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.

Monday, August 5, 2024

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

mary cummins, real estate appraiser, real estate appraisal, aei, hud, nfha, national fair housing alliance, race, discrimination, bias, settlements,

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

UPDATE: Appraisal Institute just posted about this issue here.

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

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

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

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

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

Radio spot script

"Robbed" (:60)

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

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

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

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

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

the same condition and age.

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

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

appraisals. For example, one Black homeowner received an appraisal

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

books from her home.

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

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

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

to fair housing.

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

Housing Alliance."

Radio spot 2 "Hide" (:60)

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

home. So we got an appraisal.

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

appraised again, a friend suggested we make some changes.

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

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

came back much higher!

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

appraisal.

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

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

appraisals. For example, one Black homeowner received an appraisal

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

books from her home.

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

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

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

to fair housing.

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

Housing Alliance"

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

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

ORIGINAL: The private nonprofit group National Fair Housing Alliance NFHA promotes the false narrative about alleged racist, biased real estate appraisers, lenders, AMCs to get donations, grants and millions in legal settlements per year. They falsely promote fake debunked papers about race and home values. Currently they're running advertisements falsely stating that real estate appraisers lowball blacks and Latinos. Private NFHA brings in $30,000,000 a year in donations and has $23,000,000 in assets in 2021. They're probably bringing in double that today in 2024 because of a recent 2022 $53,000,000 settlement from Fannie Mae and 2022 $4,000,000 settlement from Redfin. EIN 521676364 Phone (202) 898 1661

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

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

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

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

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

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

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

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

https://www.hud.gov/sites/documents/NFHAHUDWHEELCHAIR_EN.PDF

https://www.hud.gov/sites/dfiles/FHEO/documents/HUD_NFHA_Discrimination_ENG_508.pdf

https://www.hud.gov/sites/documents/FATHER_SON_ENG.PDF

I couldn't read the fine print in the ad I originally posted above. HUD is working with NFHA on these misleading ads. The block of text after "Everyone has a right to fair housing" could say "A public service message from the U.S. Department of Housing and Urban Development in partnership with

the National Fair Housing Alliance. The federal Fair Housing Act prohibits discrimination because of race, color, religion, national origin, sex, familial status or disability. For more information, visit www.hud.gov/fairhousing." It still makes it seem that private NFHA is part of the government when it's not.

Here is their income from settlements, shakedowns.

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

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

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

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

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

References

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

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

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

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

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

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

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

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

Thursday, August 1, 2024

Appraisal Institute AI, National Association of Realtors NAR Zoom Webinar on NAR Settlement

amy frink, mary cummins, woody fincham, jared preisler, beth graham,national association of realtors,appraisal institute,ai, nar, nar settlement, commission, concession

"The NAR Settlement: What appraisers need to know and watch for

On August 17, 2024, REALTOR® MLSs (multiple listing services) will be required to make practice changes in accordance with the National Association of Realtor (NAR) settlement, including (1): prohibiting offers of compensation on the MLS (though such offers “could [be] pursue[d] off-MLS through negotiation”).

MLS participants working with buyers must enter into written agreements with their buyers before the buyer tours a home.

What does all this mean for appraisers, the data they collect from MLSs, and the verification and reporting of that data? The unfortunate answer is that all the implications of these changes are not completely clear yet. However, our panelists are here to help make sense of what is known now and what you might be able to expect.

Panelists will discuss:

What are concessions and why they are not commissions

How are MLS Forms and policies changing in local markets and how to understand these changes

Obtaining data to verify sales in light of MLS changes

How to reflect changes in data collection in your report

What to look for in and what to ask your MLS going forward"

My notes which are super brief as I was a little busy.

Buyers and buyers agents should have been using existing buyer commission and representation contracts before the settlement. Now they are mandatory.

Sales concession vs repair cost. Sales concessions are rate buy downs, closing costs payments, anything related to finance, escrow. They are not repair costs to the property.

Homes prices and commissions will not be going down because of NAR settlement. It basically just makes things more confusing with more paperwork.

Commissions have not been 6% in many, many years. They are 1-3% since homes prices have doubled in value. The idea that the NAR Settlement will reduce commissions and home prices is false. It won't.

A few slides. Presentation was recorded. I'll post the link if it's public. I suggest watching the one hour Zoom presentation.

The slides below are in reverse order. Sorry.

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

Mary Cummins

Tuesday, July 16, 2024

HUD Bias Complaint Against Appraiser by Mary Cummins Real Estate Appraiser

UPDATE 12/05/2024: Rocket Mortgage just sued HUD in a new lawsuit 24-cv-03368. They claim they are not responsible for third party AMCs and appraisers. The DOJ provided the borrower named of Francesca Cheroutes. Rocket gave Francesca Cheroutes two chances to do a Reconsideration Of Value ROV or appraisal appeal. She declined. The address provided by DOJ is 749-751 Ash Street, Denver, Colorado. Owner lives in one unit and rents out the other.

Rocket Mortgage's main argument is that Rocket did not have a duty to "correct" the appraisal. Appraisers, AMCs are independent third parties. The government is the one that mandated that appraisers, appraisals be independent. They don't want lenders pressuring appraisers. Legally Rocket is not allowed to "correct" an appraisal. They are not allowed to even try to influence an appraiser, appraisal per the law. They further argue that they told borrower they could send in an ROV to the AMC which gives it to the appraiser but borrower refused. Failure to mitigate a claim. Lender can't send in the ROV. I agree with Rocket Mortgage.

*Everything in this article is based on public records such a building records, public MLS/rent listings, the public filed lawsuit and the public DOJ report.

Per DOJ, borrower and Zillow subject is two units, six beds, four baths, 3,550 sf and each unit is two floors. That's almost double the actual finished GLA and bed/bath count. The units are 2 beds, 1 bath 1,500 or so sf total with full basements which are not 100% finished. There is one floor and a basement level. Credit was given for the basement. Duplex comps with similar basements used. This is an area where properties would all have full basements. Zillow/Trulia value today December 2024 after three years of appreciation $826,000 based on 6+4 3,500 sf. Then I doubt it was worth $860,000 in January 20, 2020. RedFn says $797,000 with same wrong bed/bath. I obviously put no weight in Zillow, RedFn values. Clearly the borrower wanted the incorrect Zillow bed/bath count and value. Borrower claims she had a no inspection "valuation" March 2022 for $885,000. Sounds like an AVM or free broker CMA BPO for listing which would be higher than market value.

Multifamily properties are different than SFR. They generally include GBA Gross Building Area. That can include other areas if it's 100% finished. The most important thing is to compare apples to apples. In this area most duplexes, SFRs have full basements. Some are finished, some have "legal" beds/baths and some don't. The appraiser used similar comps and included basement adjustments.

I did not do the original appraisal. I live in an area where basements and especially full basements are very uncommon in Los Angeles, California. They are never in GBA of 2-4 units. They are generally never 100% finished. At most they are crawl spaces or small utility basements. We have/had a high water table and basements would flood which is why we don't have them. Most of them have no windows or legal exits from all rooms. You need a legal sized window exit from bedrooms to legally be a bedroom. You don't want to get trapped in there in a flood or fire.

It turns out the black female attorney was happy with a few previous refinances of the property. They still have their mortgage with Rocket including the servicing. They didn't go get another loan with a new lender. This appears to be another false claim of bias and discrimination. This woman filed complaints in a few places. Read the documents and come to your own conclusion.

Per DOJ January 2021 $640,000 appraisal value. Appraisal from previous year was allegedly $860,000. It appears the previous value was perhaps too high. Francesca lied to the DOJ about requesting a reconsideration of value. She didn't request one. She should have requested a ROV. Then the issue of GLA, GBA could have been clarified. Borrower stated she merely complained about racial discrimination and demanded a higher value. It would have taken her half an hour to submit a ROV. She should have done that. Failure to mitigate damages, if there were any damages. We also don't know if her credit score, debt ratio, income levels, job history, judgments, liens, payment history ... affected her credit rating. There are many reasons to be denied a loan. The appraisal value is just one of them. If you have great income, great credit, little debt, long time job history ... a lower appraisal value wouldn't matter as much especially as this is owner occupied.

Here is the property per Zillow with size of 3 bed, 2 bath1,550 sf. That value is $557,000 today. It shows only one unit. The actual units are about 2 bed, 1 bath 700-800 sf GLA each with additional basement. One place even lists this as four units. I think they took the data from a rental offering of one unit. See how inaccurate Zillow can be.

https://www.zillow.com/homedetails/749-N-Ash-St-Denver-CO-80220/2067840283_zpid/?

Zillow value adding basement. It shows two units adding basements to first floor. Basement was given credit in the appraisal. There were no beds, baths in the basement per original appraisal. It's just laundry, exposed water heater, exposed furnace, electrical outlet on outside of wall, pipes on outside of ceiling. Maybe the owner has since updated the basement. It's listed as full basement but not 100% finished.

https://www.zillow.com/homedetails/749-751-Ash-St-Denver-CO-80220/2054732090_zpid/

Property data https://www.denvergov.org/property/realproperty/summary/0606314009000/

One unit was offered for rent for $3,000 October 2024. Looks like it had upgrades in 2022. It was previously listed for $3,500 then $3,400 then $3,200. It states recent renovations. https://www.trulia.com/home/749-n-ash-st-denver-co-80220-2067840283

One unit was offered for rent for $2,800 November 2021. You can see the basement level. Photo from that listing. Half size windows so a lot less light. Legal basement egress windows must be at least 24 inches tall and 20 inches wide. I can't tell if that is 24 inches but maybe it isn't. The window must be minimum 5.7 sf area and no more than 44" off the floor. Again, it may not be big enough. As I look at interior, exterior photos I don't know if the windows meet those minimums. People need to be able to escape in a fire or flood. I don't see the current basement bedroom windows. These pics are recent after a remodel with new carpet, paint... I see exposed plumbing, electrical so not 100% finished. I see some wonkiness in an interior wall under the window which looks like water damage. Again, I'm not the appraiser and haven't seen the property.
https://www.zumperrentals.com/apartments-for-rent/12060314p/3-bedroom-hale-denver-co?gallery=#media-447399980

Here is the racial bias accusation. She had a Black Lives Matter BLM sign on the property and appraiser walked by it. Sounds like the woman just wanted the lender to give her a higher value so she could refinance her loan again. She may have tried to go to another lender with another appraisal and that appraisal was probably also low so she didn't refinance. Perhaps she was able to pressure the previous appraiser. It sounds like she was trying to pressure the appraiser in this case.

https://www.prnewswire.com/news-releases/rocket-mortgage-sues-united-states-department-of-housing-and-urban-development-302323839.html

Link to the complaint.

https://drive.google.com/file/d/1YY7L-lJ-8nQBsBEJA9H7U-K0Y1i3deWP/view?usp=sharing

Below is the court docket for the current case.

U.S. District Court - District of Colorado

District of Colorado (Denver)

CIVIL DOCKET FOR CASE #: 1:24-cv-03368-REB

Rocket Mortgage, LLC v. United States Department of Housing and Urban Development

Assigned to: Judge Robert E. Blackburn

Cause: 05:0706 - Judicial Review of Agency Action

Date Filed: 12/04/2024

Jury Demand: None

Nature of Suit: 899 APA Review/Appeal

Jurisdiction: U.S. Government Defendant

Plaintiff

Rocket Mortgage, LLC represented by Angelica Rankins

Goodwin Procter LLP

1900 N Street NW

Washington, DC 20036

202-346-4000

Email:

ATTORNEY TO BE NOTICED

Brooks R. Brown

Goodwin Procter LLP

100 Northern Avenue

Boston, MA 02210

617-570-1000

Email:

ATTORNEY TO BE NOTICED

Keith Eric Levenberg

Goodwin Procter LLP

1900 N Street NW

Washington, DC 20036

202-346-4000

Email:

ATTORNEY TO BE NOTICED

Jeffrey Brian Morganroth

Morganroth & Morganroth, PLLC

344 North Old Woodward Avenue

Suite 200

Birmingham, MI 48009

248-864-4000

Fax: 248-864-4001

Email:

ATTORNEY TO BE NOTICED

Defendant

United States Department of Housing and Urban Development

Date Filed # Docket Text

12/04/2024 1 COMPLAINT against United States Department of Housing and Urban Development (Filing fee $ 405,Receipt Number BCODC-10018454)Attorney Jeffrey Brian Morganroth added to party Rocket Mortgage, LLC(pty:pla), filed by Rocket Mortgage, LLC. (Attachments: # 1 Civil Cover Sheet, # 2 Summons, # 3 Summons, # 4 Summons)(Morganroth, Jeffrey) (Entered: 12/04/2024)

12/04/2024 2 CORPORATE DISCLOSURE STATEMENT identifying Corporate Parent Rocket Companies, Inc., Corporate Parent Rocket, LLC for Rocket Mortgage, LLC. (Morganroth, Jeffrey) (Entered: 12/04/2024)

12/04/2024 3 NOTICE of Related Cases by Plaintiff Rocket Mortgage, LLC (Morganroth, Jeffrey) (Entered: 12/04/2024)

12/04/2024 4 NOTICE of Entry of Appearance by Brooks R. Brown on behalf of Rocket Mortgage, LLCAttorney Brooks R. Brown added to party Rocket Mortgage, LLC(pty:pla) (Brown, Brooks) (Entered: 12/04/2024)

12/04/2024 5 NOTICE of Entry of Appearance by Keith Eric Levenberg on behalf of Rocket Mortgage, LLCAttorney Keith Eric Levenberg added to party Rocket Mortgage, LLC(pty:pla) (Levenberg, Keith) (Entered: 12/04/2024)

12/04/2024 6 NOTICE of Entry of Appearance by Angelica Rankins on behalf of Rocket Mortgage, LLCAttorney Angelica Rankins added to party Rocket Mortgage, LLC(pty:pla) (Rankins, Angelica) (Entered: 12/04/2024)

12/05/2024 7 Case assigned to Judge Robert E. Blackburn. Text Only Entry. (agryan) (Entered: 12/05/2024)

12/05/2024 8 SUMMONS issued by Clerk. (Attachments: # 1 Summons, # 2 Summons, # 3 Magistrate Judge Consent Form) (agryan) (Entered: 12/05/2024)

DOJ case which lists name of owner and address. We now have address, values and dates.

https://www.justice.gov/opa/media/1374081/dl?inline

Below is heading of DOJ v Rocket case 24-cv-02915 Denver, Colorado. Francesca is listed as a Plaintiff intervenor with attorney andy@newman-mcnulty.com So far the case was reassigned a few times then Rocket filed the Motion to Dismiss 12/04/2024. Below is Francesca's complaint. Francesca publicly shared her identity and home address. She shares misinformation and articles about the false narrative of the alleged "racist white appraiser" in her complaint. October 2024 USA Today, NY Times mentioned her in their articles about the case. Here is one article with a photo of Francesca. She shared this information publicly so she is legally liable for defamation. There is no litigation privilege when you share false information publicly. This is why the Maryland appraiser sued the property owners. https://www.nytimes.com/2024/12/06/realestate/rocket-mortgage-lawsuit-appraisals.html

https://drive.google.com/file/d/1REwJ4TECl1g_1JzcVytpBAMK3i6k2hTw/view?usp=sharing

U.S. District Court - District of Colorado

District of Colorado (Denver)

CIVIL DOCKET FOR CASE #: 1:24-cv-02915-GPG-TPO

USA v. Rocket Mortgage, LLC et al

Assigned to: District Judge Gordon P Gallagher

Referred to: Magistrate Judge Timothy P O'Hara

Cause: 42:3612 - Civil Rights in Housing -- Enforcement by Secretary

Date Filed: 10/21/2024

Jury Demand: Plaintiff

Nature of Suit: 440 Civil Rights: Other

Jurisdiction: U.S. Government Plaintiff

Plaintiff

As I read the DOJ complaint the borrower believed maintenance items were improvements. They also did the craziest "appraisal" math using cost per bedroom of final value to give value to basement areas. They used average price per square foot of Denver area, average appreciation...many things an appraiser would not use. They mention the 10, 15, 25% guideline adjustments. Those are not mandatory. The issue was she could not refi her apx $550K loan with a value under $860K. Borrower does mention GLA, GBA issue. She complained about racial discrimination but did not file a ROV even when offered twice. She should have filed a ROV to deal with her issues.

ORIGINAL 07/16/2024: "HUD Charges Appraiser, Appraisal Management Company, and Lender with Race Discrimination WASHINGTON - The U.S. Department of Housing and Urban Development (HUD) announced today that it has charged multiple entities with housing discrimination for issuing a biased appraisal and then denying a refinance loan application in Denver, Colorado. HUD’s Charge against the appraiser, M* M*; appraisal company, M* Appraisal Group; appraisal management company, Solidifi U.S. Inc.; and lender, Rocket Mortgage, LLC, alleges that the appraiser issued a discriminatory appraisal that undervalued a Black homeowner’s property on the basis of her race. The Charge further alleges that, when the homeowner complained to Rocket Mortgage, Rocket Mortgage would only proceed with her refinance loan application based on the appraised value that she alleged was discriminatory."

This is the first complaint HUD has investigated in years. The lack of finished investigations is probably one reason why Marcia Fudge was shown the door. As usual there is no property address or borrower/owner name so we can't ascertain if the appraisal values were accurate or not. Of course there are no appraisals just values and dates. When we know the name or address we appraisers have been able to tell if the appraisal values were accurate or not. This is intentional so the public will never know and we must just believe the HUD press release.

This case sounds a lot like the Oakland case. Sounds like an area going through revitalization. Some homes are fully renovated and some are not. Values vary greatly based on specific location and condition per the data we have. HUD again brings up race of area. Appraisers never look at census records or race data. Race of area is from census records. Census has to do with who lives there and not who owns the property. There is the race income wealth correlation which means areas with more white occupants are probably worth more because they are probably fully renovated and in slightly better locations. This is an assumption based on research which shows white areas are worth more than black or Latino areas. I really wish they'd include the address so we wouldn't have to just guess and speculate. We will probably never know but based on my experience the higher ones are generally wrong. Lower ones are generally correct.

I predict the lender, AMC will settle for a slap on the wrist without admitting or denying guilt. They'll release a press release saying that have always been and always will be committed to fair housing. The appraiser will sadly settle without paying money because he can't afford to litigate. He will be forced to watch the mockumentary Lowballed strapped to a chair and attend a bias class by a private fair housing organization who was a friend of ex HUD chief Marcia Fudge. HUD will release news of the settlement stating they are helping POC obtain fair housing and loans. No one will ever know which appraisals were correct and which were not. No problems are solved. No one is helped. Things haven't changed. The PAVE task force was just a lot of talk and more administrative paperwork for lenders and appraisers.

https://www.hud.gov/press/press_releases_media_advisories/HUD_No_24_181

The charge

https://www.hud.gov/sites/dfiles/FHEO/documents/Charge_08-21-3530-8.pdf

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

Mary Cummins

Monday, July 8, 2024

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

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

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

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

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

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

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

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

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

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

Just found this on Peter Christensen's LinkedIn page.

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

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

> 11/18/20: $3.1m

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

> 1/26/21: $2.5m

> 6/3/21: $3.15m

> 6/20/21: $3.1m

> 8/20/21: $3.1m "

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

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

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

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

Mary Cummins

Friday, June 28, 2024

Glendale Metro Station aka Southern Pacific Railroad Depot by Mary Cummins

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

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

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

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

Mary Cummins

Saturday, June 8, 2024

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

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

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

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

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

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

Summary of response. They redacted name and address.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Appraiser John Dorie sent me this information about fire code.

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

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

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

without disagreement.

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

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

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

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

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

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

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

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

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

"Dear Custodian of Record,

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

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

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

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

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

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

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

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

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

Mary Cummins

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

Monday, August 5, 2024

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

Thursday, August 1, 2024

Appraisal Institute AI, National Association of Realtors NAR Zoom Webinar on NAR Settlement

Tuesday, July 16, 2024

HUD Bias Complaint Against Appraiser by Mary Cummins Real Estate Appraiser

Monday, July 8, 2024

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

Friday, June 28, 2024

Glendale Metro Station aka Southern Pacific Railroad Depot by Mary Cummins

Saturday, June 8, 2024

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