To conduct appraisal, redlining, and lending… (FHOI230072) – Project Grant to Fair Housing Advocates Of…

Activities: 1) intake, investigation, evaluation, and referral of complaints for enforcement actions related to appraisal and/or lending discrimination, including reviewing/refining referral process to refer potential victims to HUD, DOJ, a state or local agency, or a private attorney; referring any intake of fair housing complaints stemming from appraisal and lending outreach for processing under existing PEI grant; referring complaints to HUD and/or california civil rights dept (CRD), bureau of real estate appraisers (BREA), consumer financial protection bureau (CFPB), legal services agencies, or to private attorneys; recruiting and training 4 new testers for lending and appraisal investigations; conducting individual tests or investigations as opportunities arise; and evaluating complaints/evidence of lending and/or appraisal discrimination arising from client intakes or testing for enforcement actions; refer to PEI for filing complaints as appropriate. 2) systemic lending, redlining, and appraisal investigations: systemic testing projects to uncover patterns of lending discrimination based on race, including building upon previous national fair housing alliance (NFHA) training and working with NFHA to create methodology and strategies to test for race discrimination; developing methodology for lending audit designed to investigate selected lenders for race discrimination; using hmda data to conduct a scoping analysis of lenders in fhanc's service area to investigate race discrimination; using lendingpatterns to access and analyze hmda data, create market peer groups for the selected lenders, comparing the number of applications received from black borrowers with the adjusted aggregate of similar lenders to determine whether a significant lending disparity exists; using lendingpatterns to access and analyze hmda data, create market peer groups for the selected lenders, comparing the number of loans originated for black borrowers with the adjusted aggregate of similar lenders to determine whether a significant lending disparity exists; analyzing appraisal data and/or hmda data for selected lenders to determine whether a disparity exists in the percent of loan applications withdrawn or denied based on low appraisal value (or collateral) from black borrowers compared to white borrowers; mapping branch locations within lender's catch area for each of the selected lenders and using census data to compare the racial demographics of the census tracts where branches are located versus tracts where no branches are located to determine whether racial disparities exist; identifying the assessment area for the selected lenders and conducting assessment area analysis by reviewing census race data to determine whether lenders' assessment areas exclude areas with relatively high concentrations of black residents; for each selected lender, analyzing other relevant factors, such as the most recent CRA performance evaluation (if applicable), complaints received, branches closed, and/or other investigative data for evidence of race discrimination; conducting 6-10 matched paired lending tests (12-20 test parts) to investigate selected lenders for race discrimination; and synthesizing results of investigative tasks, analyzing testing results, redlining analysis, analysis of loan withdrawals or denials based on low appraisal values, and lender outreach and marketing activities to determine whether the selected lenders are providing unequal access to credit based on race
Expected outcomes: Outcome of complaint or lawsuit; 4 testers trained; complaint-based tests conducted as needed; cases evaluated for enforcement actions with appropriate cases referred. Lending, redlining, and appraisal investigations: enforcement staff trained in advanced fair lending testing strategies and methodology; methodology for lending, redlining, and appraisal investigations developed; market analysis conducted; 12-20 tests conducted of 6-10 lenders selected; comparison groups created; race discrimination investigated. Pre-purchase education and foreclosure prevention: homeowners of protected classes educated/counseled regarding foreclosure strategies and prevention options; prospective homeowners educated on the home buying process and on how to avoid lending and appraisal discrimination through six-hour workshops and distribution of brochures; literature distributed in english, spanish, and tagalog to increase awareness of fair housing protections for general and limited english proficiency (LEP) public; realtor groups/advocates educated through presentations, with increasing awareness of fair housing protections for better complaint referral; investigation results, relevant lessons learned, and best practices shared with other local, state, and national fair housing groups
Intended beneficiaries: Fhanc will serve homeowners and prospective homebuyers of protected classes through foreclosure prevention services and education on fair housing protections and the homebuying process. Fhanc will also serve advocates and realtors through education on fair housing protections, and serve protected classes, local, state, and national fair housing groups, and the general public through information and audit reports on investigation results
Subrecipient activities: Fhanc will subcontract with the national fair housing alliance (NFHA) to build upon previous national fair housing alliance (NFHA) trainings and take part in advanced lending testing training with NFHA to create methodology and strategies to test for race discrimination. Fhanc will consult with NFHA as needed during investigations. Fhanc will partner with other community-based organizations and government agencies that contribute to the success of the project.

To conduct appraisal, redlining, and lending investigations to uncover discriminatory practices, and to provide counseling, education, and training initiatives to prevent foreclosures and guide…

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