyers, factors, insurance companies, financial consultants and private individuals. Mary Cummins was born and raised in Southern California. Cummins attended Beverly Hills Good Shepherd Catholic School and Beverly Hills High School. Besides being on the Dean's list, Mary Cummins was a top ten national swimmer and competed on the men's water polo team. Mary Cummins began college at the age of 15 attending the University of Southern California on scholarship, majoring in Psychology/Sociology. http://www.animaladvocates.us http://www.facebook.com/AnimalAdvocatesUSA

Sunday, July 30, 2023

Nazario Incorrectly Blames Their Home Affordability Issues in Los Angeles on Government by Mary Cummins

This family of four tries to blame the government for their inability, unwillingness to cheaply rent or buy a home in central Los Angeles on their low wages with little savings. There are a few issues here the biggest being their relatively low wages. The article states the two daughters graduated from college. Jennifer Nazario got a Masters in economics and Paula Zanario got one in public policy. Their Opinion op-ed piece shows they may not have been paying attention in class.

People making minimum wage can't afford to rent a one bedroom in LA same in SF and NY let alone buy a home. Median rent for one bedroom here is $2,100. You need two people with minimum wage jobs to afford that and they're still rent burdened. They should increase their wages before considering buying. They've now bought at the peak of the market with high interest rates and a super low down payment. Hope they didn't get an adjustable and never have an emergency or job loss.

One issue I've found with people living in rent control units is they never strive to increase their income because they don't need to. I can only imagine how low the rent is for that studio after having been there for 25 years. It's wayyyyyyy below market rent. They've been taking advantage of their landlord who has subsidized their rent for 25 years. Their landlord is probably also an immigrant Latino.

Legally they were not allowed to have four people in there. They could have been evicted easily but the landlord was nice to them and allowed them to stay. It's two people max allowed for a studio though sometimes they'll allow a very young underage child.

As I read the article the two kids weren't old enough to work until about 2022. They said they both went to college then grad school. They chose not to get full time jobs. Then they said they, I assume the two daughters, make over $136,650 a year combined. They did at least state they were happy they had low rent so they could save a lot of money for years. That's nice. It also means they are admitting they could have afforded a bigger better place if they wanted to. They are complaining about a situation they created for themselves.

The writers state they applied for the BofA program but didn't qualify because they made too much money. They also applied for the California Dream for All program which ran out of funds. Then they whined about the pay back part of one program if they accrue equity and sell. That's how the program works and is funded! We're really just taking their word for it. There could be more involved like credit scores, time at their jobs, other debt like car payments, credit card debt, bad debt, student loans...

They ended up buying a home outside of expensive downtown Los Angeles with 3% down. This was after they basically complained about rising rents, home prices and gentrification. They moved somewhere else and contributed to gentrification in that area. "Gentrification" has nothing to do with race but finances. Finances correlate with race in the US. Whites make more than Latinos and Blacks. It's actually just the revitalization cycle of real estate. People get pushed out of more expensive areas into less expensive areas. That's what happened with this family. They originally found a cheap place to live because it was in the recession phase before the recovery phase. They just did the same with their new place. They committed "gentrification."

Jennifer and Paula Nazario suggest government programs should provide free or cheap down payments for homes for poor people with low income jobs, bad credit, lots of debt and no savings. They clearly were not paying attention in class especially Jennifer with her Economics degree. If anyone can basically buy a home for free even though they can't easily make the mortgage, taxes, insurance, upkeep expenses, they will default and lose the home. That's why conventional loans don't allow you to borrow the down payment money. If you aren't making enough income to afford the down payment, you can't weather any emergency and won't be able to pay back the loan. Someone with no money in the deal won't care as much about losing the property. No bank would loan on a property without an equity cushion for fees, costs if they get stuck with it in foreclosure. There is a ton of years long research on this.

Someone should have dissuaded the Nazarios from writing this clueless op-ed piece. It makes them look really stupid. I wasn't going to say anything until I saw that Jennifer has a degree in Economics. I'm truly embarrassed for them because I'm Latino. Thankfully I have common sense and don't expect the government to pay for everything for me. You have to do some things for yourself in this world.

From the article: "Jennifer Nazario is a systems administrator at a network of college-preparatory schools and a first-generation college graduate with a master’s degree in economics. Paula Nazario is an assistant director at UCLA and the first person in her family to go to college. She has a master’s degree in public policy."

https://www.yahoo.com/news/family-four-shared-cramped-studio-100112963.html

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Mary Cummins

Saturday, July 22, 2023

Barbie's Malibu Beach House 33505 Pacific Coast Highway PCH Hwy by Mary Cummins Real Estate Appraiser

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The Barbie Malibu Beach house is located at 33405 Pacific Coast Highway PCH Hwy. The GPS is 34.04435703038078, -118.90477660010154 . Here is the Google map. The Assessor's Parcel Number APN is 4473-003-003.

Barbie's Malibu Dream House is owned by 62 year old real estate agent Kirby Max Kotler.

Legal description is LAND OF MATTHEW KELLER IN THE RANCHO TOPANGA MALIBU SEQUIT LOT ON N LINE OF PACIFIC COAST HWY COM N 9 14'30" E 50 FT AND N 80 45'30" W 600 FT FROM ENGR STA 229 PLUS 62.82 IN C/L OF SD HWY PER 30" E PART OF LOT 19 . Below is the parcel map. Look at the pink arrow.

It was last listed for lease for $12,000/month in 2011. Description is "Newly built, private and gated, custom architectural home situated on over 2.5 acres of land. This beautiful home, surrounded by lush and tropical landscaping, has 3 bedrooms + office/guest bedroom and 3.5 bathrooms and maids quarters. Gourmet chef's kitchen with stainless steel Viking appliances and stunning living room with fireplace. This Malibu Estate boasts magnificent 180 degree ocean and whitewater views of the beautiful Pacific Ocean from Santa Monica to the Channel Islands." Below is the last MLS for the property.

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It's currently listed on Airbnb. https://www.airbnb.com/rooms/857387972692815761?source_impression_id=p3_1690054420_cHHNZOsAAcCHU8Wl&modal=PHOTO_TOUR_SCROLLABLE

It was built in 2007 and is legally 3375 sf. The jurisdiction is City of Malibu, Los Angeles County, California.

Google image views before the pink paint job.

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Part of the property was burned in the Woolsey fire and the owner was forced to sue the insurance company. Below is a request to rebuild a nonconforming structure. It includes a letter at the end about the issues. They have until November 2023 to submit plans for permits to rebuilt. I assume they did that.

https://www.malibucity.org/AgendaCenter/ViewFile/Item/5375?fileID=27065

More information from AirBnb

"Welcome to my Kendom! While Barbie is away, she has handed over the keys to her Malibu DreamHouse this summer and my room could be yours for the night. I’ve added a few touches to bring some much-needed Kenergy to the newly renovated and iconic Malibu DreamHouse. Placed perfectly above the beach with panoramic views, this life-size toy pink mansion is a dream come true!

Booking opens at 10 a.m. PT on Monday, July 17 for two, one-night stays for up to two guests on July 21 and July 22, 2023.

The space

Situated along the stunning, photogenic coastline, the Malibu DreamHouse is a sunny surfer’s sanctuary surrounded by beach, beach and more beach – just the way I like it.

I’ve decked out the place with a little more…well, me! I’m more than just beach! My cowboy stuff is great. And horses! Guitars, games and more. And of course, rollerblades, because I literally go nowhere without them. Now, guests can live it up Ken-style for a neon night in Barbie Land – six-pack not included.

- During your stay, you will have the opportunity to live in technicolor by:

- Taking a spin through my awesome wardrobe to find your best beach fit. Look out Barbie, I’ve got quite the closet too!

- Channeling your inner cowboy and learning a line dance or two on my outdoor disco dance floor or performing a sunset serenade on my guitar

- Challenging your fellow guests to a “beach off” with plenty of sunbathing and chillaxing by the infinity pool

- Taking home a piece of my Kendom with your very own set of yellow-and-pink Impala skates and surfboard

Other things to note

Once you arrive and check-in, our concierge will ensure a comfortable stay for you and your guest — including showing you around and setting out and arranging meals.

These one-night stays are not a contest. Guests are responsible for their own travel to and from Malibu. This home is privately owned and operated.

In celebration of BARBIE hitting theaters on July 21, and to honor girls’ empowerment, Airbnb will make a one-time donation to Save the Children. Save the Children provides learning resources and support to children, families, and communities in 100+ countries to build girls’ confidence and help them excel in school – ensuring everyone has equal opportunity to achieve success."

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Mary Cummins

Thursday, July 20, 2023

PAREA Update from David Samnick - Practical Applications of Real Estate Appraisal , comment by Mary Cummins

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I haven't been following PAREA as closely as I should have but thankfully appraiser David Samnick has been following it. He attended an Appraisal Institute meeting yesterday about the program. It's disheartening to say the least. The purpose of PAREA was to make it easier, cheaper and faster for new appraisers to get the training and hours of real life experience they need to get their license. A main purpose was to help diversify appraisers by making it cheaper and getting rid of the mandatory mentor/trainee. Lower income people can't work as a trainee for free for two years. I wrote a few articles about this huge obstacle to getting a license. Here's one from June 2021. https://mary--cummins.blogspot.com/2021/06/difficulties-becoming-real-estate.html

This post below by David Samnick makes it clear that AI and others such as McKissock have used the issue of diversity just to line their pockets with money. The Appraisal Institute, McKissock make money selling education hours to appraisers. AI got a grant from the government to work on PAREA. May 18, 2023, the AQB approved the first PAREA program, belonging to the Appraisal Institute (AI). I wish I were wealthy and retired so I could train people for free. I'd only train POC if that were legal and not discriminatory.

"Practical Applications of Real Estate Appraisal (PAREA) is a program that aims to revolutionize the real estate industry by increasing the number of appraisers. However, after listening to the Appraisal Institute speaker at yesterdays board meeting it quickly became evident that this initiative is a complete failure.

A) You cannot start PAREA until you have received all your real estate appraisal education. 94 hours = $1,700 per McKissock

B) Appraisal Institute speaker said that most AMC's/banks won't accept licensed appraisers work so he suggests going the CR route. Cost to become a CR appraiser through PAREA - $10,000

C) PAREA is a complete online course. Zero mentorship in the real world. No physical measuring. No driving. No real time experience. No true mentorship.

D) No discussion with the PAREA student about the pay to play. Multiple MLS services, E&O insurance, business expenses, accounting, appraisal software, computers, reliable transportation, and other miscellaneous expenses. Total costs can exceed $6,000 per year.

E) The Appraisal Institute said that this would increase diversity into the appraisal field yet could not tell us the breakdown of how many applicants were minorities.

F) PAREA graduates will be scooped up by AMCS to sign off on Hybrid reports performed by third party data collectors.

G) PAREA graduates have no geographic competence.

H) Total cost for PAREA at the end of the day = $17,700 and potentially more.

The Average Joes argued several points in the board meeting.

A) A graduate of the PAREA course would be paid and treated like a trainee as they have no real-world experience.

B) We could have more appraisers back into the industry if banks/amcs would allow appraisers to use their trainees.

C) Reinstate Licensed appraisers to be able to mentor new trainees. This would introduce the next generation of appraisers into the business.

D) Petition FHA to reinstate any licensed appraiser who took the FHA course and had to pass the test.

E) More appraisers would hire trainees if the AMC model wasn't taking so much money out of the pockets of working appraisers. Work is slow. Most have the mentality that my bills come before your bills.

In closing PAREA launched in 2019. And the program has not been successful in diversifying the appraisal profession. In fact, a study by the Appraiser Qualifications Board found that the PAREA program has had a negative impact on diversity in the appraisal profession.

The study found that the PAREA program is disproportionately used by white appraisers. In fact, white appraisers are more than twice as likely to use the PAREA program than minority appraisers. The study also found that the PAREA program is not as effective in providing a more accessible pathway to licensure as the traditional apprenticeship model."

https://www.linkedin.com/feed/update/urn:li:activity:7087764386198556672/

Below was stated May 2023 by AI. “Market research has shown that value proposition—what PAREA is worth to someone in the marketplace—is around $5,000,” DiBiaso said. “Our pricing strategy may be different than that and include scholarships and discounts and payment plans. We have a commitment to The Appraisal Foundation that we will give preference of our scholarships to minorities, veterans, and people who indicate a willingness to serve in rural areas. The scholarships will come from a number of different sources including AI.”

McKissock stated their program will be ready June 2023. “We are investing heavily in the technology tools that appraisers use,” Nancy Gerome said, McKissock’s appraisal general manager. “Our hope is to have them consistently trained. You’ll get all different types of properties and scenarios because we’re leaning into the technology and experience. We’re trying to be thorough, that’s why we’re taking our time. We want to get it right.”

McKissock staff is preparing their launch to accommodate thousands of trainees, over a staggered period. They estimate the average time a person will take to complete the program is six months. The cost for participating is not yet determined. Staff did confirm there will be a “buy now, pay later” option, as well as scholarships.

“We are building a scholarship program because we know one of the goals of PAREA is to bring diversity into the profession, and we want to make it as affordable as we can,” Gerome said. Those interested in participating in a PAREA program of either McKissock or AI need to have already completed their Qualifying Education. "

Clearly when the government said there was a probably with diversity among real estate appraisers and the government would give money to help diversify appraisers all these companies heard was MONEY. They will just be training more appraisers for more money and the appraisers will probably all still be mainly older white men.

Appraisal Institute talks about grants and scholarships for POC and women all the time. I tried to apply and they said I have to pay to join their organization before they'd even talk about it. What if I had no qualifications or were denied? I'd be out the membership fee which is not cheap. It normally costs $15,000 to become an AI MAI appraiser even though I have 40 years of experience and have taken every publicly available real estate appraisal class in existence over the last 40 years. This is clearly a racket when you consider the government gave them money for the program. Gate keeping with a membership fee to the Appraisal Institute before you can access government funding.

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Mary Cummins

Wednesday, July 19, 2023

Fed Michael Barr: AI could 'perpetuate or even amplify' racial bias in mortgages, by Mary Cummins

Michael Barr of the Federal Reserve stated artificial intelligence AI could perpetuate or even amplify racial bias in mortgages, mary cummins, real estate appraiser, real estate appraisal, los angeles, california, michael barr, racial bias,federal reserve, fed, loan origination, race, black, white, bias

Artificial Intelligence (AI) is now being accused of racial bias. They're basically stating math, statistics, numbers themselves are racially biased. Again, the correlation between race and home value is caused by the income gap. If you have less money, you buy a less expensive home. Same with credit scores. The less money you have, the lower your credit score. POC make less money than whites. I'm just glad they're not still falsely accusing appraisers of AI's bias like they did previously with Andre Perry's fraudulent paper. No appraiser was involved in his data only robot Automated Valuation Methods (AVMs) which were basically accurate.

https://www.americanbanker.com/news/feds-barr-ai-could-perpetuate-or-even-amplify-bias-in-mortgages

"Fed's Barr: AI could 'perpetuate or even amplify' bias in mortgages

By Kyle Campbell

Michael Barr, vice chair for supervision at the Federal Reserve, said in a speech Tuesday that artificial intelligence in mortgage underwriting could exacerbate racial bias if left unchecked.Bloomberg News

The Federal Reserve's top regulator is wary of the use of artificial intelligence in mortgage underwriting.

Speaking at the National Fair Housing Alliance's national conference Tuesday morning, Fed Vice Chair for Supervision Michael Barr said advancements in mortgage origination technology could lead to discriminatory lending practices."

Just did some Googling on racial bias in loan origination. 98-99% of the difference in loan origination between blacks, whites explained by credit scores and leverage. Did they consider LTV on the home or all debts? There's more to credit than credit score and LTV ratios. They include savings, how long at current job, debts, monthly financial responsibilities, single vs married, children... AEI research considered those factors.

"How much does racial bias affect mortgage lending? We assess racial discrimination in mortgage approvals using new data on mortgage applications. Minority applicants tend to have significantly lower credit scores, higher leverage, and are less likely than white applicants to receive algorithmic approval from race-blind government automated underwriting systems (AUS). Observable applicant- risk factors explain most of the racial disparities in lender denials. Further, we exploit the AUS data to show there are risk factors we do not directly observe, and our analysis indicates that these factors explain at least some of the residual 1-2 percentage point denial gaps. Overall, we find that differential treatment has played a limited role in generating denial disparities in recent years."

https://www.federalreserve.gov/econres/feds/how-much-does-racial-bias-affect-mortgage-lending.htm

I'm thinking this is just showboating for political reasons. The banks, credit unions don't want to give up credit scores. They correlate highly with ability to repay loans.

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Mary Cummins

Thursday, June 29, 2023

Real Estate Appraisers Mentioned in False Light in California Reparations Report by Mary Cummins

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The final California Reparations Report came out today. I just started reading it but thought I'd search for the words "appraiser" and "appraisal." Sure enough they're in there because Paul Austin and Tenisha Tate-Austin told their false story about alleged racial discrimination to the Task Force.

"Consider Paul Austin and Tenisha Tate-Austin, who bought a home in Marin City in 2016. Three years later, a white appraiser valued their home for $500,000 less than it was worth, calling it a “distinct, marketable area.”27 “I took that as code word as: it’s a Black area,” said Paul Austin, who testifed before the Task Force that he felt physically sick when he read the appraisal report."

The statement above is totally false. I sent in a correction. It was not valued for $500,000 less than what it was worth. The appraisals were never made public. I wrote an in depth fully research article about the Austin v Miller case here. https://mary--cummins.blogspot.com/2021/02/alleged-discrimination-home-appraisal.html

They were not discriminated against or low balled by the first appraiser. Marin City is a distinct area just like Pacoima, Beverly Hills, La Habra are distinct areas. The second appraiser came in way too high. My article above goes into the values in great depth. The second appraiser is the one who should be investigated by the California Attorney General, Bureau of Real Estate Appraisers, lose their license and be charged with bank fraud. The harm this case caused to the first appraiser is beyond comprehension.

I haven't gotten far in the report but did notice a few important things. The report mentions the racial and other bias against Mexicans, Native Americans, Asians, Jews, Catholics, immigrants, women, poor... All of these other groups were also affected by racial, color, gender and other biases. The report isn't about slavery per se as California was never a slave state. The report is about racial harm against black people living in California before 1900. Mexicans, Native Americans, Asians, Italians were lynched. Native Americans, Mexicans lost their lands and property. Mexicans, Native Americans, Immigrants were used as near slave labor. Women, men, the poor were raped by slave owners, employers, government sanctioned church... Mexicans, Native Americans, Asians weren't allowed to attend public school with whites. All this happened in California. Every state, nation, people has done truly horrible things to others throughout all of human history.

The Governor and others already said there will be no monetary reparations. California has a budget deficit. The report was done to educate the nation and for positive PR for California and it's politicians. The state would also have to consider the harm caused to everyone else before they ever cut a check. It would be discrimination to give money to only one group based on race. There was already a case here in Oregon over Covid funds. (The Oregon CARES Act Discrimination Lawsuit is Great Northern Resources Inc., et al. v. Katy Coba, et al., Case No. 3:20-cv-01866-IM (L), in the U.S. District Court for the District of Oregon, Portland Division.) They wanted to give some Covid funds to blacks only because they were more affected than whites but the state was sued due for discrimination. Latinos who were equally negatively impacted by Covid sued for discrimination so the funds had to be given to everyone who applied. Any reparations would be the same.

If we were to do a California Reparations Report for all races, colors, religions, genders... everyone in California would end up owing everyone else money. It'd cancel itself out. You'd also have to offset benefits of living in the state minus harm caused by past actions in the state by the state. I'm Mexican, Indigenous, African and Euro. Half of my ancestral family was harmed by the other half. The reports would just cost the state a lot of money and I'd probably get half a cent. I'll pass on that waste of funds. I personally am just very happy to live here in California. I'm lucky I was born in this state and in this country.

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Mary Cummins

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

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

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Mary Cummins

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

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