CC - Item 7A - Public Hearing on the Analysis of Imperdiments to Fair Housing ChoiceROSEMEAD CITY COUNCIL
STAFF REPORT
TO: THE HONORABLE MAYOR AND CITY COUNCIL
FROM: JEFF ALLRED, CITY MANAGER
DATE: MAY 11, 2010
SUBJECT: PUBLIC HEARING ON THE ANALYSIS OF IMPEDIMENTS TO FAIR
HOUSING CHOICE
SUMMARY
The City Council will consider review and approval of the City's Five Year Analysis of
Impediments to Fair Housing Choice covering the period July 1, 2010 through June 30,
2015. Localities seeking federal program funds are required to certify that they will
engage in fair housing planning; namely: (1) that they will conduct at the beginning of
each five-year cycle an analysis of impediments (AI) to fair housing choice; (2) that they
will carry out actions to overcome the effects of identified impediments; and (3) that they
will maintain records and make available information and reports, including the analysis
of impediments, to document actions undertaken to eliminate identified impediments.
Staff Recommendation
Staff recommends that the City Council take the following actions:
1. Conduct a public hearing and take public testimony on the Analysis of
Impediments to Fair Housing Choice covering the period July 1, 2010 through
June 30, 2015; and
2. Approve the Analysis of Impediments to Fair Housing Choice and authorize
the submittal of the document to the U.S. Department of Housing and Urban
Development;
ANALYSIS
On January 5, 1995, with the publication of the Consolidated Submission regulations for
Community Planning and Development programs, significant new program
requirements were established with regard to the long-standing obligation to
affirmatively further fair housing. The City's first Al was completed in 1997 by the Fair
Housing Council of San Gabriel Valley and the Center
year update to the City's Al was completed in 2000, and
the Southern California Housing Rights Center (HRC).
for Choice in Housing. A five-
then again in January 2006 by
ITEM NO.
APPROVED FOR CITY COUNCIL AGENDA:
City Council Report
May 11, 2010
Page 2 of 6
The City's Al is a comprehensive review of policies, procedures, and practices within
Rosemead that effect the location, availability and accessibility of housing, and the
current residential patterns and conditions related to fair housing choice. Fair housing
choice should be understood as the ability of persons of similar incomes to have
available to them the same housing choices, regardless of race, color, religion, sex,
disability, familial status, or national origin. An impediment to fair housing choice is an
action, omission, or decision taken because of race, color, religion, sex, disability,
familial status, or national origin, that restricts housing choices or the availability of
housing choice. It is also any action, omission, or decision that has this kind of effect.
Policies, practices, or procedures that appear neutral on their face, but which operate to
deny or adversely affect the provision of housing to persons (in any particular protected
class) may constitute such impediments.
The FY 2010-2015 Al established eight (8) potential impediments that are identified
below as well as the activities the City will carry out during the 2010-11 FY to address
these issues.
Current Fair Housing Profile
Housing Complaints from the Asian Population in Rosemead
Potential Impediment:
According to the 2000 census the Asian population made up 48.9% of the
Rosemead population. But only 23% of Rosemead residents assisted by the
Housing Rights Center over the past three years were Asian. The Rosemead
Asian population is reporting housing issues less frequently which may indicate a
need for more fair housing outreach and education to the Asian population in
Rosemead.
Actions Proposed to Overcome Potential Impediment
• Advertise Housing Rights Workshops in English and Chinese.
• Distribute an informational newsletter in English and Chinese in
• Rosemead that provides fair housing information in a Q & A format.
Housing Discrimination Complaints Based on Familial Status
Potential Impediment:
Over the past four years the highest number of housing discrimination complaints
by Rosemead residents have been based on disability. This may indicate a need
for more education of landlords on housing discrimination and people with
disabilities.
Actions Proposed to Overcome Potential Impediment:
• Highlight disability discrimination at Fair Housing Workshops in
Rosemead.
City Council Report
May 11, 2010
Page 3 of 6
• Distribute educational materials to Rosemead property owners on fair
housing and people with disabilities.
Audit Testing
The Housing Rights Center conducted 20 phone tests to measure levels of housing
discrimination in the City of Rosemead. All 20 tests measured discrimination against
people with disabilities.
The HRC found that 50% of the disability phone tests showed evidence of
discrimination against people with disabilities. Some examples of discrimination by
property owners/agents included flat-out denials of companion dogs and requiring a "pet
deposit" for companion dogs. This could indicate intentional discrimination against
people with disabilities. It may also indicate a lack of awareness of the fair housing laws
that protect people with disabilities from housing discrimination.
Actions Proposed to Overcome Potential Impediment:
• Coordinate literature mailings to property owners using an available
database of property owners (the City's business license database,
property search database, etc.).
• Create an annual newsletter that will highlight a current fair housing
topic or recent changes in housing law. Coordinate mailings to property
owners using an available database of property owners (the City's
business license database, property search database, etc.).
Community Survey
The Housing Rights Center conducted a survey of 32 Rosemead residents.
Respondents were asked how familiar they were with laws that provide protection
against housing discrimination. The survey showed that 47% of respondents had no
knowledge of the fair housing laws and 34% had very little knowledge of the fair housing
laws. The low level of awareness of the fair housing law may indicate the need for
increased education and outreach activities in Rosemead.
Actions Proposed to Overcome Potential Impediment:
• Submit public service announcements to local cable channels
regarding fair housing laws.
• Publish articles on current fair housing topics in the Rosemead
community newsletter.
Rosemead Zoning Ordinance
HRC reviewed provisions of the Rosemead Municipal Code ("RMC"), specifically Title
15 (Buildings and Construction) and Title 17 (Zoning), for compliance with state and
federal fair housing laws.
City Council Report
May 11, 2010
Page 4 of 6
Overly Restrictive Definition of Family
Potential Impedimenta
Section 17.04.020 of the Rosemead Zoning Code has an overly restrictive
definition of family. This definition restricts thehousing choices of individuals
with disabilities because it places numerical limits on unrelated person. The
definition of "family" must emphasize the functioning of the members as a
cohesive household and cannot distinguish between related and unrelated
persons.
Actions Proposed to Overcome Potential Impediment:
• Prepare a new definition of family and amend the zoning code
accordingly.
Definitions of Bachelor Apartment
Potential Impediment:
Section 17.04.020 of the Rosemead Zoning Code defines a bachelor apartment
as "[A]n apartment of dwelling unit in a multiple dwelling or apartment house,
occupied or suitable for occupancy as a residence for one person." This
occupancy limit could lead property owners to discriminate against families with
children or couples in violation of federal and state fair housing laws.
Actions Proposed to Overcome Potential Impediment:
• Remove the definition of a bachelor apartment from the zoning code.
Reasonable Accommodations
Potential Impediment:
Pursuant to fair housing laws and also the Americans with Disabilities Act
("ADA"), the City of Rosemead should provide for reasonable accommodations
for persons with disabilities.
Actions Proposed to Overcome Potential Impediment:
• Prepare a notation for the off-street parking and nuisance abatement
ordinances that explains that accommodations are available to people
with disabilities.
• Prepare an accommodation application procedure
Rosemead Home Mortgage Disclosure Act Data
HMDA data indicates that as the minority population percentage at the census track
level increases, the loan approval rates decrease and the denial rates increase. There
is also slight evidence of racial approval gaps between Asian American and Hispanic
applicants. In the higher income categories, Asian Americans have higher approval
rates and lower denial rates than Hispanics.
City Council Report
May 11, 2010
Page 5 of 6
Actions Proposed to Overcome Potential Impediment.
Distribute information materials to Rosemead residents regarding
lending discrimination.
Conduct a Fair Lending Workshop for Rosemead residents.
The analysis of impediments to fair housing choice in any community is a delicate and
tedious process. The City recognizes the effect that discrimination has in limiting
housing choice and equal opportunity in renting, selling, and financing housing. During
the 2010-11 FY, the City will continue to address the potential impediments identified in
the City's Al. By addressing these issues, the City hopes to take incremental steps
toward overcoming and eliminating all the impediments identified in the City's Al.
By contracting with a Fair Housing Organization to implement a Fair Housing Program
within Rosemead during the 2010-11 FY, the City hopes to provide an extensive and
comprehensive community education program to inform the community about fair
housing laws. This will allow the City to make a significant impact in affirmatively
furthering the goal of fair housing choice.
During the 2010-11 FY, the City will also make a significant impact in affirmatively
furthering fair housing and eliminating impediments to fair housing choice by offering
housing programs without impediments based on race, color, religion, sex, disability,
familial status, or national origin. The City continually increases the awareness of the
availability and benefits of City programs regarding housing choice and housing
assistance through public information to the community. This information is distributed
to the community in a number of ways, including notices placed in newspapers and on
the City's newsletter. This proves to be a positive impact on the community by ensuring
that the community is aware of the different services provided by the City.
The City plans to continue making a significant effort toward affirmatively furthering fair
housing and eliminate impediments to fair housing choice that are within its authority
during the period of July 1, 2009 to June 30, 2010. The City has an ongoing
commitment to preventing, reducing, and ultimately eliminating housing discrimination
and other barriers related to equal opportunity in housing choice.
PUBLIC NOTICE PROCESS
Notice of the public hearing was published in the San Gabriel Valley Tribune on April
26, 2010, as well as through the regular agenda notification process.
Prepared by:
Michelle G. Ramirez
Economic Development Administrator
City Council Report
May 11, 2010
Page 6 of 6
Submitted by:
a ong
Community Development Director
Attachment A - Analysis of Impediments to Fair Housing Choice Study
Analysis of Impediments to Fair Housing Choice
For
The City of Rosemead
Prepared By:
The Housing Rights Center
520 S. Virgil Avenue, Suite 400
Los Angeles, CA 90020
(213) 387-8400
(800) 477-5977
Fax (213) 381-8555
www.hrc-la.org
April 2010
Table of Contents
1. Executive Summary 1
A. Purpose of Analysis 1
B. Data Sources and Methodology 2
C. Key Findings and Recommendations 3
II. Demographic Profile of Rosemead
6
A.
Population Growth by Households and Families
6
B.
Age
6
C.
Racial Composition
7
D.
Income
7
E.
Poverty Rates
8
F.
Employment
9
G.
Education
9
H.
Housing Conditions
10
III. Evaluation of Current Fair Housing Profile 12
A. Client Demographic Profile 12
B. Summary of Housing Discrimination Complaints 14
C. Requests for Assistance with General Housing Concerns 15
IV. Rental Audit Testing in Rosemead 17
A. Purpose of the Audit 17
B. Audit Methodology 17
C. Audit Results 18
D. Conclusion 26
V. Analysis of Phone Surveys 27
A. Demographic Profile of Respondents 27
B. Analysis 28
C. Conclusion 33
VI. Review of Government Policies
34
A. Direct Conflicts
34
B. Potential Conflicts
35
C. Other Relevant Considerations
36
VII. Home Mortgage Disclosure Act Data 37
A. Access to Housing Credit in Rosemead-General Background 37
B. Access to Housing Credit in Rosemead-Local Practices 39
C. Access to Housing Credit in Rosemead-Conclusion 57
I. EXECUTIVE SUMMARY
A. Purpose of Analysis
The Department of Housing and Urban Development (HUD) requires "actions to
affirmatively further fair housing" of all jurisdictions that receive funds through the
Consolidation Submission. HUD requires each jurisdiction to certify that it "will engage
in fair housing planning by:
(1) conducting an analysis of impediments to fair housing choice at the beginning of
each five-year cycle;
(2) Carrying out actions to overcome the effects of identified impediments;
(3) Maintaining records and making available information and reports, including the
analysis of impediments, and to document actions undertaken to eliminate
identified impediments."
As a result, each jurisdiction is required to develop an Analysis of Impediments to
Fair Housing Choice. Thus, the City of Rosemead is required, pursuant to 34 CFR
570.904 (c), to conduct "...[an] analysis to determine the impediments to fair housing
choice for its housing and community development programs and activities." The
Department of Housing and Urban Development (HUD) defines "impediments" as:
"any actions, omissions, or decisions taken because of race, color, religion, sex,
disability, familial status or national origin that restricts housing choices or the
availability of housing choices of these protected classes."
The term "fair housing choice" is defined as: the ability of persons of similar income
levels in the same housing market area to have a like range of choice available to them
regardless of race, color, religion, sex, national origin, familial status, disability, marital
status, ancestry, sexual orientation, source of income or arbitrary characteristics such
as age.
As a result, the City of Rosemead has contracted with the Housing Rights Center
(HRC) to perform this analysis of fair housing choice.
City of Rosemead page 1 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
B. Data Sources and Methodology
The report that follows is the result of a comprehensive review of policies,
procedures, and practices within the City of Rosemead that affect the location,
availability, and accessibility of housing and current residential conditions related to fair
housing choice. Specifically, HUD encouraged: (1) sources of relevant demographic
information and data, (2) sources of authoritative studies of housing discrimination, (3)
methods for obtaining diverse citizen participation in development, implementation, and
evaluation of fair housing planning, and (4) corrective actions and solutions.
Accordingly, this report is primarily based on the following sources of information:
• Rosemead Census Data: The HRC compared census data from 1990 and
2000.
• Housing Rights Center Complaint Data: HRC used housing complaint
statistics for the period July 1, 2005 to June 30, 2009.
• Rental Audit Testing: The HRC conducted random audit testing of Rosemead
rental units to determine levels of discrimination based on disability. The HRC
conducted 20 phone tests.
• Phone Survey of Rosemead Residents: The HRC conducted a phone survey
of Rosemead residents throughout the city.
• Rosemead Zoning Code: The HRC reviewed provisions of the Rosemead
Municipal Code ("RMC"), specifically Title 15 (Buildings and Construction) and
Title 17 (Zoning), for compliance with state and federal fair housing laws.
• Home Mortgage Disclosure Act (HMDA) data for Rosemead: The HRC
compared HMDA data from 2006, 2007 and 2008.
City of Rosemead page 2 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
C. Key Findings and Recommendations
This Analysis of Impediments Study analyzed data (census, fair housing
complaint), audit tests and surveys to identify barriers to fair housing choice in the City
of Rosemead. This section provides a list of key potential impediments that may exist in
Rosemead and recommendations to address them. For each recommendation, please
also refer to the particular chapter that led to the recommendations.
1. Current Fair Housing Profile (Section III)
a. Housing Complaints from the Asian Population in Rosemead
According to the 2000 census the Asian population made up 48.9% of the
Rosemead population. But only 23% of Rosemead residents assisted by the Housing
Rights Center over the past three years were Asian. The Rosemead Asian population is
reporting housing issues less frequently which may indicate a need for more fair
housing outreach and education to the Asian population in Rosemead.
Recommendation
• Advertise Housing Rights Workshops in English and Chinese.
• Distribute an informational newsletter in English and Chinese in
Rosemead that Drovides fair housino information in a Q & A format.
b. Housing Discrimination Complaints Based on Disability
Over the past four years the highest number of housing discrimination complaints
by Rosemead residents have been based on disability.' This may indicate a need for
more education of landlords on housing discrimination and people with disabilities.
Recommendation
• Highlight disability discrimination at Fair Housing Workshops in
Rosemead.
• Distribute educational materials to Rosemead property owners on fair
housing and people with disabilities.
2. Audit Testing (Section IV)
The Housing Rights Center conducted 20 phone tests to measure levels of
housing discrimination in the City of Rosemead. All 20 tests measured discrimination
against people with disabilities.
' This percentage is based on Section III, Table 3.5, Housing Discrimination Complaints Reported by
Rosemead Residents. The total number of complaints over the past four years is 57. Of this number 36
were based on physical or mental disability.
City of Rosemead page 3 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
The HRC found that 50% of the disability phone tests showed evidence of
discrimination against people with disabilities. Some examples of discrimination by
property owners/agents included flat-out denials of companion dogs and requiring a "pet
deposit" for companion dogs. This could indicate intentional discrimination against
people with disabilities. It may also indicate a lack of awareness of the fair housing laws
that protect people with disabilities from housing discrimination.
Recommendations
• Coordinate literature mailings to property owners using an available
database of property owners (the City's business license database,
property search database, etc.).
• Create an annual newsletter that will highlight a current fair housing topic
or recent changes in housing law. Coordinate mailings to property owners
using an available database of property owners (the City's business
license database, property search database, etc.).
3. Community Survey (Section V)
The Housing Rights Center conducted a survey of 32 Rosemead residents.
Respondents were asked how familiar they were with laws that provide protection
against housing discrimination. The survey showed that 47% of respondents had no
knowledge of the fair housing laws and 34% had very little knowledge of the fair housing
laws. The low level of awareness of the fair housing law may indicate the need for
increased education and outreach activities in Rosemead.
Recommendations
• Submit public service announcements to local cable channels regarding
fair housing laws.
• Publish articles on current fair housing topics in the Rosemead community
newsletter.
4. Rosemead Zoning Code (Section VI)
HRC reviewed provisions of the Rosemead Municipal Code ("RMC"), specifically
Title 15 (Buildings and Construction) and Title 17 (Zoning), for compliance with state
and federal fair housing laws.
a. Overly Restrictive Definition of Family
Section 17.04.020 of the Rosemead Zoning Code has an overly restrictive
definition of family. This definition restricts the housing choices of individuals with
disabilities because it places numerical limits on unrelated persons. The definition of
"family" must emphasize the functioning of the members as a cohesive household and
cannot distinguish between related and unrelated persons.
Recommendation
• Prepare a new definition of family and recommend that the city amend the
zoning code to reflect this revised definition.
City of Rosemead page 4 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
b. Definitions of Bachelor Apartment
Section 17.04.020 of the Rosemead Zoning Code
as "[A]n apartment or dwelling unit in a multiple dwelling
or suitable for occupancy as a residence for one person
lead property owners to discriminate against families with
of federal and state fair housing laws.
Recommendation
defines a bachelor apartment
or apartment house, occupied
This occupancy limit could
children or couples in violation
The City should remove the definition of a bachelor apartment from the
zoning code.
c. Reasonable Accommodations
Pursuant to fair housing laws and also the Americans with Disabilities Act
("ADA"), the City of Rosemead should provide for reasonable accommodations for
persons with disabilities.
Recommendation
• Prepare a notation for the off-street parking and nuisance abatement
ordinances that explains that accommodations are available to people with
disabilities.
• Prepare an accommodation application procedure.
4. Rosemead Home Mortgage Disclosure Act Data (Section VII)
HMDA data indicates that as the minority population percentage at the census
track level increases, the loan approval rates decrease and the denial rates increase.
There is also slight evidence of racial approval gaps between Asian American
and Hispanic applicants. In the higher income categories, Asian Americans have higher
approval rates and lower denial rates than Hispanics.
Recommendation
Distribute information materials to Rosemead residents regarding lending
discrimination.
Conduct a Fair Lending Workshop for Rosemead residents.
City of Rosemead page 5 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
II. DEMOGRAPHIC PROFILE OF ROSEMEAD
The following analysis was constructed from 1990 and 2000 Census data. This
section highlights selected demographic changes between 1990 and 2000 in order to
evaluate some key demographic characteristics and what they might mean to housing
access and affordability.
A. Population Growth by Households and Families
The City of Rosemead experienced an increase in population between 1990 and
2000. The city's population rose from 51,638 in 1990 to 53,505 in 2000 representing an
increase of 3.62%. The number of total households increased slightly from 13,701 in
1990 to 13,913 in 2000 which represents an increase of 1.55%. The number of persons
per household also rose slightly from 3.72 in 1990 to 3.80 in 2000. There was also an
increase (3.56%) in the number of families. The number of families grew from 11,228 in
1990 to 11,628 in 2000. The number of persons per family increased as well from 4.08
in 1990 to 4.11 in 2000.
There were, however, some notable changes among the above population
categories. While the percentages of families (3.56%) and families with children
(17.48%) increased, there was also an increase in female-headed households
(14.72°/x). The number of female-headed households grew from 2,106 in 1990 to 2.416
in 2000.
Table 2.1 Population. Household. and Familv Chances: 1990 and 2000
Category
1990
2000
% Change
Total Population
51,638
53,505
3.62
# of Households
13,701
13,913
1.55
# of Persons per household
3.72
3.80
2.15
# of Families
11,228
11,628
3.56
# of Persons per Family
4.08
4.11
0.74
# of Families with Children
5,166
6,069
17.48
# of Female-Headed
Households
2,106
2,416
14.72
B. Age
The age composition of residents changed over the ten-year period between
1990 and 2000. The changes for children (under 18 years of age) were slight, however,
for seniors (over the age of 65) the changes were more significant. The population of
people under 18 years of age decreased from 15,677 in 1990 to 14,729 in 2000, which
was a change of 6.05%.
City of Rosemead page 6 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
In 1990, there were 4,635 people over the age of 65 years of age. In 2000, there
were 5,685 people over the age of 65 years. The percentage change in the proportion
of people over 65 years of age reflects an increase of 22.65%.
Table 2.2 Youth and Senior Changes: 1990 and 2000
Category
1990
2000
% Change
Po ulation under 18 ears
15,677
14,729
-6.05
Population over 65 ears
4,635
5,685
22.65
C. Racial Composition
In 1990, 35.4% of the population was White. In 2000, however, Whites only
represented 26.6% of the population. During this same period, the American Indian,
Asian/Pacific Islander and Black population increased. The American Indian population
increased from 0.5% in 1990 to 0.9% in 2000, people of Asian/Pacific Islander
increased from 34.3% in 1990 to 48.9% in 2000 and the Black population increased
from 0.6% in 1990 to 0.7% in 2000. The Hispanic Origin population decreased. The
Hispanic population dropped from 49.7% in 1990 to 41.3% in 2000. The census
indicates that the majority of the population of Rosemead is Asian/Pacific Islander.
Table 2.3 Percentage of Racial Composition and Change: 1990 and 2000
Racial Composition
1990
2000
Difference
American Indian
0.5
0.9
0.4
Asian/Pacific Islander
34.3
48.9
14.6
Black
0.6
0.7
0.1
Hispanic Origin
49.7
41.3
-8.4
White
35.4
26.6
-8.8
D. Income
Overall, there were significant increases in the amount of income for Rosemead
residents. The median household income increased from $29,770 to $36,181 (21.5%
change) and the median family income increased from $30,905 to $36,552 (18.3%
change). Similarly, the median per capita income rose from $9,796 to $12,146 (24.0%
change).
City of Rosemead page 7 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Table 2.4 Chanaes in Income for Families and Households: 1990 and 2000
Income Categories
1990
2000
% Change
Median Household Income
29,770
36,181
21.5
Median Family Income
30,905
36,552
18.3
Median Per Capita
9,796
12,146
24.0
Median household incomes among all major ethnic groups increased. The
median household income for people of Hispanic origin increased from $27,935 in 1990
to $35,162 in 2000 representing a 25.9% increase. Similarly, Asian/Pacific Islander and
Whites also had a higher median household income. Asian/Pacific Islander increased
from $32,462 in 1990 to $36,919 in 2000 representing a 13.7% increase. The median
income for Whites increased from $28,791 to $36,287 in 2000 (26.0% change). The
median household income for people of Black origin in 2000 was $25,357. The median
household income for people of Black origin was not available for 1990.
Table 2.5 Chanaes in Income By Race: 1990 and 2000
Median Household Income by
Race
1990
2000
% Change
Asian/Pacific Islander
32,462
36,919
13.7
Black
25,357
Hispanic Origin
27,935
35,162
25.9
White
28,791
36,287
26.0
*Indicates that 1990 census data was not available for this category.
E. Poverty Rates
Families making less than the poverty level increased from 16.2% in 1990 to
19.4% in 2000: The poverty rate for individuals increased from 20.0% in 1990 to 22.8%
in 2000. Similarly, there was an increase in poverty rates for female-headed
households from 25.2% in 1990 to 31.4% in 2000.
Table 2.6 Changes In Poverty Rates for Families, Individuals, and Female-Headed
Households: 1990 and 2000
Poverty Rates
1990
2000
Difference
Families
16.2
19.4
3.2
Individuals
20.0
22.8
2.8
Female-Headed Households
25.2
31.4
6.2
Poverty rates by race show that the Asian/Pacific Islander population had the
highest levels of poverty and the White population had the lowest poverty rates in 1990.
Poverty rates for most races increased. Poverty rates dropped for Asian/Pacific Islander
from 24.3% in 1990 to 24.2% in 2000 and increased for Whites by 12.8% from 1990 to
18.5% in 2000 (44.5%). Blacks poverty rates increased dramatically from 2.8% in 1990
to 36.9% in 2000. Data for people of Hispanic Origin was not available for 1990.
City of Rosemead page 8 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Table 2.7 Chanaes In Povertv Rates by Race: 1990 and 2000
Poverty Rates
1990
2000
Difference
Asian/Pacific Islander
24.3
24.2
-0.1
Black
2.8
36.9
34.1
Hispanic Origin
22.4
White
12.8
18.5
5.7
"Indicates that 1990 census data was not available for this category.
Similar to national trends, there were large declines in the lowest income levels and
increases in the highest income levels. It must be noted that the income figures were
not adjusted for inflation and reflect increases in nominal income only and not
necessarily increases in purchasing power.
Table 2.8 Chances In Household Income Distribution: 1990 and 2000
Income Distribution
1990
2000
Difference
Less than $5,000
5.1
Less than $10,000
9.0
9.3
0.3
$10,000 - $14,999
9.8
7.7
-2.1
$15,000 - $24,999
17.7
17.4
-0.3
$25,000 - $34,999
17.0
13.5
-3.5
$35,000 - $49,999
16.5
17.2
0.7
More than $50,000
25.0
34.9
9.9
`Indicates that 2000 census data was not available for this category.
F. Employment
Labor force participation rates decreased in Rosemead from 61.4% to 54.2%
between 1990 and 2000. The unemployment rate also decreased from 8.4% in 1990 to
7.5% in 2000.
Table 2.9.Changes in Labor Force Participation Rate & Unemployment Rate: 1990
and 2000
Labor Rates
1990
2000
Difference
Labor Force Partici ation Rates
61.4
54.2
-7.2
Unemployment Rates
8.4
7.5
-0.9
G. Education
Education levels for the population of Rosemead varied between 1990 and 2000.
The number of residents with less than a 9th grade education rose from 26.0% in 1990
to 29.7% in 2000. High school education (no diploma) dropped from 20.1% in 1990 to
17.1% in 2000. In 1990, the proportion of high school graduates or higher was 22.0%,
City of Rosemead page 9 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
but by 2000 had decreased to 18.9%. In 1990 10.0% of the population had a Bachelor
Degree or higher and by 2000, 12.9% had a Bachelor Degree or higher.
Table 2.10 Chanoes in Education: 1990 and 2000
Level of Education
1990
2000
Difference
Less than 9 Grade
26.0
29.7
3.7
9 to 12 Grade (No Diploma)
20.1
17.1
-3.0
High School or Higher
22.0
18.9
-3.1
Bachelor Degree or Higher
10.0
12.9
2.9
H. Housing Conditions
The number of housing units increased from 14,134 in 1990 to 14,345 in 2000
representing an increase of 1.5%. The median value of owner-occupied housing
dropped from $193,900 in 1990 to $182,200 in 2000, a decrease of -6.0%. In 1990,
49.3% of housing was owner occupied and in 2000 it decreased slightly to 48.8%.
Similarly, vacancy rates dropped from 3.1% in 1990 to 3.0% in 2000. Of the homes
vacant in Rosemead in 1990, 1.2% were for sale and 2.1% were for rent. In 2000, 1.0%
of vacant units were for sale and 2.2% were for rent.
Table 2.11 Selected Housing Data: 1990 and 2000
Housing Data
1990
2000
% Change
Median Owner Occupied Home Value
193,900
182,200
-6.0
Number of Housing Units
14,134
14,345
1.5
Difference
%Vacant Rate
3.1
3.0
-0.1
%Vacant for Sale
1.2
1.0
-0.2
%Vacant for Rent
2.1
2.2
0.1
Owner Occupied
49.3
48.8
-0.5
% Renter Occupied
50.7
51.2
0.5
The top part of the table below reveals that 40.0% of owner occupied housing
was Asian/Pacific Islander, 0.3% Black, 38.0% Hispanic Origin, and 51.6% White in
1990. In 2000, 52.7% of owner occupied housing was Asian/Pacific Islander, 23.4%
Black, 37.0% Hispanic Origin and 50.1% White. The bottom part of the table reveals
that Asian/Pacific Islanders occupied 11.8% of housing in 1990 and 52.3% in 2000. In
1990, 7.2% of Blacks were in owner occupied housing and 18.7% in 2000. Owner
occupied housing by the Hispanic Origin population increased dramatically, 10.0% in
1990 to 36.4%. Finally, the percentage of Whites in owner occupied housing increased
from 19.1 % in 1990 to 49.4% in 2000.
City of Rosemead page 10 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Table 2.12 Occupied Housing B Race: 1990 and 2000
Percentage of Owner Occupancy by Race
1990
2000
Difference
Asian/Pacific Islander
40.0
52.7
12.7
Black
0.3
23.4
23.1
Hispanic Origin
38.0
37.0
-1.0
White
51.6
50.1
-1.5
Percentage of Race in Owner Occupied
Housing
Asian/Pacific Islander
11.8
52.3
40.5
Black
7.2
18.7
11.5
Hispanic Origin
10.0
36.4
26.4
White
19.1
49.4
30.3
Table 13 reveals that in 2000 Rosemead homeowners are using more of their
monthly income towards the mortgage payment then they did in 1990. However,
Rosemead renters are using less of their monthly income toward the rent payment then
they did in 1990.
Table 2.13 Percentage of Income Spent on Housing: 1990 and 2000
Owner Occupied
1990
2000
% Change
Less than 20.0%
3,138
2,802
-10.7
20 to 24 percent
620
715
15.3
25 to 29 percent
527
534
1.3
30 to 34 percent
420
429
2.1
35 percent or more
1,301
1,584
21.8
Renter Occupied
Less than 20.0%
1,548
1,785
15.3
20 to 24 percent
933
836
-10.4
25 to 29 percent
731
715
-2.2
30 to 34 percent
553
531
-4.0
35 percent or more
2,820
2,921
3.6
City of Rosemead page 11 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
III. EVALUATION OF CURRENT FAIR HOUSING PROFILE
All entitlement cities are required by HUD to have a pro-active and reactive fair
housing program with specific actions and procedures that will have an impact on
preventing, reducing, and eliminating housing discrimination and barriers to equal
housing choice.
The City of Rosemead has worked in conjunction with the Housing Rights
Center2 to affirmatively further fair housing opportunities for over a decade. HRC was
originally founded in 1968. HRC's mission is to actively support and promote fair
housing through education and advocacy, to the end that all persons have the
opportunity to secure the housing they desire and can afford, without discrimination
based on their race, color, religion, gender, sexual orientation, national origin, familial
status, marital status, disability, ancestry, age, source of income or other characteristics
protected by law.
The City of Rosemead contracts with the HRC to provide its residents with fair
housing services that include discrimination complaint intake and investigation,
education and outreach, information and counseling and legal services.
A. Client Demographic Profile
Overall, 84% of Rosemead residents assisted by the HRC in the past four years
were extremely low or low-income individuals and families.
Table 3.1 Income Level of Rosemead Clients
Income Level
July 1, 2005 to
June 30, 2006
July 1, 2006 to
June 30, 2007
July 1, 2007 to
June 30, 2008
July 1, 2008 to
June 30, 2009
Total
Extreme) Low
97
64
74
117
352
Low
73
89
54
34
250
Moderate
30
29
28
13
100
Above Moderate
9
3
2
0
14
Total
209
185
158
164
716
In 2002 the U.S. Department of Housing and Urban Development required
recipients of Community Development Block Grant funds to use new race and ethnicity
categories when collecting demographic information from clients. This changed the
HRC's process of collecting client information in that clients are first asked to identify
their race and then to identify whether they are Hispanic.
During the past three years, the highest number of Rosemead residents assisted
by the HRC were Other (27%), followed by Asian (23%). The reason the percentage of
clients who identified as "Other" is so high is that Hispanic/Latino is not a separate race
2 The Housing Rights Center was formerly named the Fair Housing Council of San Gabriel Valley. The
name change took effect April 1, 2002.
City of Rosemead page 12 of 58
Analysis of Impediments to Fair Housing Choice
Apil 2010
category according to the US Census. Most often when asked their race, Hispanic
Latino clients identify as "Other."
According to the 2000 census the Asian population made up 48.9% of the
Rosemead population. But only 23% of Rosemead residents assisted by HRC over the
period July 1, 2005 to June 30, 2009 were Asian. However this is an increase when
compared to the period July 1, 2002 to June 30, 2005 when only 15.6% of the clients
assisted by HRC were Asian. This is likely due to HRC's increased outreach efforts to
the Asian population in Rosemead.
Conversely, the Hispanic population made up 41.3% of the Rosemead
population and 51% of Rosemead residents assisted by the HRC over the past four
years. Hispanics are overrepresented and Asians underrepresented in their reporting of
housing issues as compared to their representation in the Rosemead population.
Tahle A 9 Rarer of Rncemead Clients
Race
July 1, 2005 to
June 30, 2006
July 1, 2006 to
June 30, 2007
July 1, 2007 to
June 30, 2008
July 1, 2008 to
June 30, 2009
Total
Am Ind or Alsk
17
6
0
2
25
Am Ind/Alsk & Black
11
1
15
0
27
Am In/Alsk & Wht
70
56
40
0
166
Asian
47
30
52
39
168
Asian & White
0
0
0
0
0
Black/African Am
5
5
0
0
10
Blk/African Am &
Wht
0
0
0
0
0
Other
19
32
38
101
190
Pacific Islander
1
0
0
0
1
White
39
55
13
22
129
Total
209
185
158
164
716
Tnhla 3 A Fthniritv of Qn9PmPad Clients
Ethnicity
July 1, 2005 to
June 30, 2006
July 1, 2006 to
June 30, 2007
July 1, 2007 to
June 30, 2008
July 1, 2008 to
June 30, 2009
Total
Cuban
0
0
0
0
0
Mexican/Chicano
101
70
56
44
271
Other
His anic/Latino
10
27
17
39
93
Puerto Rican
0
0
0
1
1
Not His anic/Latino
98
88
85
80
351
Total
209
185
158
164
716
City of Rosemead page 13 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
While the number of female-headed households has gradually increased over
the past four years from 11 in 2005/06 to 23 in 2008/09, the number of seniors has
radically fluctuated. In 2005/06 the number of Rosemead seniors who contacted the
HRC was 20, which decreased to 13 in 2006/07 and by 2008/09 had increased to 17.
Not surprisingly the number of people with disabilities that contacted HRC over the past
four years has remained relatively consistent. As you will also see in Table 3.5 the
highest number of discrimination complaints received by the HRC in the past four years
are based on disability.
Table 3 d Nnmher of Female Headed Hnucahnlds_ Senior and Disabled Clients
Household Info
July 1, 2005 to
June 30, 2006
July 1, 2006 to
June 30, 2007
July 1, 2007 to
June 30, 2008
July 1, 2008 to
June 30, 2009
Total
Female Head of
Household
11
14
21
23
69
Senior
20
13
14
17
64
Disabled
20
12
19
19
70
B. Summary of Housing Discrimination Complaints
From July 2005 to June 2009, the Housing Rights Center received 57 housing
discrimination complaints from Rosemead residents. The highest number of complaints
were based on physical and mental disability, which together made up 63% of all
discrimination complaints. This is drastically different from the period July 2002 to June
2005 when the highest number of complaints was based on familial status, which made
up 32% of all complaints.
Table 3.5 Housina Discrimination Complaints Reported by Rosemead Residents
Basis of
Complaint
July 1, 2005 to
June 30, 2006
July 1, 2006 to
June 30, 2007
July 1, 2007 to
June 30, 2008
July 1, 2008 to
June 30, 2009
Total
Age
1
1
Arbitrary
1
1
Familial Status
6
1
1
8
Gender
1
1
Marital Status
1
1
2
Mental Disability
2
4
3
9
National Origin
1
1
2
Physical Disability
13
5
6
3
27
Race
1
1
1
3
City of Rosemead page 14 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
IGeneral Info. 3 1 1
Total 21 12 13 11 57
Of the 57 complaints, 31 were counseled 3, 2 were referred and 24 were
investigated. The Housing Rights Center found evidence to support the allegation in 17
cases and in 7 cases the evidence was inconclusive 4. HRC successfully conciliated 14
cases, in 3 cases the client withdrew, and in 7 cases no enforcement action was
possible.
C. Requests for Assistance with General Housing Concerns
In addition to fair housing complaint intake and investigation, the HRC assists
Rosemead residents with general housing concerns particularly landlord/tenant issues.
In the last four years, the HRC has received 659 requests for information or assistance
with housing concerns.
Tahle 3.6 Number of Rosemead Residents with General Housina Issues
Year
# of Complaints
Jul
1, 2005 to June 20, 2006
188
Jul
1, 2006 to June 30, 2007
173
Jul
1, 2007 to June 30, 2008
145
Jul
1, 2008 to June 30, 2009
153
Total
659
While most of the tenant/landlord concerns are not directly identified as
discrimination issues, many of the calls are related to concerns about displacement,
harassment, or failure to provide basic services.
3 The main reason HRC counsels clients who present housing discrimination allegations is that, upon a
thorough interview with the client, HRC finds that the allegation is not based on housing discrimination.
Other reasons include clients who, after talking to HRC staff, do not want the agency to pursue an
investigation or tell us that they only want housing discrimination educational information.
4 HRC assigns cases a disposition of "No Enforcement Action Possible" when there is inconclusive
evidence of discrimination.
City of Rosemead page 15 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Table 3.7 Types of General Housing Issues
Landlord/Tenant
Complaints
July 1, 2005 to
June 30, 2006
July 1, 2006 to
June 30, 2007
July 1, 2007 to
June 30, 2008
July 1, 2008 to
June 30, 2009
Total
Eviction
12
18
15
20
65
Harassment
3
1
0
5
9
Lease Terms
8
8
7
14
37
Notices
53
36
44
35
168
Rent Increase
24
30
18
17
89
Repairs
9
2
6
6
23
Security Deposit
10
20
10
11
51
Seeking Housing
12
10
5
9
36
Substandard
Conditions
22
11
10
13
56
Generallnfo/Other
35
37
30
23
125
Total
188
173
145
153
659
City of Rosemead page 16 of 59
Analysis of Impediments to Fair Housing Choice
April 2010
IV. RENTAL AUDIT TESTING IN ROSEMEAD
A. Purpose of the Audit
1. Introduction
To measure the extent of discrimination in the rental market, the Housing Rights
Center conducted 20 phone tests within the City of Rosemead. All 20 tests measured
the level of discrimination against people with disabilities. The results of the audit tests
suggest that housing discrimination exists in the City of Rosemead. The discrimination
rarely took the form of outright exclusion. Instead, more subtle actions emerged such as
discouraging statements and a less friendly property owner/manager demeanor.
2. Goal
The goal of the audit was to determine if there was a pattern or practice of
steering or providing unfavorable treatment to prospective renters in the City of
Rosemead based on disability or familial status. The audit examined housing agent
behavior in the inquiry stage of the rental process. It is important to note that not all
forms of differential treatment in the housing transaction are of equal seriousness.
Nevertheless, all forms of unfavorable treatment to be documented in this audit have
the potential to impede an individual's efforts to obtain housing of his or her choice.
By controlling for legitimate business concerns such as income, length of
employment, and length of tenancy (see methodology below), we hope to determine
whether people with disabilities are given the same housing opportunity as their
counterparts without disabilities in their efforts to find rental housing.
B. Audit Methodology
1. Overview of Testing
Testing is an enforcement tool used by the Housing Rights Center to determine
whether housing professionals engage in discrimination in violation of federal and state
fair housing laws5. HRC generally conducts these tests at the inquiry level when the
applicant first inquires about housing. A test involves a minority group tester referred to
as a "protected tester" and a majority group tester referred to as a "control tester" who
both visit the same housing unit for rent or for sale. The protected tester always visits
the unit first and is carefully chosen to ensure she or he is a superior applicant to the
matching "control" tester with regard to income, number of years at current employer,
etc. The matching of testers is extremely important because it removes any business
justifications for rejecting the applicant.
Once both testers view the unit, they are required to complete a standardized
report documenting their experience. We are careful to ensure the two testers have no
contact with one another. The test coordinator then analyzes the reports to determine if
the testers have experienced discrimination based on the established criteria noted
below.
e The courts have repeatedly endorsed testing and recognized the important role that testers play in
gathering evidence of discrimination in areas where such evidence is particularly hard to come by.
Havens Realty Corp. v. Coleman. 455 U.S. 363 (1982).
City of Rosemead - page 17 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
2. Phone Testing
For protected classes such as race and national origin, it is necessary to conduct
on-site tests in order to adequately measure differential treatment in the rental and sales
process. Through our experience with testing, we have found that in most cases, phone
testing is adequate to measure discrimination based on disability. In a fair housing
phone test, a minority group tester and a majority group tester are matched on all
relevant characteristics. These characteristics include age, income, employment and
time at job. Characteristics are assigned to the applicant by the test coordinator. The
tester merely pretends to work in a certain profession, make a certain amount of money,
and/or assumes whatever characteristics have been assigned to him or her.
The testers then separately call the housing provider, usually the property owner
or manager, within an hour of one another. The protected tester always makes the first
call. For disability tests, the protected tester is required to tell the housing provider that
he or she will need a reasonable accommodation due to a disability. If these criteria
aren't met, the test is incomplete.
The testers are trained to carefully listen and later objectively record the details of
their experiences on the standardized reporting forms. These forms include specific
questions as well as a narrative. HRC designed its tester forms to ensure that each
tester reports his or her experience in sufficient detail so as to determine whether the
testers remained "similarly situated" during the test. A test coordinator examines the
report forms to determine whether the testers were given the same information and
treatment.
3. Number and Type of Tests
The Housing Rights Center conducted a total of 20 phone inquiry Disability tests.
Each paired test was measured for differential treatment in the housing transaction,
including differences in the quantity, content and accuracy of information and quality of
service given to each home seeker by a property owner or manager.
4. Target Area Selection
HRC used Internet services such as www.westsiderentals.com, www.craigslist.com
and local newspapers to identify rental vacancy listings.
C. Audit Results
The Housing Rights Center conducted 20 phone tests to measure discrimination
against people with disabilities.
6 In the tests HRC conducted in Rosemead, the Protected Disabled Tester required the use of an
assistance animal (companion dog to help alleviate symptoms of a mental disability). Under the disability
provision of the fair housing law, an individual with a disability can request a reasonable accommodation,
or change, in rules, policies, practices, or services, in order to have the same use and enjoyment of a
dwelling as a person who does not have a disability. In the example of a "no pet" policy, a person with a
disability can request an exemption from the policy to accommodate her need for a companion dog.
City of Rosemead page 18 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
1. Audits Finding Evidence of Discrimination
Of the 20 Disability tests conducted in Rosemead, 10 tests (50%) showed
evidence of discrimination based on disability. Tests 1, 3, 5, 7, 12, 15, 16, 17, 18, and
20 produced evidence of differential treatment based on disability.
In Test 1 the housing provider did not flat out reject the service animal but told
the Protected Disabled Tester that she would be required to pay a pet deposit. A pet
deposit is commonly charged in addition to the regular deposit when a housing provider
allows pets, but wants to obtain a higher security deposit to cover damage that might be
caused by the pet.
This practice of collecting a pet deposit when the animal provides assistance to a
person with a disability is unlawful. 7 A person with a disability can request a reasonable
accommodation to a "no pet" policy and to a "pet deposit" policy. This accommodation is
in the form of an exception to the rule. Housing providers often use the "flood gates"
argument and claim that they will then have to allow anyone to have a pet. This
argument is not correct because the "no pet" policy can remain in place for tenants that
do not have disabilities.
In Tests 3 and 20 the agent told the Protected Disabled Tester that she did not
allow pets. In response the Protected Disabled Tester told the agent that she had a note
from her doctor about the dog. In both Tests, the agent said she would look into it but
never called the Protected Disabled Tester back.
In Tests 5 and 7 the housing provider flat out rejected the Protected Disabled
Tester after she said that the unit would be for her and her companion dog. In both tests
the Protected Disabled Tester said the companion dog was prescribed by her doctor.
The housing provider responded in both tests that dogs were not allowed.
In Test 12 the Protected Disabled Tester told the housing provider that the unit
was for her and her companion dog that was required by her doctor. The housing
provider told the Protected Disabled Tester that dogs were not allowed because the
previous tenant had a cat that ruined the carpet and that kids at the property would want
to play with the dog. As a final rejection the housing provider stated that the dog would
cause too much damage to the property.
In Test 15 the housing provider didn't reject the Protected Disabled Tester upon
finding out about the companion animal but insisted the Protected Disabled Tester
would have to pay a $2,300 security deposit. The housing provider stated that this was
because the carpet would have to be changed when the Protected Disabled Tester
moved out. The Control Tester was also quoted a $2,300 security deposit but was told
that amount was negotiable.
In Test 16 the agent asked the Protected Disabled Tester numerous questions
about the dog. The agent wanted to know if it was an indoor dog and asked about the
dog's size. The Protected Disabled Tester answered the questions and added that the
See Joint Statement of the Department of Housing and Urban Development and the Department of
Justice, "Reasonable Accommodations Under the Fair Housing Act," p. 9, n. 11 (May 17, 2004) ("Housing
providers may not require persons with disabilities to pay extra fees or deposits as a condition of
receiving a reasonable accommodation.')
Also in HUD v. Guenther, No. HUDALJ 08-00-0390-8, the U.S. Department of Housing and Urban
Development (HUD) prosecuted a case where a landlord charged a pet deposit for service animal. HUD
was able to get a consent decree that required the landlord to attend fair housing training, perform 40
hours of community service and pay the complainant $3,500.
City of Rosemead page 19 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
dog was prescribed by her doctor. The agent stated that she would have to check with
her sister who owned the house. The agent never called back.
In Test 17 the Protected Disabled Tester told the agent that the unit would be for
her and her companion dog. The agent stated that he was not the owner and would
have to look into the matter. The Protected Disabled Tester later called back and the
agent told her that the manager does not allow dogs. The Protected Disabled Tester
told the agent she had a note from her doctor for the dog. The agent responded that he
might allow the dog if the Protected Disabled Tester got renter's insurance. The agent
then recommended another available unit that accepted tenants with cats.
In Test 18 the agent told the Protected Disabled Tester that they didn't accept
dogs after the Protected Disabled Tester stated that the unit would be for her and her
companion dog. The Protected Disabled Tester went on to state that the dog was
prescribed by her doctor. The agent then told the Tester to call the manager. The
Protected Disabled Tester called the manager and told him the unit would be for her
and her companion dog. The manager did not comment on the dog. In this test the
agent and manager seemed to have different policies.
Audit #
-1 Protected: Disabled Control: Not Disabled
Location
Rosemead, 91770-1972
Finding
♦ The protected tester stated that the unit would
be for her and her companion dog. The agent
Evidence of
said that a pet deposit would need to be paid.
Discrimination
♦ Both testers were quoted $895 for the rent,
$895 security deposit and $30 for the credit
check. They were both asked to bring their
social security card and pay stubs.
♦ The control tester was told of a move in
special of 2 weeks free.
Audit #
-3 Protected: Disabled Control: Not disabled
Location
Rosemead, CA 91770-3571
Finding
♦ The protected tester stated the unit would be
for her and her companion dog and that she
Evidence of
had a note from her doctor for the dog. The
Discrimination
agent told the protected tester they do not
allow pets. The protected tester asked the
agent if she would grant an exception. The
agent said she would look into it but didn't call
back.
♦ The protected tester was told that the first
month's rent is free.
♦ Both testers were quoted $1,000 for rent,
$1,100 for the security deposit, and a $30
credit check fee.
City of Rosemead page 20 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Audit #
-5 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-3257
Finding
♦ The protected tester stated that the unit would
be for her and her companion dog. The agent
Evidence of
told the protected tester that there are no pets
Discrimination
allowed. The protected tested told the agent
that the companion dog was prescribed by her
doctor. The agent repeated that no pets were
allowed.
♦ Both testers were quoted $1,550 for rent,
$1,550 for the security deposit, and a $30
credit check fee.
Audit #
-7 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-2329
Finding
♦ The protected tester stated that the unit would
be for her and her companion animal that was
Evidence of
prescribed by her doctor. The agent said that
Discrimination
they do not accept dogs. The protected tester
repeated that the dog was prescribed by her
doctor. The agent's response was that under
no circumstances do they allow dogs.
♦ Both testers were quoted $699 in rent, $900
security deposit, and a $35 credit check fee.
Audit #
-12 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-3243
Finding
♦ The protected tester told the agent the unit
would be for her and her companion dog that
Evidence of
was required by her doctor. The agent said
Discrimination
that dogs are not allowed because the
previous tenant had cats that ruined the
carpet. The agent also said there are also kids
there that would want to play with the dog. The
agent stated that the dog would cause too
much damage to the property.
♦ The protected tester was quoted $1,100 for
the rent and $1,200 for the security deposit.
♦ The control tester was told that there were two
units available, one in the front renting for
$1,200 and the other one renting for $1,100.
The control tester was also told that the
security deposit was negotiable and there was
a $25 credit check fee per adult.
City of Rosemead page 21 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Audit #
-15 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-3430
Finding
♦ The protected tester stated that the unit would
be for her and her companion dog. The agent
Evidence of
told the tester that she would need to pay a
Discrimination
$2,300 deposit because they would have to
change the carpet when she left.
♦ The control tester was quoted $2,300 for the
deposit but that it was negotiable.
♦ Both testers were quoted $2,000 for the rent
and a $25 credit check fee.
Audit #
-16 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-2462
Finding
♦ The protected tester told the agent that the
unit would be for her and her companion dog.
Possible
The agent asked if the dog was an indoor dog
Evidence of
and if it was a small dog. The protected tester
Discrimination
told the agent it was a small poodle and is an
indoor dog but she takes it out for bathroom
breaks. The agent said she didn't own the
house and would need to talk to her sister who
is the owner. The protected tester said the dog
was prescribed by her doctor. After calling
back and leaving a message for the agent, the
protected tester did not receive a call back
from the agent about the dog.
♦ Both testers were quoted $875 in rent and
$875 for the security deposit.
Audit #
-17 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-1305
Finding
♦ The protected tester told the agent the unit
would be for her and her companion dog. The
Evidence of
agent said he was not the owner therefore he
Discrimination
would need to look into the matter. The
protected tester offered to call back in order to
confirm the pet policy. The protected tester
waited before calling back and the agent told
the tester "the manager does not allow dogs."
The protected tester told the agent she had a
note from the doctor for the dogs and the
agent responded that he might allow it if she
gets renter's insurance. The agent told the
protected tester about another available unit
where cats were acceptable.
City of Rosemead page 22 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
♦ Both testers were quoted $700 in rent, $1,000
for the security deposit and no credit check
Audit #
-18 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-2076
Finding
♦ The protected tester stated that the unit would
be for her and her companion dog. The agent
Possible
said that they didn't accept dogs. The tester
Evidence of
explained that the dog was prescribed by her
Discrimination
doctor but the agent instructed her to call the
manager instead. The tester called the
manager and stated the unit would be for her
and her companion dog but the manager did
not comment about the dog.
♦ The protected tester was quoted $1,150 in
rent, a $30 credit check fee, and that the
security deposit was dependent on the credit
score. If she had good credit, the security
deposit would be equal to one month's rent.
♦ The control tester contacted the agent but was
asked to call the manager. The tester called
the manager but the call went to voicemail.
Audit #
-20 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-1227
Finding
♦ The protected tester stated the unit would be
for her and her companion dog. The agent
Possible
said there is a "no pets" policy and she would
Evidence of
need to talk to the manager. The agent said
Discrimination
she would call the tester back. After 24 hours
there was no return call from the agent or the
manager
♦ Both testers were quoted $1,200 for the rent
and $1,200 for the security deposit. The
control tester was quoted $35 for the credit
check fee.
2. Audits with No Evidence of Discrimination
Of the 20 Disability tests conducted in Rosemead, 10 tests (50%) showed no
evidence of discrimination based on disability. Tests 2, 4, 6, 8, 9, 10, 11, 13, 14, and 19
did not produce evidence of discrimination based on disability.
In all of these Tests the housing providers allowed the companion animals. The
housing providers also quoted the same rental amounts, security deposit amounts, and
credit check fees to both the Protected Disabled Tester and the Control Tester.
City of Rosemead page 23 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
The one exception was Test 11. In this test the Protected Disabled Tester told
the agent the unit would be for her and her companion dog. The agent initially said no to
the companion dog but then the Protected Disabled Tester told the agent that the dog
was prescribed by her doctor, weighed less than 20 pounds and does not bark
consistently. The agent then responded that if the Protected Disabled Tester needed
the dog then it would be fine.
Audit #
-2 Protected: Disabled Control: Not disabled
Location
Rosemead, 91770-1316
Finding
♦ The protected tester stated that the unit would
be for her and her companion dog.
No Evidence of
♦ Both testers were quoted $800 for rent, $800
Discrimination
for the security deposit and no credit check
fee.
Audit #
-4 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-1384
Finding
♦ The protected tester stated that the unit would
No Evidence of
be for her and her companion dog.
Discrimination
♦ Both testers were quoted $750 in rent, $750
for the security deposit and a $30 credit check
fee.
Audit #
-6 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-3019
Finding
♦ The protected tester stated that the unit would
be for her and her companion dog that is
No Evidence of
prescribed by her doctor.
Discrimination
♦ Both testers were quoted $975 in rent, $975
for the security deposit and $25-$30 credit
check fee.
Audit #
-8 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-1973
Finding
♦ The protected tester stated that the unit would
be for her and her companion dog. The agent
No Evidence of
told the tester that dogs were not accepted.
Discrimination
The tester explained that the dog was for her
depression and that she had a prescription
from her doctor. The agent told the tester that
as long as she had the paperwork it would be
fine to have the dog.
♦ Both testers quoted $835 in rent, $835 for the
security deposit and a $25 credit check fee.
City of Rosemead page 24 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Audit#
-9 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-1151
Finding
♦ The protected tester stated the unit would be
for her and her companion dog that the dog
No Evidence of
was prescribed by her doctor. The agent made
Discrimination
no comment but Cp asked if there was a pet
deposit and the agent said no.
♦ Both testers were quoted $1,600 for the rent,
$1,600 for the security deposit a $20 credit
check fee.
Audit #
-10 Protected: Disabled Control: Not Disabled:
Location
Rosemead, CA 91770-4208
Finding
♦ The protected tester stated the unit would be
for her and her companion dog. The agent
No Evidence of
asked if it was a large dog. The protected
Discrimination
tester told the agent it was a little Shih Tzu that
was prescribed by her doctor. The agent said
that it would be fine.
♦ Both testers were quoted $700 for the rent and
$1,000 for the security deposit.
Audit #
-11 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-3320
Finding
♦ Once the protected tester told the agent that
the unit would be for her and her companion
No Evidence of
dog the agent said no to the companion dog.
Discrimination
The protected tester explained to the agent
that it was prescribed by her doctor, weighed
less than 20 Ibs and does not bark
consistently. The agent said that if she needed
the companion dog that it would be fine.
♦ Both testers were quoted $1,200 for the rent
and $1,200 for the security deposit. The agent
told both testers that there was no charge for
the credit check.
Audit #
-13 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-2345
Finding
♦ The protected tester stated that the unit would
be for her and her companion dog.
No Evidence of
♦ Both testers were quoted $1,100 in rent and a
Discrimination
$500 security deposit.
♦ Both testers were told that the credit check fee
was $25.
City of Rosemead page 25 of 57
Analysis of Impediments to Fair Housing Choice
April 2010
Audit #
-14 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-3656
Finding
♦ The protected tester stated that the unit would
be for him and his companion dog. The agent
No Evidence of
said that pets were now allowed. The tester
Discrimination
explained that the dog was prescribed by a
doctor and the agent said it would be okay.
♦ Both testers were quoted $1,195 in rent and
$1,000 for the security deposit.
Audit #
-19 Protected: Disabled Control: Not Disabled
Location
Rosemead, CA 91770-1457
Finding
♦ The tester stated that the unit would be for her
and her companion dog that was prescribed
No Evidence of
by her doctor.
Discrimination
♦ Both testers were quoted $1,300 for the rent
and $2,000 for the security deposit
D. Conclusion
Of the 20 disability phone tests conducted, 10 produced evidence of differential
treatment based on disability. Overall 50% of the tests showed some evidence of
discrimination. These results show that discrimination is occurring in the pre-
application rental process in Rosemead.
City of Rosemead page 26 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
V. ANALYSIS OF PHONE SURVEYS
This chapter analyzes data gathered from community members through surveys
conducted by the Housing Rights Center. The goal of the survey was to find out if
current residents of the City of Rosemead experienced discrimination when looking.for
property to rent or purchase. Respondents were asked a series of questions to
measure the prevalence and type of housing discrimination, if any, that they
experienced as residents of Rosemead.
A. Demographic Profile of Respondents
The participants of the survey were 32 individuals who are currently residents of
the City of Rosemead. The respondents were randomly chosen from the Yahoo! Yellow
Pages. Thirty-two (32) were taken via telephone through random selection from the
Yahoo! Yellow Pages. Twenty (20) of the respondents were female and twelve (12)
were male.
All 32 respondents were asked to give their age. Overall, the highest number of
respondents were 66 and over (31
Table 5.1 Ages of Respondents
Age
Male
Female
Percent
18-25
3
1
13%
26-35
4
3
22%
36-45
0
2
6%
46-55
2
1
9%
56-65
1
5
19%
66+
2
8
31%
Preferred not to state
0
0
0%
age.
Total
12
20
100%
The 32 respondents were also asked to give their annual income. The highest
number of respondents had annual incomes less than $20,000 (50%).
Table 5.2 Income of Respondents
Age
Male
Female
Percent
Less than $10,000
0
8
25%
$10,001-$20,000
5
3
25%
$20,001-$30,000
1
5
19%
$30,001-$40,000
2
1
9%
$40,001-$50,000
1
0
3%
$50,001-$60,000
0
0
0%
More than $60,000
1
3
13%
Preferred not to state
2
0
6%
income.
Total
12
20
100%
City of Rosemead
page 27 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Of the 32 respondents, five (5) were single person households, eight (8) were
from two-person households, five (5) had three in the household, nine (9) had four in the
household, three (3) had five in the household, one (1) had an eight person household
and one (1) had nine in the household.
B. Analysis
1. Finding Housing in the City of Rosemead
Respondents were first asked if they had experienced problems when trying to
find housing in Rosemead. The majority of respondents stated they had never had
problems finding housing in Rosemead. Sixty-nine percent (69%) of the respondents
said they had 'never' experienced problems when finding housing in Rosemead, nine
percent (9%) reported they had 'sometimes' had problems finding housing in
Rosemead, and sixteen percent (16%) indicated that they 'always' experienced
problems when looking for housing in Rosemead and (6%) refused to answer the
question.
Table 5.3 Problems finding housing in Rosemead
Frequency
Percent
Never
22
69%
Sometimes
3
9%
Always
5
16%
Did Not Answer
2
6%
Total
32
100%
Respondents were next asked what resources they used to find housing in
Rosemead. Respondents were given a variety of different response categories including
(1) newspaper rental listings, (2) driving around, (3) rental listings in magazines, (4)
word of mouth, (5) internet rental listings, (6) fee-based rental listings, (7) city resources
(listings), (8) Project Place-8 and (9) Other. Thirteen percent (13%) of respondents said
they drove around to find housing, 13% said they heard about housing vacancies
through word of mouth, and 6% used newspaper rental listing. Interesting to note is that
44% of respondents used sources not listed on the survey. The other sources identified
by respondents were real estate agents, friends, and family. In addition, 3% of
respondents stated they did not remember the source they used.
8 Project Place is a listing service provided to the public by the Housing Rights Center.
City of Rosemead page 28 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Table 5.4 Resources used to find housing
Frequency of "Yes"
Percent
Newspaper rental listings 2 6%
Driving around 4 13%
Rental listings in magazines 1 3%
Word of mouth 4 13%
Internet rental listings 1 3%
Fee based rental service 3 9%
City resources (listings) 2 6%
Project Place 0 0%
Other resource 14 44%
Did not remember 1 3%
Total 32 100%
Sixty-three (63%) stated they found housing in Rosemead within a month of
starting their search.
Table 5.5 How long to find housing in Rosemead
Frequency Percent
Less than a week
13
41%
Less than 2 weeks
2
6%
Less than a month
5
16%
Less than 2 months
6
19%
Less than 3 months
0
0%
More than 3 months
4
12%
Did not remember
2
6%
Total
32
100%
Respondents were also asked to state the type of housing in which they lived.
The majority of respondents lived in purchased single-family homes (66%) and the
remaining respondents lived in rental units (34%).
Table 5.6 Type of housing
F
Percent
Rental Unit (apartment, house, 11 34%
duplex, etc.)
Mobile Home 0 0%
Singe Family Home (purchased) 21 66%
Total 32 100%
2. Prevalence of Housing Discrimination in the Rosemead Housing Market
All respondents were asked whether they had ever had any language or
communication difficulties when looking for housing in Rosemead and how familiar they
were with the laws that provide protection against housing discrimination. If
respondents stated they were familiar with the fair housing laws, they were then asked
how they learned about these laws. After this series of questions, respondents were
City of Rosemead page 29 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
asked a second set of questions that were based on their current type of housing: (1)
rental housing; (2) mobile home, or (3) purchased home. This second series of
questions was specifically tailored to the type of home in which the respondent stated
they currently lived.
First, respondents were next asked if they had ever experienced language or
communication difficulties when looking for housing in Rosemead. The majority of
respondents who answered this question (88%) stated they had not experienced
language or communication difficulties when looking for housing in Rosemead.
Table 5.7 Language or communication difficulties when looking for housing
Frequency Percent
Yes
3
9%
No
28
88%
Did not answer
1
3%
Total
32
100%
Respondents were also asked how familiar they were with housing laws that
provide protection against housing discrimination. Fifteen (47%) indicated that they
were "not at all" aware of the fair housing laws. In addition to this, eleven (34%) of
respondents stated they were "a little bit" familiar with the fair housing laws and six
(19%) stated they were "a lot" familiar with fair housing laws. These results indicate that
the Housing Rights Center needs to increase the level of fair housing outreach to the
Rosemead community.
Table 5.8 Familiarity with housing laws that protect against housing
discrimination
Frequency
Percent
Not at all
15
47%
A little bit
11
34%
A lot
6
19%
Did not answer
0
0%
Total
32
100%
Of the respondents who said that they were "a little bit" or "a lot" familiar with fair
housing laws, fourteen (14) told surveyors where they had learned about the fair
housing laws. Two (2) indicated they had received information from City Hall, two (2)
received information from other tenants or friends, two (2) learned about fair housing
from television public service announcements, four (4) read about fair housing in the
newspaper, two (2) learned information from school, one (1) learned about fair housing
by contacting a fair housing organization and one (1) learned about fair housing on the
internet.
a. Rental Housing
As indicated in Table 5.6, eleven (11) respondents stated they lived in rental
housing. Each respondent was asked a series of ten questions to uncover whether he
City of Rosemead page 30 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
or she had ever experienced any different treatment because they belonged to a group
protected by the fair housing laws.
Of the 11 respondents who were asked if they had ever felt discriminated against
when renting property in Rosemead, nine (82%) indicated that they had never felt
discriminated against, one said he was discriminated against once or twice and one
stated he was discriminated against often. Although is seems low that only two
respondents out of eleven indicated they felt discriminated against, if these eleven
respondents are representatives of Rosemead residents, than housing discrimination
could be occurring frequently in rental housing.
Table 5.9 Ever felt discriminated against when renting
Frequency
Once or twice
1
Often
1
Did not answer
0
Total
11
Percent
b2W/o
9%
9%
0%
100%
For the respondent who said that they had felt discriminated against when
renting property in Rosemead, the survey next asked a follow-up question regarding
how the respondent handled or dealt with the situation. The respondents were given six
choice categories which were: (1) contacted City Hall, (2) contacted a fair housing
organization, (3) contacted the police, (4) contacted a lawyer, (5) did nothing about it
and (6) looked for another place to live. The two respondents who reported that they
had experienced discrimination "once, twice or often" indicated they 'did nothing about
it' and 'looked for another place to live.'
Next, respondents were asked if they have ever been charged higher fees for
their apartment for any reason. Of the 11 respondents who answered this question, six
(55%) said they felt that they had never been charged higher fees, three (27%) said that
they had been charged higher fees 'once or twice,' and two (18%) said they were often
charged higher fees for their apartment.
Table 5.10 Charged higher fees on apartment for no reason
t-requen
Never
6
Once or twice
3
Often
2
Total
11
Percent
55%
27%
18%
100%
The last part of the survey asked respondents if they felt that their landlord had
treated them differently for any reason including the categories that are protected under
fair housing laws which include because of their racial background, gender, family size,
national origin or age. For each of the reasons, respondents could answer from the
following responses: (1) never, (2) sometimes or (3) always.
City of Rosemead page 31 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Respondent were first asked if they had ever felt treated differently by their
landlord because of their racial background. Eight (73%) respondents indicated that
they had 'never' been treated differently based on their race. Only three (27%) said that
they felt treated differently either 'sometimes' or'always.'
Table 5.11 Ever been treated differently because of racial background
Frequency ' Percent
Never
Sometimes
Always
Total
8
7.i"/o
1
9%
2
18%
11
100%
Respondents were next asked if they had ever felt treated differently by their
landlord because of their gender. Nine (82%) respondents said that they had 'never'
been treated differently based on their gender and two (18%) indicated they had
'sometimes' been treated differently based on their gender.
Table 5.12 Ever been treated differently because of gender
Frequency Percerl
Never 9 82%
Sometimes 2 18%
Always 0 0%
Total 11 100%
Five (45%) respondents who answered this question indicated that they felt their
landlord had treated them differently either 'sometimes' or 'always' because of the size
of their family. Six (55%) said that they had 'never' experienced discriminatory
treatment by their landlord based on their family size.
Table 5.13 Ever been treated differently because of family size
Never
Sometimes
Always
Total
4
36%
1
9%
11
100%
Next, respondents were asked if they had ever felt that their landlord had treated
them differently because of their national origin. Seven (64%) said that they had 'never'
been treated differently based on their national origin, and four (36%) indicated they
either 'sometimes' or 'always' had experienced discriminatory treatment by their
landlord based on their national origin.
City of Rosemead page 32 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Table 5.14 Ever been treated differently because of national origin
Frequency Percent
Sometimes
Always'
Total
7
b4%
2
18%
2
18%
11
100%
Finally, respondents were asked if they felt their landlord treated them differently
because of their age. Eight (73%) said that they 'never' had experienced differential
treatment by their landlord based on their age. Only three (27%) indicated they
'sometimes' had experienced discriminatory treatment by their landlord based on their
age.
Table 5.15 Ever been treated differently because of age
rreauen
Never
8
Sometimes
3
Always
0
Total
11
C. Conclusion
/ 3"/0
27%
0%
100%
Overall, results from the survey reveal three major findings. First, some
Rosemead residents find it difficult to find housing. Twenty-five percent of all
respondents indicated that they had problems securing housing in Rosemead. On
average, respondents indicated that it took them more than a month to find housing.
Secondly, when asked about familiarity with fair housing laws, 47% of respondents
indicated that they were "not at all" aware of housing discrimination laws. Lastly, when
questioned regarding experiencing discrimination, 27% of respondents indicated that
they experienced racial discrimination, 18% indicated that they had experienced
discrimination based on gender, 45% indicated they had experienced familial status
discrimination, 36% indicated they had experienced discrimination based on their
national origin, and 27% indicated that they experienced age discrimination.
Percent
City of Rosemead page 33 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
VI. REVIEW OF GOVERNMENT POLICIES
HRC reviewed provisions of the Rosemead Municipal Code ("RMC"), specifically
Title 15 (Buildings and Construction) and Title 17 (Zoning), for compliance with state
and federal fair housing laws. We detailed any actual and potential conflicts between
the RMC and the letter and spirit of the state and federal fair housing laws, analyzed the
fair housing impact on protected groups of Rosemead residents, and suggested
changes to bring the respective sections into compliance. This review does not include
analysis of the Building Code vis-a-vis the technical accessibility requirements of the
Fair Housing Act or the Americans with Disabilities Act.
This section is divided into three parts. The first presents RMC sections that are
in direct conflict with state or federal fair housing laws. HRC recommends that the City
makes it a priority to change these sections to bring the RMC into compliance with fair
housing law. The second part analyzes RMC sections that should be changed to
achieve the goal of affirmatively furthering fair housing. The third part addresses other
relevant considerations.
A. Direct Conflicts
1. Definition of Family
Under § 17.04.020, "Family" is defined as:
[A] person, or persons related by blood, marriage or adoption, irrespective
of number, or a group of not to exceed five persons (excluding servants)
living together as a single housekeeping unit in a dwelling unit.
People with disabilities may require a group living arrangement whereby they
secure the support they need to live in the community. Overly restrictive definitions of
family that place numerical limits on unrelated persons and occupancy standards based
on familial status restrict the housing choices of individuals with disabilities in violation of
federal and state fair housing laws. The definition of "family" must emphasize the
functioning of the members as a cohesive household and cannot distinguish between
related and unrelated persons. When a group home of individuals with disabilities
functions like a family, they cannot be excluded from residential zones solely because
the residents are unrelated by blood, marriage, or adoption.
In 1980, the California Supreme Court, in City of Santa Barbara v. Adamson (27
Cal. 3d 123, 164 Cal. Rptr. 539 [1980]), struck down a municipal ordinance that
permitted any number of related people to live in a house in an R1 zone, but limited the
number of unrelated people who were allowed to do so to five. The court held that the
residents of the Adamson household, although unrelated, were a single housekeeping
unit that could be termed an alternative family and as such could not be excluded from
the single family zone, or made to apply for a conditional use permit.
City of Rosemead page 34 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
The Code should be amended to properly reflect the law. A proposed
amendment to the code would define family as "one or more persons living together in a
dwelling unit, with common access to, and common use of all living, kitchen, and eating
areas within the dwelling unit." This is a lawful, and therefore preferable, definition than
the current definition.
2. Definition of Bachelor Apartment
Under 17.04.020, "Bachelor apartment" is defined as
[A]n apartment or dwelling unit in a multiple dwelling or apartment house,
occupied or suitable for occupancy as a residence for one person. A
bachelor apartment contains bath and cooking facilities and one room
used for living room and sleeping with no separate bedroom.
Federal and state fair housing laws protect families with children from unlawful
discrimination. These laws indicate that reasonable occupancy limits may be set for
dwellings, but occupancy limits may be deemed unreasonable if overly restrictive with
respect to families with children, which by definition are comprised of 2 or more people.
It is a violation of the federal and state fair housing laws to restrict occupancy of
bachelor apartments to one person only, without taking into regard the size (square
footage) of the apartment. For example, if a woman living in a bachelor apartment
became pregnant and, after giving birth, resided in that apartment with her infant, this
definition of bachelor apartment containing an occupancy limit of one person may be
interpreted by a landlord that this tenant and her child should be evicted, even if they
were able to comfortably reside there. This would cause a direct conflict with state and
federal fair housing laws.
B. Potential Conflicts
1. Lack of References to Accessibility and Accommodations
Federal and state fair housing laws require cities and counties to provide
modifications and accommodations to disabled persons where such modifications or
accommodations are reasonable and necessary.
The State Attorney General has stated that local governments have an
affirmative duty under fair housing laws to provide reasonable accommodation and that
existing variances or conditional use permit processes are not sufficient to provide such
accommodations because they do not provide the correct standard for making fair
housing determinations and because the public process used in making entitlement
determinations fosters opposition to housing for persons with disabilities.
City of Rosemead page 35 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Pursuant to fair housing laws and also the Americans with Disabilities Act
("ADA"), the City of Rosemead should provide for reasonable accommodations for
persons with disabilities.
2. Off-Street Parking Regulations
Chapter 17.84 contains provisions regarding off-street parking. HRC's review
indicated that the Chapter contains no provisions regarding parking reserved for
persons with disabilities. Pursuant to the Americans with Disabilities Act ("ADA"),
building developers must include a specified number of parking spaces for persons with
disabilities, depending on the total number of parking spaces provided, in particular
relating to multiple family dwellings and condominium developments.
Reference should be made regarding the ADA and to Part 20 of the United
States Code of Federal Regulations, directing readers to the provisions regarding the
required number of disabled spaces.
C. Other Relevant Considerations
1. Prohibitions and Penalties for Improper Garbage and Rubbish Disposal
Provisions regarding garbage and rubbish disposal are located outside of Titles
15 and 17, and, specifically, are provided in Title 8, Health and Safety. However,
nuisance laws affect certain persons with disabilities and therefore we address this
issue herein.
Recently, mental health professionals have identified a disorder related to
obsessive compulsive disorder, which causes some individuals to engage in activity
labeled "hoarding." An individual who engages in "hoarding" might run afoul of the
measures with regard to garbage and rubbish disposal (See 8.32.010 through
8.32.150) and need a reasonable accommodation, e.g., additional time to comply with
the order to abate the nuisance or information regarding community resources to assist
with the clean-up. Additionally, persons with physical disabilities who cannot sustain
long periods of strenuous activity might need additional time to comply. While the right
to a reasonable accommodation is available to persons with disabilities under existing
fair housing laws, it would be helpful to explicitly state within this code section that
persons with disabilities may request an accommodation as needed, which request will
be evaluated by the appropriate agency. Such accommodation should include relief
from any penalties assessed pursuant to a finding of a nuisance, or other, violation.
City of Rosemead page 36 of 58
Analysis of Impediments to Fair Housing Choice
Ap ril 2010
VII. HOME MORTGAGE DISCLOSURE ACT DATA
The following section was constructed using 2006, 2007 and 2008 Home Mortgage
Disclosure Act (HMDA) data. This section examines the impediments to fair housing
choice in the City of Rosemead as they relate to credit markets, including mortgages.
A. Access to Housing Credit in Rosemead-General Background
1) The legal context of barriers to credit markets
In the United States, economic security and advancement are frequently based on
owning a home. Acquiring a home, however, depends to a large degree on having
access to credit. Credit provides a market conduit for channeling spending power to
households that can use it productively. If this market channel malfunctions, only inside
channels such as other family members can be tapped. For those households without
this option, homeownership and the economic security this can bring become
impossible.
Thus, it becomes evident that equality of opportunity and fair access to markets
(including credit markets) are linked. Laws passed in the 1960's and 1970's make this
link clear and legally enforceable. The Civil Rights Act of 1964 mandates that
institutions that control economic resources cannot legally discriminate on the basis of
race, gender, age, or disability. The 1968 Fair Housing Act went further:
"It shall be unlawful for any person or other entity whose business
includes engaging in residential real estate-related transactions to
discriminate against any person in making available such a transaction, or
in the terms or conditions of such a transaction, because of race," (42
U.S.C., sec. 3601-3631 (1988)).
The Equal Credit Opportunity Act (ECOA) of 1974, in turn, makes racial
discrimination illegal in credit market decisions.
Federal responsibility for ensuring that financial and housing markets operate equitably
was strengthened in the 1970's. The 1975 Home Mortgage Disclosure Act (HMDA)
requires banks and other depository institutions to provide annual data on their
mortgage lending by census tract. The 1977 Community Reinvestment Act expands
upon the responsibility of banks and other depository institutions to meet credit needs
throughout their entire market area, no matter how income and race vary within this
area, and it also requires that banks not define their market areas in a manner that
discriminates against minority areas. In 1989, the HMDA was amended: as of 1990,
lenders were directed to submit more detailed evidence (on applications, not just loans),
and more types of lenders (including mortgage companies) were required to report
under HMDA.
In sum, federal law makes it illegal for lenders to practice either discrimination or
City of Rosemead page 37 of 58
Analysis of Impediments to Fair Housing Choice ,
April 2010
redlining in credit and housing markets. Discrimination occurs whenever minorities (or
any group protected by law) are more likely to be turned down in a given market
transaction than are Whites or when minorities can make a given transaction only at a
higher cost or worse terms than Whites. Redlining occurs when a given market
transaction costs more or occurs less often in a geographic area with a high minority
population (or in an inner-city location) than in a low minority (or suburban) area, even
when differences in these areas' economic characteristics are considered. So
discrimination disadvantages a borrower or applicant independent of her location and
redlining disadvantages borrowers or applicants in a location independent of their
individual characteristics.
2) Detecting evidence of credit-market barriers
Numerous court cases and Congressional fine-tuning have clarified the legal meaning
of discrimination. In March 1994, the federal agencies responsible for enforcing credit-
market discrimination, issued a unified policy statement incorporating these
clarifications. Three types of discrimination are identified:
• Overt Discrimination - refusing to initiate a transaction with a person of color;
• Disparate Treatment - screening minorities more harshly than Whites in
application processes, or subjecting minority applications to different application
processes;
• Disparate Impact - conducting commercial practices that disproportionately harm
a racial minority without being justified by a legitimate business need.
Economists and legal experts agree that the first two types of discrimination can best be
detected through well-designed, direct "tests" of whether the procedures of lenders,
real-estate agents, and others are racially neutral. But detecting the third type of
discrimination requires the use of indirect evidence. Experts disagree about what
standard of proof for indirect evidence is required to demonstrate an "unfair" pattern of
credit flow. The problem is that differences between groups (such as White and
African-American loan applicants) or areas (such as minority and White neighborhoods)
may arise either because of market-based reasons, such as differences in wealth, or
"irrational" reasons such as racism. In general, the federal government is willing to go
after race-based disparities, but not market-based disparities. In practice, the line
between the two is blurry, at least in part because differences may arise from both.
Redlining has not been given a precise legal meaning, since the legislation creating it is
less clear in defining what behaviors constitute a failure to provide credit equitably over
bank market areas. The CRA itself provides that "credit needs" should be met uniformly,
but economists have no established method of determining such needs. In practice,
redlining has been measured by testing for credit-market "fair share." Simply put, every
neighborhood should receive its "fair share" of credit flows, adjusted for the prices of its
homes.
City of Rosemead page 38 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
3) Evidence of discrimination and redlining
What kind of evidence do studies and regulators find concerning discrimination and
redlining in credit and housing markets? Definitive proof of discrimination is hard to
come by, because this proof would have to account for all factors that lenders may
legitimately use before demonstrating- conclusively that lenders are biased. The only
city for which definitive proof of discrimination in credit markets has been established is
Boston, and even the various studies of Boston' still have their critics who refuse to
concede the discrimination has been proven.
Boston's studies were special because researchers received complete access to
lenders' data files on loan applicants. In many studies elsewhere in the U.S.,
suggestive evidence, if not definitive proof, of credit-market discrimination has been
produced using HMDA data. While experts agree that HMDA data cannot be used to
"prove" discrimination by banks, experts also agree that this data can be used to
determine whether discrimination may be occurring. In sum, HMDA data can be used
to conduct a diagnostic analysis of whether discrimination may be a problem in any
area.
The detection of redlining presents fewer measurement problems than that of
discrimination. Redlining may occur whenever there are significant social differences
between any two sub-areas within a larger community; suburb vs. inner-city,
professional vs. working class areas, largely White vs. largely minority areas. Most
redlining analyses test for lending gaps between areas with differing racial
compositions.
Studies of racial redlining follow a three-step procedure. First, the community being
analyzed is subdivided according to the percentage of minority residents in its various
sub-areas (census tracts). Second, sub-area loan flows and approval/denial rates are
compared. If differences are found (for example, minority areas received lower credit
flows than non-minority areas), then an effort is made to determine whether these
differences are attributable to economic elements. Third, further tests on loan flows and
denial rates are run, taking economic factors into account. If significant racial gaps exist
after accounting for economic factors, then redlining is found. Evidence of redlining is
always "suggestive" and not "definitive" because so many different economic and social
variables interact in communities.
This study relies exclusively on suggestive evidence of discrimination and redlining in
the credit market. Achieving definitive evidence of discrimination would require more
detailed information than HMDA and Census data can provide.
B. Access to Housing Credit in Rosemead: Local Practices
1) The evidence for Rosemead's credit markets
It is important to look into the problem of discrimination because of the tremendous
City of Rosemead page 39 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
ethnic diversity of the Los Angeles region and, indeed, of Rosemead itself. Lenders
might exercise different lending practices with different ethnic groups, for example. The
sections that follow will examine whether loan flows differ among different categories of
Rosemead loan applicants and in different geographic areas within Rosemead.
Redlining analyses tend to compare loan flow differences between broad geographic
areas (inner-city versus suburban areas) within large metropolitan areas. It might seem
inappropriate to examine redlining just within the city of, Rosemead. However,
Rosemead is large and diverse enough that geographic variations in loan flows may be
significant.
This evaluation of Rosemead's credit markets is based on the 2006-2008 HMDA data
for the City of Rosemead, which are the most recent years of data available. HMDA
data are collected at the census-tract level. Our analysis proceeds in several steps. We
first review the participants in the Rosemead residential credit markets- the most active
banks and other lenders on the supply side of these markets, as well as the racial and
income characteristics of the households on the demand side. We then evaluate
evidence concerning discrimination and redlining in Rosemead residential-credit
markets in two stages; first, a broad overview, and next, an in-depth analysis.
2) Participants in the Rosemead residential credit market
The supply side. Table 1 provides summary data for 2006-2008. During this time
period mortgage companies provided 49% of all residential loans in the city of
Rosemead. Commercial banks and thrifts accounted for 29% and 21% of this market,
respectively, and credit unions provided the remaining 1% of market share.
This pattern of market share is similar to newer suburban communities. In newer
communities such as Santa Clarita and Lancaster, mortgage companies account for
60% or even more of the mortgage market. In older communities and in the urban core
areas, mortgage companies have a much lower market share. In the City of Los
Angeles, for example, mortgage companies account for about a third of all residential
loans as thrifts remain the dominant lenders.
In Rosemead five lending institutions have a dominant presence: Citimortgage Inc.,
Bank of America, Countrywide Home Loans, JPMorgan Chase Bank, and Washington
Mutual Bank. Citimortgage Inc. made 430 loans on its own in Rosemead in 2006-2008,
a 9.4% of the market share. Bank of America made 399 loans, a 8.7% of the market
share, Countrywide Home loans made 261 loans, a 5.7% of the market share,
JPMorgan Chase Bank made 236 loans, a 5.2% of the share, and Washington Mutual
made 226 loans, a 4.9% of the market share. It may be that these institutions have
more established ties with the real estate industry in Rosemead, or it may be that they
invest more time and energy in securing the Rosemead clientele.
The demand side. Who applied for a mortgage loan on a home in Rosemead between
2006-2008? Including both conventional and VA/FHA loan applications, 10% of all
applicants who identified their race are White, 38% are Hispanic, less than one percent
City of Rosemead page 40 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
(1%) are African American, 51% are Asian American and less than one percent (1%)
are American Indian.
This pattern in applications is not at all similar to the racial composition of all Los
Angeles County applications for both conventional and VA/FHA home loans in 2006-
2008. Of 735,906 County applicants, 553,424 identified their ethnicity. Of this total,
some 0.3% were American Indian, 14% were Asian American, 8% African American,
43% Hispanic, and the remaining 34% were White. Clearly, the racial composition of
Rosemead home-purchase applicant pool is very different than that for conventional
home-purchase loans in the County as a whole. The applicant pool includes significantly
lower proportions of African Americans, with Asian Americans having the largest
population.
City of Rosemead page 41 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Table 1: Most Active Residential-Credit Lenders in Rosemead, 2006-2008
Commercial Banks
•
• Lender
ID #
2006-2008
Loans
% of 2006-2008
market
Bank of America
0000013044
399
0 8.7
JPMorgan Chase Bank
0000000008
236
• 5.2
Wells Fargo Bank, NA
0000001741
159
• 3.5
Citibank, NA
0000001461
84
• 1.8
Countrywide Bank, NA
0000024141
55
• 1.2
• Total, all
1306
28.6
commercial Banks
Thrifts (Savings and Loans)
•
• Lender
ID #
2006-2008
Loans
% of 2006-2008
market
Washington Mutual Bank
0000008551
226
• 4.9
Countrywide Bank, FSB
0000018039
150
• 3.3
World Savings Bank, FSB
0000012642
134
• 2.9
Indymac Bank, FSB
0000003970
123
• 2.7
First Suburban National Bank
0000014470
64
• 1.4
• Total, all Thrifts
951
20.8
Credit Unions
•
• Lender
ID #
2006-2008
Loans
% of 2006-2008
market
Wescom Credit Union
0000066703
11
• 0.2
E1 Financial Credit Union
0000086059
7
• 0.2
Credit Union of Southern
0000068456
6
• 0.1
California
Pentagon Federal Credit Union
0000000227
4
• 0.1
California Credit Union
0000060784
4
• 0.1
• All Credit Unions
I
65
1.4
Combined
Mortgage Companies
•
• Lender
ID #
2006-2008
Loans
% of 2006-2008
market
Citimortgage Inc.
13-3222578
430
• 9.4
Countrywide Home Loans
0001644643
261
• 5.7
HSBC Mortgage Corporation
16-1245395
119
• 2.6
GMAC Mortgage LLC
4216200005
63
• 1.4
HFC Company LLC
0003197956
62
• 1.4
City of Rosemead page 42 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
• Total, Mortgage I I 2252 I 49.2
Total for 2006-2008 4574 100
Note: Only the top lenders for each category are shown
3) Redlining and Discrimination in Rosemead: Basic Statistics
Redlining. According to HMDA data, all census tracts in Rosemead are comprised of
high percentages of ethnic minority individuals. Tract 4322.02 has the lowest minority
population percentage at 86% while tract 4825.03 has the highest minority population
percentage at 97%. From these numbers, it is clear that in every single tract in
Rosemead, ethnic minority individuals comprise the majority population. Since all
census tracts are high in their ethnic minority population it may not be possible to
determine redlining practices. There are no low ethnic minority populated census tracts
to compare with the high ethnic minority tracts. Nevertheless, all census tracts were
divided into three equal size census tract groups (lowest ethnic minority population
tracts, medium ethnic minority population tracts, and highest ethnic minority population
tracts) with the ethnic minority population ranging from 86% to 97%. Despite the limited
percentage range, table 2 shows that as the percent minority population in a census
tract increases, the acceptance rate decreases but only slightly (49%, 52%, and 47%
respectively for the low, medium, and high ethnic minority population census tract
groups) and the denial rate increases, but again, only slightly (17%, 17%, and 19%
respectively for low, medium, and high ethnic minority population census tract groups).
Table 2: Action by Census Tract Minority Population Percentage
Rosemead, 2006-2008
Low
Medium
High
Total
minority
minority
minority
population
population
population
Loan Approved
649
595
561
1805
% within Action Type
36.0%
33.0%
31.1%
100.0%
/o within Applicant Race
39.8%
40.7%
37.8%
39.5%
Loan Approved but not accepted
143
153
129
425
within Action Type
33.6%
36.0%
30.4%
100.0%
within Applicant Race
8.8%
10.5%
8.7%
9.3%
Loan Denied
283
246
286
815
within Action Type
34.7%
30.2%
35.1%
100.0%
within Applicant Race
17.4%
16.8%
19.3%
17.8%
Other actions
555
467
507
1529
/o within Action Type
36.3%
30.5%
33.2%
100.0%
/o within Applicant Race
34.0%
32.0%
34.2%
33.4%
otal
1630
1461
1483
4574
% within Action Type
35.6%
31.9%
32.4%
100.0%
within Applicant Race
100.0%
100.0%
100.0%
100.0%
City of Rosemead page 43 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Discrimination. Table 3 shows lenders' loan actions by applicant race, for both home
purchase loans and refinancing loans. In a pattern that will be followed throughout this
analysis, each cell in this table contains three numbers: the first is a raw count, the
second provides the row percentage, and the third provides the column percentage for
each cell. For example, 74 Hispanic applicants for home-purchase mortgages were
denied in 2006-2008. This figure represents 24% of all Hispanic applicants, and 40% of
all loan denials.
Table 3 indicates that for home-purchase loans, Asian American applicants have higher
rates of loan approval than White and Hispanic applicants, who have similar rates of
loan approvals. White and Hispanics have the same loan denial rates at 24%. Asians
have the lowest denial rates of all groups at 12%. The gap in loan approvals is about
17% between Asian Americans and Hispanic applicants and 18% between Asian
American and Whites.9
The aggregate data for refinancing loans, also set out in Table 3, tells a similar story.
Here approval rates for Asian Americans are 10-13% higher than Hispanic and White
applicants' approval rates. For all refinancing loans, approval rates are similar to those
for home-purchase loans - 47% vs. 53%. Denial rates are a little higher for refinancing
loans (at about 18%) than for home-purchase loans (at about 15%).
What explains the difference in the home-purchase and home-refinancing markets?
One possible explanation is that some racial groups have higher incomes and therefore
have different chances of being approved for loans. If this is so, then further analyses
should find some racial and/or income lending gaps.
Table 3: Action by Applicant Race
All lenders, Rosemead, 2006-2008
All Home Purchase Loans
American
Asian
African
White
Other
Total
Indian
Loan Originated
0
an
366
an
0
126
16
31
539
within Action Type
0%
67
9%
0%
23
4%
3.0%
5.8%
100.0
.
.
.
.
within Applicant Race
.0%
55.8%
.0%
41.4%
31 A%
12.7%
42.8%
Application approved but not
0
75
0
28
9
9
121
accepted
within Action Type
0%
62
0%
0%
23
1%
7
4%
7
4%
100.0
.
.
.
.
.
.
within Applicant Race
.0%
11.4%
.0%
9.2%
17.6%
3.7%
9.6%
9 Note that loan "approvals" includes both loans made and loans approved but not made. Most formal
analysis of loan-market discrimination has examined only approval and denial outcomes. However,
information from practitioners indicated that minority applicants are often encouraged to withdraw their
applications rather than be formally rejected.
City of Rosemead page 44 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Application denied
1
78
1
74
12
17
183
/o within Action Type
5%
42
6%
5%
40
4%
6
6%
9.3%
100.0
.
.
.
.
.
within Applicant Race
50
0%
9%
11
100.0
24.3%
23.5%
6.9%
14.5%
.
.
Application Withdrawn by
1
50
0
47
7
13
118
applicant
within Action Type
8%
42
4%
0%
39
8%
5
9%
11.0%
100.0
.
.
.
.
.
within Applicant Race
50.0%
7.6%
.0%
15.5%
13.7%
5.3%
9.4%
File Closed for Incompleteness
0
20
0
7
2
0
29
within Action Type
0%
69
0%
0%
24
1%
6
9%
.0%
100.0
.
.
.
.
.
within Applicant Race
.0%
3.0%
.0%
2.3%
3.9%
.0%
2.3%
Loan Purchased by the
0
67
0
22
5
175
269
institution
within Action Type
0%
24
9%
0%
8
2%
1.9%
65.1%
100.0
.
.
.
.
/o within Applicant Race
.0%
10.2%
.0%
7.2%
9.8%
71.4%
21.4%
Total
2
656
1
304
51
245
1259
within Action Type
2%
1%
24
4.1%
19.5%
100.0
.
.
within Applicant Race
100
0%
100.0
100.0
100.0
100.0
100.0
100.0
.
City of Rosemead - page 45 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
All Home Refinancing Loans
American
Asian
African
Hispanic
Other
Total
Indian
American
American
Loan Originated
5
512
1
345
111
138
1112
% within Action Type
.4%
46.0%
.1%
31.00%
10.0%
12.4%
100.0%
within Applicant Race
62.5%
51.5%
7.1%
38.7%
44.2%
18.3%
38.2%
Application approved but
2
111
.1
98
23
40
275
not accepted
% within Action Type
.7%
40.4%
.4%
35.6%
8.4%
14.5%
100.0%
% within Applicant Race
25.0%
11.2%
7.1%
11.0%
9.2%
5.3%
9.4%
Application denied by
0
143
5
229
52
90
519
financial Institution
% within Action Type
.0%
27.6%
1.0%
44.1%
10.0%
17.3%
100.0%
within Applicant Race
.0%
14.4%
35.7%
25.7%
20.7%
12.0%
17.8%
Application Withdrawn by
0
82
5
111
36
80
314
applicant
%within Action Type
.0%
26.1%
1.6%
35.4%
11.5%
25.5%
100.0%
within Applicant Race
.0%
8.2%
35.7%
12.5%
14.3%
10.6%
10.8%
File Closed for
0
33
1
33
3
17
87
Incompleteness
%within Action Type
.0%
37.9%
1.1%
37.9%
3.4%
19.5%
100.0%
%within Applicant Race
.0%
3.3%
7.1%
3.7%
1.2%
2.3%
3.0%
Loan Purchased by the
1
114
1
75
26
388
605
institution
within Action Type
.2%
18.8%
.2%
12.4%
4.3%
64.1%
100.0%
within Applicant Race
12.5%
11.5%
7.1%
8.4%
10.4%
51.5%
20.8%
Total
8
995
14
891
251
753
2912
% within Action Type
.3%
34.2%
.5%
30.6%
8.6%
25.9%
100.0%
within Applicant Race
100.0%
100.0%
100.0%
100.0%
100.0%
100.00/
100.0%
Table 4 tests the latter part of this connection - whether lenders' approval and denial
rates vary systematically for home-purchase applicants in different income brackets.
Table 4 shows that approval rates increase across income groups. Loan approval rates
have a positively linear association with income, the higher the income the higher the
approval rates. Approval rates for the four income groups starting from the lowest to the
highest incomes are 42%, 55%, 59%, and 59% respectively. Similarly, denial rates
decrease across income groups with the lower income groups having higher denial
rates than the higher income groups. These findings indicate that for the various
income groups in Table 4, loan approval and denial rates seem to vary systematically
with income level. This means that for most of Rosemead's applicants, income and
approval/denial seem to be correlated.
City of Rosemead page 46 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Table 4: Action by Applicant Income, Rosemead
All Lenders, All Home Purchase Loans
1111
41
'.61
'91111
Total
per year
60,000
•1 111 per
per year
Loan Originated
6
year
32
year
106
371
515
within Action Type
1.2%
6.2%
20.6%
72.0%
100.0%
% within income categories
31.6%
35.6%
50.0%
48.2%
47.2%
Application approved but not
2
17
18
82
119
accepted
% within Action Type
1.7%
14.3%
15.1%
68.9%
100.0%
within income categories
10.5%
18.9%
8.5%
10.7%
10.9%
Application denied
5
13
25
128
171
within Action Type
2.9%
7.6%
14.6%
74.9%
100.0%
within income categories
26.3%
14.4%
11.8%
16.6%
15.7%
Application Withdrawn by
5
12
21
72
110
applicant
% within Action Type
4.5%
10.9%
19.1%
65.5%
100.0%
% within income categories
26.3%
13.3%
9.9%
9.4%
10.1%
File Closed for Incompleteness
0
2
6
19
27
within Action Type
.0%
7.4%
22.2%
70.4%
100.0%
within income categories
.0%
2.2%
2.8%
2.5%
2.5%
Loan Purchased by the
1
14
36
97
148
institution
within Action Type
.7%
9.5%
24.3%
65.5%
100.0%
% within income categories
5.3%
15.6%
17.0%
12.6%
13.6%
Total
19
90
212
769
1090
within Action Type
1.7%
8.3%
19.4%
70.6%
100.0%
within income categories
100.0%
100.0%
100.0%
100.0%
100.0%
4) Discrimination in Rosemead: Detailed Analysis
The basic results reviewed above suggest no lending gaps due to income. We now turn
to a more detailed examination of racial/income connections in Rosemead's lending
data. Table 5 divides home-purchase applicants into four income levels (less than
$40,000 annual income, $40-59,999 income, $60-89,999, and $90,000 income and
above), and then looks at approval/denial rates. This is a way of holding income
approximately constant while focusing on racial differences in approval/denial rates.
This table yields some interesting patterns by applicant race. In the lowest income
group, it is not possible to make comparisons across racial groups due to the very low
numbers of African Americans, Hispanics, and Whites. In the next highest income group
- that is, for applicants earning between $40,000 and $60,000 - Asian Americans have
about a 17% higher loan approval rate than Hispanics. However, denial rates for
Hispanics are 3% lower than Asian Americans. At the $60-90,000 income range,
Hispanics have about a 4% higher approval rate than Asian Americans and also have a
City of Rosemead page 47 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
denial rate that is 3% lower than Asian Americans. At the more than $90,000 income
range, Asian Americans have a 20% higher loan approval rate than Hispanics and 18%
higher loan approval rate than White applicants. Similarly denial rates for Asian
Americans are 16% lower than Hispanics and 15% lower than White applicants. In sum,
there is some indication of a racial lending gap for Hispanic and White applicants in the
middle and high income range in the Rosemead home-purchase market.
Another hypothesis is that borrowers in different ethnic groups systematically apply to
different types of lender institutions, and these lender institutions have different loan-
making policies. If this were the case, then what appears to be a racial lending gap
would instead be a financial-institutions lending gap.
Table 5: Action by Applicant Race and Income Level, Rosemead
All lenders, All Home Purchase Loans
Income of $40.000 and less
American
Asian
African
Hispanic
White
Other
Total
Indian
American
American
Loan Approved
0
5
0
0
1
0
6
within Action Type
.000
83.3%
.0%
.0%
16.7%
.0%
100.0%
within Applicant Race
.0%
35.7%
.0%
.0%
50.0%
.0%
31.6%
Loan Approved but not
0
2
0
0
0
0
2
accepted
within Action Type
.0%
100.0%
.0%
.0%
.0%
.0%
100.0%
within Applicant Race
.0%
14.3%
.0%
.0%
.0%
.0%
10.5%
Loan Denied
1
4
0
0
0
0
5
within Action Type
20.0%
80.0%
.0%
.0%
.0%
.0%
100.0%
within Applicant Race
100.0%
28.6%
.0%
.0%
.0%
.0%
26.3%
Other actions
0
3
0
1
1
1
6
within Action Type
.0%
50.0%
.0%
16.7%
16.7%
16.7%
100.0%
within Applicant Race
.0%
21.4%
.0%
100.0%
50.0%
100.0%
31.6%
otal
1
14
0
1
2
1
19
% within Action Type
5.3%
73.7%
.0%
5.3%
10.5%
5.3%
100.0%
% within Applicant Race
100.0%
100.0%
.0%
100.0%
100.0%1
100.0%
100.0%
Incomes of $40.000-60.000
American
Asian
African
Hispanic
Other
Total
Indian
'
Loan Approved
0
27
0
4
1
0
32
within Action Type
.0%
84.4%
.0%
12.5%
3.1%
.0%
100.0%
within Applicant Race
.0%
46.6%
.0%
26.7%
12.5%
.0%
35.6%
Loan Approved but not
0
10
0
3
3
1
17
accepted
within Action Type
.0%
58.8%
.0%
17.6%
17.6%
5.9%
100.0%
within Applicant Race
.0%
17.2%
.0%
20.0%
37.5%
12.5%
18.9%
Loan Denied
0
9
0
2
1
1
13
% within Action Type
.0%
69.2%
.0%
15.4%
7.7%
7.7%
100.0%
City of Rosemead page 48 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
% within Applicant Race
.0%
15.5%
.0%
13.3%
12.5%
12.5%
14.4%
Other actions
1
12
0
6
3
6
28
within Action Type
3.6%
42.9%
.0%
21.4%
10.7%
21.4%
100.0%
within Applicant Race
100.0%
20.7%
.0%
40.0%
37.5%
75.0%
31.1%
Total
1
58
0
15
8
8
90
within Action Type
1.1%
64.4%
.0%
16.7%
8.9%
8.9%
100.0%
/o within Applicant Race
100.0%
100.0%
.0%
100.0%
100.0%
100.0%
100.0%
Incomes of $60,000-90,000
American
Asian
African
Hispanic
Other
Total
Indian
Loan Approved
0
81
0
18
4
3
106
within Action Type
%
0%
76.4%
0%
17.0%
3.8%
2.8%
100.0%
% within Applicant Race
.0%
54.4%
.0%
60.0%
44.4%
13.0%
50.0%
Loan Approved but not
0
13
0
2
2
1
18
accepted
%within Action Type
.0%
72.2%
.0%
11.1%
11.1%
5.6%
100.0%
within Applicant Race
.0%
8.7%
.0%
6.7%
22.2%
4.3%
8.5%
Loan Denied
0
15
1
2
2
5
25
within Action Type
.0%
60.0%
4.0%
8.0%
8.0%
20.0%
100.0%
/o within Applicant Race
.0%
10.1%
100.0%
6.7%
22.2%
21.7%
11.8%
Other actions
0
40
0
8
1
14
63
within Action Type
.00Y0
63.5%
.0%
12.7%
1.6%
22.2%
100.0%
within Applicant Race
.0%
26.8%
.0%
26.7%
11.1%
60.9%
29.7%
Total
0
149
1
30
9
23
212
/o within Action Type
.0%
70.3%
.5%
14.2%
4.2%
10.8%
100.0%
% within Applicant Race
.0%
100.0%
100.0%
100.0%
100.0%
100.0%
100.0%
Incomes of more than $90,000
American
Asian
African
Hispanic
White
Other
Total
Indian
Loan Approved
0
239
0
97
10
25
371
within Action Type
0%
64.4%
00/0
26.1%
2.7%
6.7%
100.0%
within Applicant Race
0%
58.2%
00/0
40.8%
37.0%
26.9%
48.2%
Loan Approved but not
0
49
0
22
4
7
82
accepted
within Action Type
0%
59.8%
0%
26.8%
4.9%
8.5%
100.0%
within Applicant Race
.0%
11.9%
.0%
9.2%
14.8%
7.5%
10.7%
Loan Denied
0
47
0
. 64
7
10
128
within Action Type
.0%
36.7%
.0%
50.0%
5.5%
7.8%
100.0%
within Applicant Race
.0%
11.4%
.0%
26.9%
25.9%
10.8%
16.6%
Other actions
0
76
0
55
6
51
188
within Action Type
.0%
40.4%
.0%
29.3%
3.2%
27.1%
100.0%
within Applicant Race
.0%
18.5%
.0%
23.1%
22.2%
54.8%
24.4%
Total
0
411
0
238
27
93
769
%within Action Type
.0%
53.4%
.0%
30.9%
3.5%
12.1%
100.0%
City of Rosemead page 49 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
I% within Applicant Race 1 .0% 1100.0% 1 .0% 1100.0% 1100.0%1100.0%1100.0%I
Table 6 shows that there are some systematic differences in the types of lending
institutions at which White and minority home-seekers apply for mortgages. Asian
Americans are more likely to apply at Commercial Banks than other borrower groups.
Mortgage companies were the preferred lending institutions for all racial groups, but
Hispanics were more likely to apply at a mortgage company than other borrowers.
Table 6: Applicants by Lender Type and Applicant Race, Rosemead
All Home-Purchase Loans, 2006-2008
Commerci
Thrifts
Credit
Mortgage
Total
al Banks
(S & L's)
Unions
.Companie
American Indian
0
1
0
1
2
within Applicant Race
.0%
50.0%
.0%
50.0%
.0%
7
within Lender type
.0%
.5%
.0%
.2%
2016
Sian American
275
88
1
292
656
% within Applicant Race
41.9%
13.4%
.2%
44.5%
100.0%
% within Lender type
65.8%
40.9%
33.3%
46.8%
52.1%
African American
1
0
0
0
1
within Applicant Race
100.0%
.0%
.0%
.0%
100.0%
within Lender type
.2%
.0%
.0%
.0%
.1%
Hispanic
69
47
1
188
305
within Applicant Race
22.6%
15.4%
.3%
61.6%
100.0%
within Lender type
16.5%
21.9%
33.3%
30.1%
24.2%
White
11
10
0
30
51
within Applicant Race
21.6%
19.6%
.0%
58.8%
100.0%
within Lender type
2.6%
4.7%
.0%
4.8%
4.0%
Other
62
69
1
113
245
within Applicant Race
25.3%
28.2%
.4%
46.1%
100.0%
within Lender type
14.8%
32.1%
33.3%
18.1%
19.4%
Total
418
215
3
624
1260
within Applicant Race
33.2%
17.1%
.2%
49.5%
100.0%
within Lender type
100.0%
100.0%
100.0%
100.0%
100.0%
Table 7 also indicates that across all income levels, mortgage companies dominated the
Home Loan market. For the top income group, 52% of applications are registered at
mortgage companies, compared to 58% for the lowest income group. Finally, for the
lowest income group, 32% are registered at Savings and Loans compared to 34% for
the highest income group.
City of Rosemead page 50 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Table 7: Applicants by Lender Type and Applicant Income
All Home-Purchase Loans, 2006-2008, Rosemead
Commerci
Thrifts (S&
Credit
Mortgage
al Banks
L's)
Unions
.Companie
$40,000/year
6
2
0
11
19
% within income categories
31.6%
10.5%
.0%
57.9%
100.0%
% within Lender type
1.7%
1.3%
.0%
1.9%
1.7%
40-60,000/year
24
12
1
53
90
within income categories
26.7%
13.3%
1.1%
58.9%
100.0%
within Lender type
6.7%
7.6%
50.0%
9.2%
8.3%
60-90,000/year
62
35
1
114
212
within income categories
29.2%
16.5%
.5%
53.8%
100.0%
within Lender type
17.4%
22.3%
50.0%
19.8%
19.4%
$90,000/year
264
108
0
397
769
within income categories
34.3%
14.0%
.0%
51.6%
100.0%
within Lender type
74.2%
68.8%
.0%
69.0%
70.6%
Total
356
157
2
575
1090
within income categories
32.7%
14.4%
.2%
52.8%
100.0%
within Lender type
100.0%
100.0%
100.0%
100.0%
100.0%
Table 8 goes deeper into the question of differences among types of lenders. It shows
data separately for commercial banks, thrifts, credit unions, and mortgage companies.
This table shows, first, that loan approval rates are 64% for commercial banks, 39% for
thrifts, and 50% for mortgage companies. Second, a racial lending gap arises between
Asian American and Hispanic applicants for the Commercial Banks lender category.
Asian American applicants had denial rates 17% lower and approval rates 6% higher
than Hispanic applicants. Third, Hispanics had lower approval rates and higher denial
rates than Asian Americans for the Savings and Loan lender category. Asian American
applicants had 59% approval rates vs. 49% for Hispanic applicants. Hispanic applicants
had a denial rate of 26% compared to Asian American applicants who had a 13% denial
rate. Finally, a similar trend emerged in the mortgage lender category. Asian American
applicants had an approval rate of 64% compared to 48% for Hispanics. The denial rate
was twice as high for Hispanics at 22% compared to 11 % for Asian Americans.
Table 8: Action by Applicant Race and Lender Type
All Home Purchase Loans, 2006-2008, Rosemead
Commercial Banks
City of Rosemead page 51 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Loan Approved but not
0
39
0
9
2
3
53
accepted
/o within Action Type
.0%
73.6%
.0%
17.0%
3.8%
5.7%
100.0%
within Applicant Race
.0%
14.2%
.0%
13.0%
18.2%
4.8%
12.7%
Loan Denied
0
34
1
20
1
6
62
within Action Type
.0%
54.8%
1.6%
32.3%
1.6%
9.7%
100.0%
within Applicant Race
.0%
12.4%
100.0%
29.0%
9.1%
9.7%
14.8%
Other actions
0
37
0
9
3
43
92
within Action Type
.0%
40.2%
.0%
9.8%
3.3%
46.7%
100.0%
within Applicant Race
.0%
13.5%
.0%
13.0%
27.3%
69.4%
22.0%
Total
0
275
1
69
11
62
418
within Action Type
.0%
65.8%
.2%
16.5%
2.6%
14.8%
100.0%
within Applicant Race
.0%
100.0%
100.0%
100.0%
100.0%
100.0%,
100.0%
Thrifts (S&L's)
Americ
Asian
African
White
Other
Total
Indian
an
an
Loan Approved
0
47
0
19
2
6
74
within Action Type
.0%
63.5%
.0%
25.7%
2.7%
8.1%
100.0%
within Applicant Race
.0%
53.4%
.0%
40.4%
20.0%
8.7%
34.4%
Loan Approved but not
0
5
0
4
2
0
11
accepted
within Action Type
.0%
45.5%
.0%
36.4%
18.2%
.0%
100.0%
within Applicant Race
.0%
5.7%
.0%
8.5%
20.0%
.0%
5.1%
Loan Denied
0
11
0
12
4
3
30
within Action Type
.0%
36.7%
.0%
40.0%
13.3%
10.0%
100.0%
within Applicant Race
.0%
12.5%
.0%
25.5%
40.0%
4.3%
14.0%
Other actions
1
25
0
12
2
60
100
within Action Type
1.0%
25.0%
.0%
12.0%
2.0%
60.0%
100.0%
within Applicant Race
100.0%
28.4%
.0%
25.5%
20.0%
87.0%
46.5%
Total
1
88
0
47
10
69
215
within Action Type
.5%
40.9%
.0%
21.9%
4.7%
32.1 %
100.0%
within Applicant Race
100.0%
100.0%
.0%
100.0%
100.0%
100.0%
100.0%
Credit Unions
American
Asian
African
Hispanic
White
Other
Total
Indian
American
American
Loan Approved
0
0
0
1
0
0
1
within Action Type
.0%
.0%
.0%
100.0%
.0%
.0%
100.0%
% within Applicant
0%
.0%
.0%
100.0%
.0%
.0%
33.3%
Race
Loan Approved but
0
0
0
0
0
1
1
not accepted
within Action Type
.0%
.0%
.0%
.0%
.0%
100.0%
100.0%
%within Applicant
.0%
.0%
.0%
.0%
.0%
100.0%
33.3%
City of Rosemead page 52 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Race
Loan Denied
0
1
0
0
0
0
1
% within Action Type
.0%
100.0%
.0%
.0%
.0%
.0%
100.0%
%within Applicant
0%
100.0%
.0%
.0%
.0%
.0%
33.3%
Race
Other actions
0
1
0
1
0
1
3
% within Action Type
.0%
33.3%
.0%
33.3%
.0%
33.3%
100.0%
% within Applicant
0%
100.0%
.0%
100.0%
.0%
100.0%
100.0%
Race
Total
0
0
0
1
0
0
1
within Action Type
.0%
.0%
.0%
100.0%
.0%
.0%
100.0%
% within Applicant
0%
.0%
.0%
100.0%
.0%
.0%
33.3%
Race
Mortaaae Comoanies
American
Asian
African
Hispanic
White
Other
Total
Indian
American
American
Loan Approved
0
154
0
75
9
15
253
within Action Type
.0%
60.9%
.0%
29.6%
3.6%
5.9%
100.0%
% within Applicant
0%
52.7%
0%
39.9%
30.0%
13.3%
40.5%
Race
.
Loan Approved but
0
31
0
15
5
5
56
not accepted
within Action Type
.0%
55.4%
.0%
26.8%
8.9%
8.9%
100.0%
% within Applicant
0%
10.6%
.0%
8.0%
16.7%
4.4%
9.0%
Race
Loan Denied
1
33
0
42
7
8
91
% within Action Type
1.1%
36.3%
.0%
. 46.2%
7.7%
8.8%
100.0%
within Applicant
100.0%
11.3%
.0%
22.3%
23.3%
7.1%
14.6%
Race
Other actions
0
74
0
56
9
85
224
% within Action Type
.0%
33.0%
.0%
25.0%
4.0%
37.9%
100.0%
within Applicant
0%
25.3%
.0%
29.8%
30.0%
75.2%
35.9%
Race
Total
1
292
0
188
30
113
624
within Action Type
.2%
46.8%
.0%
30.1%
4.8%
18.1%
100.0%
within Applicant
100.0%
100.0%
.0%
100.0%
100.0%
100.0%
100.00/(
Race
These statistics suggest that there may be racial lending gaps involving Asian American
and Hispanic applicants. We now analyze it further by going more deeply into the links
between income and race. Table 9 shows that the Hispanic applicant pool has the
highest proportion of high-income households, followed by the Asian American
applicant pool and finally the White applicant pool which has the lowest proportion of
applicants in the high-income range. Among Hispanics, 9 out of every 10 applicants in
Rosemead have incomes greater than $60,000. Similarly, among Asian Americans, just
City of Rosemead page 53 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
below 9 out of every 10 applicants for homes in Rosemead have incomes above
$60,000. The statistics shown in Table 10 indicate that in the $40,000460,000 income
range Asian Americans have approval rates that are 20% higher than Hispanics and
denial rates that are 16% lower. The same trend is found in the $60,000490,000
income range and also in the over $90,000 income category. Overall the loan refinance
data suggest a racial lending gap in Rosemead that favors Asian American applicants
over Hispanic applicants.
Table 9: Applicant Income and Applicant Race, Rosemead
All Home-Purchase Loan Applications, 2006-2008
Applicant
White
Other
Total
Income
n Indian
America
America
c
$40,000/year
1
14
0
1
2
1
19
within Income
5.3%
73.7%
.0%
5.3%
10.5%
5.3%
100.0%
% within Applicant
50.0%
2.2%
.0%
.4%
4.3%
.8%
1.7%
Race
40-60,000/year
1
58
0
15
8
8
90
%within Income
1.1%
64.4%
.0%
16.7%
8.9%
8.9%
100.0%
% within Applicant
50.0%
9.2%
.0%
5.3%
17.4%
6.4%
8.3%
Race
60-90,000/year
0
149
1
30
9
23
212
within Income
.0%
70.3%
.5%
14.2%
4.2%
10.8%
100.0%
% within Applicant
0%
23.6%
100.0%
10.6%
19.6%
18.4%
19.4%
Race
$90,000/year
0
411
0
238
27
93
769
%within Income
.0%
53.4%
.0%
30.9%
3.5%
12.1%
100.0%
% within Applicant
0%
65.0%
.0%
83.8%
58.7%
74.4%
70.6%
Race
Total
2
632
1
284
46
125
1090
%within Income
.2%
58.0%
.1%
26.1%
4.2%
11.5%
100.0%
% within Applicant
100
0%
100
0%
100
0%
100.0%
100.0%
100.0%
100.0%
Race
.
.
.
Table 10: Refinancing Loans by Applicant Income and Race
All lenders, 2006-2008, Rosemead
licant Income less than 40,000
American Asi
Indian Amer
an Approved 0 11
within Action Type .0% 20.0%
within Applicant .0% 24.4%
City of Rosemead
Analysis of Impediments to Fair Housing Choice
April 2010
0
26
6
12 55
.0%
47.3%
10.9%
21.8% 100.00/
.0%
42.6%
31.6%
25.5% 32.0%
page 54 of 58
Loan Approved but
0
5
0
6
1
5
17
not accepted
/o within Action Type
.0%
29.4%
.0%
35.3%
5.9%
29.4%
100.0%
within Applicant
0%
11.1%
.0%
9.8%
5.3%
10.6%
9.9%
Race
Loan Denied
0
12
0
18
8
10
48
within Action Type
.0%
25.0%
.0%
37.5%
16.7%
20.8%
100.0%
within Applicant
0%
26
7%
0%
29.5%
42.1%
21.3%
27.9%
Race
.
.
.
Other actions
0
17
0
11
4
20
52
within Action Type
.0%
32.7%
.0%
21.2%
7.7%
38.5%
100.0%
within Applicant
0%
37.8%
.0%
18.0%
21.1%
42.6%
30.2%
Race
Total
0
45
0
61
19
47
172
within Action Type
.0%
26.2%
.0%
35.5%
11.0%
27.3%
100.0%
within Applicant
0%
100.0%
.0%
100.0%
100.0%
100.0%
100.0%
Race
A ....1:--- 4, 1........e . f QAn nnn_cn nnn
America
n Asian Afri
can Hisp
anic W
hite Oth
erTotal
Indian
Loan Approved
0
52 0
59
14
13
138
within Action Type
.0%
37.7% .0%
42.8%
10.1%
9.4%
100.0%
within Applicant Race
.0%
50.0% .0%
36.6%
40.0%
15.7%
36.0%
Loan Approved but
0
16
0
14
4
5
39
not accepted
within Action Type
.0%
41.0%
.0%
35.9%
10.3%
12.8%
100.0%
within Applicant Race
.0%
15.4%
.0%
8.7%
11.4%
6.0%
10.2%
Loan Denied
0
13
0
47
7
19
86
within Action Type
.0%
15.1%
.0%
54.7%
8.1%
22.1%
100.0%
/o within Applicant Race
.0%
12.5%
.0%
29.2%
20.0%
22.9%
22.5%
Other actions
0
23
0
41
10
46
120
within Action Type
.0%
19.2%
.0%
34.2%
8.3%
38.3%
100.0%
within Applicant Race
.0%
22.1%
.0%
25.506
28.6%
55.4%
31.306
Total
0
104
0
161
35
83
383
within Action Type
.0%
27.2%
.0%
42.0%
9.1%
21.7%
100.0%
within Applicant Race
100.0%
.0%
100.0%
100.0%
100.0%
100.0%
an Approved
within Action Type
within Applicant
3 - 140
1.0% 44.7%
75.0% 1 57.1%
0
99
30
41 313
0%
31.6%
9.6%
13.1 % 100.00
0%
36.7%
53.6%
29.1% 43.4%
City of Rosemead page 55 of 58
Analysis of Impediments to Fair Housing Choice
April 2010 '
Loan Approved but
0
22
1
34
6
6
69
not accepted
within Action Type
.0%
31.9%
1.4%
49.3%
8.7%
8.7%
100.00
within Applicant
0%
9.0%
20.0%
12
6%
10.7%
4.3%
9.6%
Race
.
Loan Denied
0
33
2
68
6
25
134
within Action Type
.0%
24.6%
1.5%
50.7%
4.5%
18.7%
100.0%
within Applicant
0%
13
5%
40
0%
25
2%
10
7%
17
7%
18
6%
Race
.
.
.
.
.
.
Other actions
1
50
2
69
14
69
205
within Action Type
.5%
24.4%
1.0%
33.7%
6.8%
33.7%
100.0%
within Applicant
25.0%
20.4%
40.0%
25.6%
25.0%
48.9%
28.4%
Race
Total
4
245
5
270
56
141
721
% within Action Type
.6%
34.0%
.7%
37.4%
7.8%
19.6%
100.0%
% within Applicant
100.0%
100
0%
100
0%
100
0%
100.0%
100.0%
100.0°/
Race
.
.
.
ADDlicant Income of over $90.000
America
n As
ian Afri
can .Hisp
anicW
hite Oth
erTotal
Indian
Ame
ricanAme
rican
Loan Approved
2
279
1
134
50
52
518
within Action Type
.4%
53.9%
.2%
25.9%
9.7%
10.0%
100.0%
within Applicant Race
50.0%
52.1%
20.0%
41.2%
39.4%
27.8%
43.8%
Loan Approved but
2
63
0
35
12
22
134
not accepted
within Action Type
1.5%
47.0%
.0%
26.1%
9.0%
16.4%
100.0%
within Applicant Race
50.0%
11.8%
.0%
10.8%
9.4%
11.8%
11.3%
Loan Denied
0
77
3
84
30
33
227
within Action Type
.0%
33.9%
1.3%
37.0%
13.2%
14.5%
100.0%
within Applicant Race
.0%
14.4%
60.0%
25.8%
23.6%
17.6%
19.2%
Other actions
0
116
1
72
35
80
304
within Action Type
.0%
38.2%
.3%
23.7%
11.5%
26.3%
100.0%
within Applicant Race
.0%
21.7%
20.0%
22.2%
27.6%
42.8%
25.7%
Total
4
535
5
325
127
187
1183
within Action Type
.3%
45.2%
.4%
27.5%
10.7%
15.8%
100.0%
within Applicant Race
100.0%
100.0%
100.0%
100.0%
100.0%
100.0%
100.0%
Finally, to determine if there is a sex bias in the lending practices in Rosemead an
analysis examining approval and denial rates by applicant sex was conducted. Table
11 indicates that male applicants have similar approval rates to women for home
purchase loans. Males have an approval rate of 61% versus female applicants who
also have a 61% approval rate. Denial rates show a different pattern with male
applicants having a 15% denial rate while female applicants have a 19% denial rate.
Overall, the loan approval/denial discrepancy between male and female applicants was
not statistically significant.
City of Rosemead page 56 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
Table 11: Home Purchase Loans by Applicant Sex
All lenders, 2006-2008, Rosemead
Male
Female
Total
Loan Approved
346
173
519
within Action Type
66.7%
33.3%
100.0%
within Applicant Sex
49.9%
49.3%
49.7%
Loan Approved but not accepted
78
37
115
within Action Type
67.8%
32.2%
100.0%
within Applicant Sex
11.2%
10.5%
11.0%
Loan Denied
105
68
173
within Action Type
60.7%
39.3%
100.0%
within Applicant Sex
15.1%
19.4%
16.6%
Other actions
165
73
238
within Action Type
69.3%
30.7%
100.0%
within Applicant Sex
23.8%
20.8%
22.8%
Total
694
351
1045
within Action Type
66.4%
33.6%
100.0%
within Applicant Sex
100.0%
100.0%
100.0%
C. Access to Housing Credit in Rosemead-Conclusion
From the perspective of barriers to fair housing, this detailed analysis of Rosemead
HMDA lending patterns comes to three central conclusions. First, there is some
evidence of "redlining." Table 2 indicates that as the minority population percentage at
the census track level increases, the loan approval rates decrease and the denial rates
increase.
Second, there is slight evidence of racial approval gaps between Asian American and
Hispanic applicants. More specifically, Tables 6-10 indicate that for home purchase
loans, without controlling for income or lending institution, Asian Americans have higher
approval rates and lower denial rates than Hispanics. A variety of adjustments for lender
type, income areas, racial areas, and applicant incomes did no eliminate most of these
gaps (see table 6). For example, after controlling for income, Table 5 shows that in the
higher income categories, Asian Americans have higher approval rates and lower denial
rates than Hispanics, suggesting that the gaps favoring Asian American applicants
seem to arise largely in the $60,000 to $90,000 and over $90,000 income categories.
Furthermore, Table 8 shows that for Commercial Bank, and Mortgage company loans,
Asian American applicants have lower denial rates than Hispanic applicants.
The third major finding (see table 3) indicates that Asian Americans comprise a
significant percentage of Rosemead's applicant pool (51% of the home purchase
market), a pattern that is not found in many other suburban cities in the Los Angeles
region where Whites and Hispanics tend to dominate. Finally, African American and
White applicants constitute a small percentage of all loan applications in Rosemead
City of Rosemead page 57 of 58
Analysis of Impediments to Fair Housing Choice
April 2010
(.4% and 10% for the home purchase loan market respectively). This is significant
given the growing number of Asian Americans across many cities in Los Angeles
County, including the City of Rosemead.
City of Rosemead page 58 of 58
Analysis of Impediments to Fair Housing Choice
April 2010