Sales Comparison Approach is Racist
“…the modern appraisal industry perpetuates racial inequality through its continued use of the “sales comparison approach”… the sales comparison approach persists as the dominant method of assessing home value… the sales comparison approach — the most used method for contemporary residential appraisals — perpetuates inequities through maintaining historical hierarchies and current racialized definitions of comparability…”
Appraisers, here’s a YouTube video that you MUST view. This person’s, Dr. Elizabeth Korver-Glenn, PhD, work is one of the key reasons why there is so much chatter about racist appraisers in the US.
Her discussion of her book ‘Race Brokers‘ begins at the 8:30 mark, so you can scroll to that point.
At the 26:30 mark, she discusses the aspects of why she believes appraisers are responsible for the low property values in certain neighborhoods.
At the 28:30 mark, she claims that appraisers are required to discuss ‘race’ in reports. That’s a blatantly inaccurate statement. But the problem is, other people who don’t understand our CURRENT appraisal processes believe this stuff.
Ms., or should I say Doctor-Professor Korver-Glenn, PhD, has managed to almost single-handily tar and feather appraisers by totally misunderstanding what we do in our work. “We” are the convenient target, according to her.
I’m convinced, after watching this YouTube video, that this is where so many of the media article comments have come from that advocate appraisers abandon the current protocols, and use sales ‘from anywhere’ in the community, regardless of location or similarity to the actual subject neighborhood. This is dangerous stuff folks.
That said, if you are fairly new in this profession, you may not know that governmental sponsored racial redlining was the accepted lending protocol, backed by maps and the GSE’s, FHA and VA appraisal guidelines, from the 1930s until the Fair Housing Law was passed in 1976. Dr. Korver-Glenn cites the Appraisal Institute textbooks of that era which did give instruction about how comparables should be picked and used, which corresponded to the government edicts. How could they not do that??
So yes, those Appraisal Institute textbooks were still in use when the law changed. It took a while for the appraisal protocols to be re-written to match the Fair Housing Law and incorporated into new textbooks. But the Appraisal Institute and other organizations began teaching to the new law once it was passed. The GSE’s, FHA and VA also changed their Selling Guides to reflect the law.
That means nowadays, NO discussion of racial composition in neighborhoods is permitted to be included in reports. Certain words cannot be used to denote how the buyers, or appraisers, perceive the neighborhood. We are REQUIRED to discuss the type of housing only and other non-racial or religious amenities in the area in factual terms.
Yet both GSE’s produced white papers last year, released to the media, which used RACIAL census tract data as a justification for why we appraisers don’t, or should, consider RACE in our work.
The entire emphasis of this specious PhD “research project” is that if appraisers would just quit the current protocols, per GSE, FHA and VA instructions, of appraising properties, then racial inequities will be magically erased, and property values of homes owned by certain people will be much more ‘fair’ than what is current.
That is absolute bunk.
Humans of all races tend to associate with ‘their own kind’ as a normal occurrence, or buy properties according to their economic status. It’s been this way for thousands of years on this earth, depending on the historical data source used.
Independent appraisers, who look at sale properties similar to and proximate to the subject cannot be held liable for how people want to live, their socio-economic status, or for the inequality of appraised values across regions. “We don’t establish values; we only report what we find.”
In my continuing effort to evaluate Dr. Elizabeth Korver-Glenn’s hypothesis that virtually all appraisers are racist, I’ve been digging deeper into the academic papers she has authored, or co-authored.
You may have seen where some people high up in the cafeteria food line are advocating radically changing how appraisals are done, in an effort to ‘equalize’ values across communities. The belief is if that is done, racial differences will magically subside. The paper below is one source of that belief.
Korver-Glenn, PhD, was the co-author of this academic paper, published in Sept. 2020.
This paper discusses the original red-lining that was mandated by the US GOVERNMENT and local communities, starting in the 1930s. The paper mentions that the Sales Comparison Approach of nearby properties was one process to evaluate and conclude ‘appraised’ values, starting back then when appraising became a profession. This process continues to this day. And the academics hate it!
In their paper’s conclusion, it says this:
From our analysis, we conclude contemporary appraising practices contribute to ongoing inequality. We argue they do so in two ways. First, the continued use of the sales comparison approach after fair housing legislation meant appraisers used previous sales, which explicitly relied on neighborhood racial composition, to determine appraisals. Since no steps were taken to rectify the historic inequities, this approach has enabled such inequalities to persist. Second, appraisers continue to use neighborhood racial composition to help determine which homes are comparable. In this way, much like historical practices (Taylor 2019), contemporary appraisers are constructing a racialized housing market and exacerbating racial inequality. Addressing the inequality created by racialized home appraisals will require transforming the appraisal industry.
At the policy level, we propose swift, dramatic interventions to transform the existing appraisal landscape. New regulatory legislation should decouple neighborhood demographic characteristics from home values and appreciation rates (see also Howell and Korver-Glenn 2018).
Additionally, policy makers need to consider how we can collectively offer reparations for explicitly racist housing policies that contributed to the systemic hyper-valuing of White neighborhoods and de-valuing of neighborhoods of color (especially between the 1930s and 1970s). Such considerations should also grapple with the dramatic divergence in home appreciation rates observed in the last 35 years: since 1980, homes in White neighborhoods appreciated $194,000 more than comparable homes in otherwise comparable communities of color.
By addressing these stark historical and contemporary inequalities in appraisals, we can also reduce growing inequality in other spheres. Because home value inequality is at the center of wealth, health, education, and occupational inequities, fairly evaluating home and neighborhood value is a key starting point for dismantling the historical and contemporary racialized housing market and generating equitable opportunities for communities of color.
This is just one example of multiple ‘research papers’ that throw independent appraisers under the bus.
It’s one that the folks high up in the cafeteria food line are using to attack ‘us’. Academics, who think they have all the knowledge but no actual first-hand appraisal experience, want to dismantle the appraisal process, but if you carefully note what they write, they offer no valid way to replace the current process with something else.
Doing the research I’ve done last weekend, it has become abundantly clear to me that Dr. Korver-Glenn’s philosophy and perspective has become entrenched in the minds of high US government officials.
This work of hers, and of others, is the basis for why independent appraisers have been under attack since 2018. It’s not coincidental that this happened after her PhD dissertation was approved and circulated in 2017.
Her paper’s title is this: Under Construction: Race and Housing Markets in 21st-Century Urban America
Why is this person so fixated on this topic? Well, on page 6 of her paper, she says this:
“I study race because I want to deconstruct it, and I want you (and everyone else) to be a part of a world in which race can be stripped of its hierarchical human difference.
That’s an admirable and lofty goal, and I admire her for the desire to eliminate racism. But frankly, after about 8000 years of humanoid or human existence on this planet, is it achievable? After all, she admits it is “hierarchical”, which basically means it’s a philosophy or ranking built into human psychology.
Dr. Korver-Glenn’s dissertation offers no concrete implementable ideas or suggestions as to how to solve ‘race’ problems in the valuation process. Rather she says that the way things are done now is wrong, and based on two revealed interviews with Houston, Texas appraisers, implies that appraisers overall are racists.
On page 126, she states
…my findings point to the need for solving the challenge of finding a form of governance in the relatively loosely-arranged institutional space of the housing market.
This is why we have been hearing so much about doing away with appraisers and appraisals, having valuations done by AVMs, using third parties to ‘inspect’ homes, etc. This is also why Representative Maxine Waters is proposing legislation that will RADICALLY change the appraisal process.
Don’t let your guard down folks. Damnation has been underway for a while, and unless other ‘structural changes’ are made, it’s not going to get any better.
After you watch this video, and take careful notes of what she presented, you may want to send her a polite email to give her a working appraiser’s point of view on this race and appraising topic. Here is her email address email@example.com.
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“appraisers continue to use neighborhood racial composition to help determine which homes are comparable…”
How does one search for comps by racial composition?? This shows a lack of true understanding of what we appraisers do & how we do it.
What a terrific and simply logical inquiry response. I tried VERY hard to search an entire county by racial composition. Such a search is, in addition to illegal, impossible. Good call.
Am I missing something? Do appraisers tell buyers where to buy and for how much? No, buyers and sellers create markets. Appraisers only report their activity. Can’t wait to sit in on one of these CE classes.
Until we see these appraisals, we will never know !
2055_05UAD – REPORT – Fair Lending – Comments in the Ending Addenda contain “black”, which could be a violation of fair lending practices. Please revise these comments so that there is no risk of a fair lending violation.
When rage quitting sound like the best option.
Legal Des: Black Forest Estates.
Sad times in America and I’m exhausted of it all.
The lies being portrayed in our profession are being hemorrhaged from other government bodies which appear to have a solid agenda and that is to control and equalize all housing prices by force based on race. Starting last month, I tell every homeowner they are not allowed in the home and that they need to lock up all valuables so that they are not within view. If you accuse every appraiser of being a racist then you now have to pay the price – we need to evolve as appraisers and beat the stupidity at their own game. Make it impossible for them to accuse us of any wrong doing.
So why are the Top Officials not demanding a change to the age old Real Estate Sales marketing & textbook mantra of “location, location, location”? Real Estate Agents market to Buyers, and push Buyers toward properties based on location which result in the Data we have to use for our Reports – should the process “modernization” not START there? We are last in line in the Financing process.
I believe this “PhD” wants appraisers to commit fraud by using homes outside a specific market to inflate values based on skin color calling that equity. NOT on my license
She reminds me of that scene in the movie Hunt for Red October where Alec Baldwin tells Sean Connery about a book he wrote. Connery scoffs and says “You wrote that book?! ….. your conclusions were all wrong”
She clearly “doesn’t know what she doesn’t know”.
Well, OK, if we appraisers are NOT going to use the “closest, most similar properties” as comparables, fine. But then we will have to apply this philosophy across the board, right? Those million dollar plus houses should be compared to the homes of similar size, wherever they are. Maybe we just average sizes for an entire state, or country if we’re going to be “fair” – the folks in California should have values equal to Mississippi or South Dakota. Why have appraisers at all? Just have the algorithms determine what people pay. No need for quality or age adjustments if we are using comps from wherever we want. And what are comps anyway? Sorry, just slid down…..the……rabbit hole…….ahhhh!
Does anyone else see what I see? Stupidityism has taken over as the worst “ism” there is. How sad that this so called doctor spends her days looking for another reason to be pissed off about life. Maybe if we add some fluffy cotton clouds in our appraisals, so people like her will go to bed at night knowing the world is safe until they wake up and start spewing again. Never thought in a million years our industry would be race baited like all the others. A good appraiser couldn’t play dumb even if they tried. Its call USPAP. And if they did, they would be the same 5% of the stupid people in this world who screw it up for the rest of us.
This all appears to be the age-old problem of ignorance, wait now before I get ousted by the Mods here it is…
Ignorance NOUN lack of knowledge or information: “he acted in ignorance of basic procedures” synonyms: incomprehension · unawareness · unconsciousness · inexperience · innocence · unfamiliarity with · lack of enlightenment about · lack of knowledge about · lack of information about · nescience · lack of knowledge · lack of education
To me… This is the same problem we have been fighting since appraising began. NO ONE KNOWS WHAT WE DO OR HOW! No one knows the value of our industry!!
Realtors don’t understand what we do, the public does not understand what we do and even the very people that are elected to act in the best interest of the public do not understand or know what we do. EVEN THE QCs, lenders and underwriters don’t all know how we as Appraisers really work and what we do! FNMA would not pass all the requirements they do with no consideration of the why and how their “ideas” and requirements improve anything and… FREDDIE MAC would not have the “white paper” about with the current topic if they did understand… Just saying. AND IF investors knew what we do and how our Industry helps in protecting their cash, do you think they would want the lenders to GET RID of us?
I also think we need to have some serious meetings with the Dept of Commerce APPRAISAL DIVISION and ask them for something more then silent support here.
NAR is the largest Lobbyist Group in the US and we NEED to get them on board to support us in this fight now. How much money does NAR and the MLS make from Appraisers? Will they miss that capitol if we are gone?
I REALLY think it’s time for US to take action and EDUCATE everyone we can on what we do.
Recently I contacted the Dept of Commerce Dept of Real Estate and Appraisal in my state and had a long discussion with the “powers that are in control”. I suggested that ALL Realtors be required to have much more in depth education in appraisal practices as part of the education and continuing ED programs. In fact I suggested a period of time of shadowing an appraiser as part of the education. Maybe that could be modified and worked out as to how this could be done or a variation of it completed.
Next we may just have to make ourselves available as speakers for community programs offered by lenders or create a school program offered to Seniors. We NEED TO EDUCATE THE PUBLIC as much as we can. We need to take the initiative to explain what we do and how. We need to design materials to be sent out or given to people at the time of the Appraisal or before with information and explanations on what we do, why and how. Almost all the complaints filed with the State officials on Appraisers are unfounded and due to lack of knowledge on the part of home owners, buyers and Realtors.
They say knowledge is power shouldn’t WE be using it to aid our industry against ALL of the attacks by all of the entities and everyone who wants us gone… or more regulated… or more educated or more steam-lined!!
How can we be an industry in the USA that has been in practice since the 30’s or before and NOT have any (or very little) effort in educating the public on what we do… how we do it and the value of our Industry to the public.
Now is the time to step it up not only on the very important issues we now face like the accusation of discrimination in out practice being discussed here but also the bifurcated appraisals, desk top appraisals and the never ending attempts to END us and our Industry. If we educated the public and pushed a campaign with NAR to educate the Realtors and educate and inform them, we could make a lot of head way IMO and ward off and may be even end many of these attacks. IF we start offering an educational program teaming up with Financial planners, Accountants and even local Boards of Realtors with State approved CE curriculum we may be able to get a head of the next campaign to get rid of us.
Maybe I am just dreaming but I think we CAN DO THIS!
I have spent many hours speaking to Banking & Realtor groups & Home Buyer seminars. The presentations at Realtors Groups typically end up being “bone picking” sessions during the Q & A portions and only a handful of Agents have taken me up on further info offers. Local Association Board Administrators usually say their hands are tied by the State AR & NAR.
We do not have a National Organization that is interested in advancing/defending the Residential side, only the Commercial side where the monetary and political gains are more lucrative.
Ba,. You ask me why a VA guy would care about uniform standard of measurement ANSI…. It is because They now will be instructed in their classes about how appraisers measure houses. And maybe, just maybe we can get better data from them.
Just one small step….
Except that a garden level IS NOT a basement.
Baggins… Garden levels are considered below grade areas for purposes of appraisal reporting and have been for more than 15 years now.
You must have been absent that day, it happens to the best of us.
Your propaganda has failed. Give it up. Garden levels are not basements.
I see you have a hard time respecting other peoples opinions.
No, we don’t have to agree. Nor will we ever.
Because garden levels are not basements.
Baggins….Propaganda ???? Failed ???? Give up ????
We don’t have to agree……I would love to put those areas under above grade GLA,.like I used too 15 years ago….I spent 20 minutes the other day trying to figure out a split level comp (3,500 sqft by assessor), but only 2,600 sqft above grade…..And I had to use 2 Two story colonials against it, my split level sale was 3,300 sqft above grade with 2 garden levels and 1/2 basement level….
FUN FUN FUN
The appraised value came in a little higher than the sales price…..I wrote the addendum, explained things and no under writer letter…..property settles this week.
Now we have ANSI…..How are you making out with the new rule…do you see a value difference yet between above grade, garden level and basement???
Of course I do not see a difference. Because in Colorado, we recognize garden level as ground level, not basement. Garden levels are not basements. Your broken record nonsense is getting old. Repeating something over and over again does not make it true.
And the market responds to garden level just like any other ground level, this space tracks at an equivalent price and value, where as truly below ground basements track at a lower price and value basis. All the MLS stats which use the RESO standard confirms this. Garden level space finds positive market acceptance at the exact same amount as any other ground level and/or above grade finished living space.
You are advocating for appraisers driving a different price and value basis than is actually true in these markets. That is incompetence, deception, market data manipulation, and you’re advocating on behalf of something which is not true. Appraisers do not set the market, we merely analyze the existing market data. You continue to make not just regular assumptions but rather extra ordinary assumptions which are not true to the Colorado markets, yet with no data what so ever, you continue to presume your statements are accurate, which they are not.
This argument is not settled and we are enlisting the help of appraiser groups, state regulatory agencies, our combined shared MLS systems, and various state chapters of NAR. FNMA has severely overstepped it’s boundaries and authority on the matter of mandatory ANSI. It appears there is quite a bit of incompetence over there too.
Again, as soon as everyone else adopts this standard, from the local municipalities rewriting a century of building code, a national Corelogic Matrix MLS system abandoning it’s 5+ year RESO real estate standards approach and revising every single MLS record, all assessors revising their records retroactively for millions of housing units, and all licensed realtors adopting ANSI, at that point it will be sensible for appraisers to voluntarily comply, and not a moment sooner. The grand dream of collectivism requires consensus and agreement, something which is not present on the matter of ANSI. You’re arguing to a wall because well over a hundred thousand licensed professionals in the state of Colorado do not use the ANSI standard.
Baggins.. I never said garden levels are worth the same as basements… That is just beyond stupid.
And you have had that stuck in your head for months now.
My question is… as you start to separate Garden levels from above grade, do you NOW see a value difference….???
Let us know…
Your question is illogical. Perhaps that is true in your markets but that is simply not true in Colorado. I would not presume to know your markets, having no practical experience there. In our Colorado markets, there is no market value difference in the response to above grade vs garden level. If at any time, anywhere, an appraiser is discovering some secret trend nobody else recognizes, that is more than likely a sign of incompetent or flawed analysis. The very basics of market valuation response analysis, there can only be a difference if buyers recognize a difference. In Colorado, the garden level tracks the same as any other above grade area. MLS statistics confirm, as realty agents continue to list and sell, and buyers continue to accept, an equivalent value amount for these spaces. Any assumptions otherwise would be contrary to market fact and would be reflective of incompetent analysis. Probably due to improperly co mingling garden level and basements in the same line, in markets which clearly recognize different value factors for those spaces. You may want to consider you may be wrong, and could be engaging in incompetent analysis with improper data co mingling. That would be true if you made such a ‘discovery’ here in Colorado. If garden levels track for less where you are at, fine, but that’s not true here.
FNMA has jumped the shark and put the cart before the horse here. Our local MLS system implemented RESO standards years ago which the work groups were in effect years before that. This is the standard we operate under. For FNMA to impose we utilize a different standard nobody else uses is absurd. They apparently did not bother consulting any of the major corporations we rely on, or the hundreds of additional software companies whom have furnished supportive applications which revolve around something other than ANSI standards. They did not consult with any of the assessors, our local NAR, the national NAR, Corelogic whom has plans to implement RESO nationwide through their systems, or our state regulatory bodies. The ANSI workgroup was of insufficient size and comprised of an insufficient body of people whom obviously have no experience operating in areas where other uniform standards are already in place.
Because some appraisers and realty agents elsewhere are engaging in blatant fraud such as counting open space areas as ground level, or were too incompetent to take the time to research their local municipal building code guidelines in the jurisdictions where they operate, now we all have to pay the price to manage their problems. We have a functional system in place now in places like Colorado and have no such problems which are the basis of FNMA’s position to implement a non negotiable ANSI standard. FNMA’s very basis for denying voluntary compliance with ANSI or not is deeply flawed.
We’re going to need three distinct home building spaces on the new FNMA forms to account for this. Above grade, garden level, and basement. Because now we’re going to need to separate above grade from garden level, even though we’ll adjust for those at the exact same amount. It’s a silly pointless exercise but given the existing forms improperly co mingle basement and garden level in the same line, now we need a workable solution. Because through entire counties there are hundreds and thousands if not millions of housing units where the recognition of building space is defined by the local municipal authorities, which everyone else follows those standards, where there is no practical distinction between garden level and above grade spaces. Entire networks of supported digital infrastructure have been developed over decades around this. FNMA is not going to change that.
“Further, because these standards are used across the industry, you’ll have access to third-party products that will bring you better and more affordable technology tools faster. Plus, it means your listing data will be consistent with national standards established by RESO.”
ANSI supporters are missing the big picture. This needs to be rescinded back to a voluntary standard. Use it if you want. We don’t need it, don’t appreciate it, and we’ve got problems because of it. A lot more work for no damned good reason and it’s going to confuse everyone whom relies on valuation services in states like Colorado. Which is why outside of FNMA, in the state of Colorado, hardly anybody uses ANSI.
Baggins .. One more final question
Are you trying to tell me that a 2200 ft² one-story ranch, all above grade, three bedrooms 20 years old is worth the same as a bi-level, three bedrooms with 1500 ft² above grade and 700 ft² garden level, are the same value in Colorado?
With everything being exactly the same?
If you answer me honestly, I will never bother you again.
Nope, that’s not it. ANSI will not effect ranch reporting. A ranch typically will sell for less than a bi, since basements track for less and are often unfinished, or if finished, not as well finished. One should not cross compare ranch vs non ranch as they often (but not always) have a different price and value metric. In some markets, ranches bigger better vaulted, track higher. In many others, ranches are the affordable more entry level homes with less space and less stature, the presence of basement is random. Sometimes I have to due to data scarcity but if at all possible, I will never comp a ranch vs non ranch. Ranch is in a category all it’s own, all others are fair game for cross comparisons.
A bi vs a tri vs a 2 story are better examples. Because for all three of those property types (presuming none have basements), if they were all the same size, they often will all sell for the same ppsf value metric if they’re in the same market setting with equivalent finish. It makes no sense to try and cut out the space into two different 1004 form reporting lines. Then toss in a legitimate basement on a tri (which will actually have 4 levels, basement under the mid level), or a two story with a basement full or partial, and it’s a sudden reporting mess. Because for those basement areas, they will track for less ppsf value metric than the garden and/or above grade levels.
Basically in CO, garden and above grade are the same thing, some even prefer the bi’s over 2 stories because they offer better energy efficiency and less maintenance, yet offer equivalent space. They can sell for the exact same amount but it will confuse report readers if the above grade/ and/or garden, are suddenly parsed into different reporting lines. Something will have to give, either the garden moves to it’s own line item reporting, or the basement will have to move to a line item and the lower garden/basement line on 1004 will only have the garden. Because if we start applying the same adjustment amount to a garden as we do an actual basement, we will be applying incorrect market response adjustments if the reporting figures are co mingled. ANSI forces us to scoot garden, which would otherwise go into the above grade line, now scooted into the basement line, and that’s the specific problem.
I posted the wrong link above. Corrected CO MLS size guide:
Gotta love how easy our local MLS makes this, because they simply followed municipal building code guidelines and did not confuse garden levels with basements. There is clear guidance to not intermingle those reporting spaces.
In my State the Dept of Commerce claims that there is not much communication from Appraisers (until this year with complaints against agents) So here at least the Appraisers are pretty silent and don’t suggest much. The local board here welcomes any education on Appraising it just has to be State approved for CE for most agents to even bother. OCAP does seem to take our concerns seriously for the most part.
NAR should be a little more interested in the issues but honestly FNMA had promised NAR that they would not ever lower Real Estate commissions on REO properties below 6% then less than a year later they lowered them to 2% for the LA, I spoke to Charlie Daniels at the time and he was not aware of the action by FNMA… NAR did nothing.
NAR recently sent out a notice to Realtors stating they will not be requiring agents to adopt any standardized measuring system including ANSI and the MLS for my State stated the same thing when I called. I’m not sure or any other States other than those surrounding OH though.
IF we could just get all States to have the same mindset and to implement the same rules/requirements that would be good for a start IMO.
It was just a suggestion I thought could be somehow implemented since it seems there are so many people that are affected, involved or in control of what we do and how we do it and who do not understand much about our industry, that it seems obvious that information could be very helpful.
Just my very humble opinion.
I’m written the local MLS, the state based NAR, and will also work to get the state regulatory agency in on this. People far far away have no business injecting their ideas into our local management programs.
Some people today just do not understand the principals of voluntary engagement. They should be careful what they wish for, drunk on the power of pushing other people around. Tables always turn eventually.