CC - Item 3C - Public Hearing on the Analysis of Impediments to Fair Housing NoticeROSEMEAD CITY COUNCIL
STAFF REPORT
TO: THE HONORABLE MAYOR AND CITY COUNCIL
FROM: JEFF ALLRED, CITY MANAGER
DATE: APRIL 28, 2015
SUBJECT: PUBLIC HEARING ON THE ANALYSIS OF IMPEDIMENTS TO FAIR
HOUSING CHOICE
SUMMARY
The City Council will consider the approval of the City's Five Year Analysis of
Impediments to Fair Housing Choice covering the period July 1, 2015 through June 30,
2020. 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
It is recommended 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, 2015 through
June 30, 2020; 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 for Choice in Housing. A five -
year update to the City's Al was completed in 2000, 2006, and 2010 by the Southern
California Housing Rights Center (HRC).
ITEM NUMBER:
City Council Report
April 28, 2015
Page 2 of 7
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 2015 -2020 AI established seven (7) potential impediments that are identified
below as well as the activities the City will carry out over the next five years to address
these issues.
Demographic Profile and Subsidized Housinq
Potential Impediment.
The Housing Authority of the County of Los Angeles (HACoLA) administers the
Housing Choice Voucher program for those who use their Section 8 vouchers in the
City of Rosemead. HUD implemented the Section 8 voucher program to promote
racial and ethnic integration in its affordable housing programs. Under the Section 8
voucher program the recipient may use the subsidized housing voucher if it is
accepted by a private housing provider.
Similar to data for the state of California, in the Greater Los Angeles area, the
majority of Section 8 voucher participants are Black/African American (36 %). Asians
only represent 11% of the voucher participants in the Greater Los Angeles area. In
Rosemead, however, Black/African Americans only represent 1% of Section 8
voucher holders and Asians represent 74% of the Section 8 voucher holders.
Considering that Asians represent .60.7% of the total population, they are
disproportionally receiving and utilizing federally subsidized housing in the City of
Rosemead. It is possible that Black/African American Section 8 voucher holders
have difficulty in finding a housing provider in the City of Rosemead who will rent to
them. It is also possible that Black/African American Section 8 voucher holders do
not attempt to rent in Rosemead out of concern that they will feel isolated in a city
with so few African Americans. In addition, some housing providers are reluctant to
accept government housing assistance for low- income renters.
Actions Proposed to Overcome Potential Impediment.
• Examine ways in which the City can work with HACoLA to encourage Rosemead
housing providers to advertise available units in areas that are more racially and
ethnically diverse.
City Council Report
April 28, 2015
Page 3 of 7
• Examine ways in which the City can work with HACoLA to provide more
education and outreach to housing providers about the benefits of the Section 8
rental assistance program in an effort to avoid possible negative stereotyping of
ethnic minorities, Section 8 housing subsidy recipients, and government
assistance programs.
Current Fair Housing Profile and Trends
Potential Impediment.
a. Housing Complaints from the Asian Population in Rosemead — According to the
2010 census, the Asian population made up 60.7% of the Rosemead population.
In 2000, the Asian population made up 48.7% of the Rosemead residents.
Approximately 20% of Rosemead residents assisted by HRC, over the past five
years were Asian. Conversely, the Hispanic population made up 33.8% of the
Rosemead population and approximately 60% of Rosemead residents assisted by
the HRC over the past four years. 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. At the same time,
a significant number of housing opportunities including home purchases tend to
favor Asians numerically. This may indicate differential treatment in rentals and
home purchase lending against non - Asians in Rosemead which would merit more
education and outreach to the Asian housing providers and lenders about their
responsibilities under fair housing laws.
While various conclusions may be drawn from this data, two questions of
relevance are whether discriminatory housing practices may be disproportionately
impacting non -Asian populations within the City, and /or whether Asian residents
may be turning to resources other than fair housing organizations for assistance
with housing issues, if they do at all. The relatively low number of Asian clients
seeking assistance from HRC becomes even more noteworthy in light of the
relatively large number of Hispanic /Latino residents who comprised HRC's
Rosemead clientele during the 10 -year period in question. One possible
conclusion is that Hispanic residents of Rosemead are outpacing Asian residents
in terms of their need for fair housing services. Another conclusion is that if the
Asian population is significantly foreign -born or recently immigrated, it may not be
using the City's public service programs such as the Housing Rights Center's
(HRC) fair housing services program in a ratio proportionate with its size due to
unfamiliarity with such programs. It is recommended that the City of Rosemead
and the HRC work together in doing more outreach to Asian immigrant and non-
immigrant tenants and housing providers to ensure that they are aware of their
rights and responsibilities under fair housing law.
City Council Report
April 28, 2015
Page 4 of 7
Actions Proposed to Overcome Potential Impediment.
• Advertise all fair housing workshops to housing providers and tenants in English
and Chinese.
• Work with the Rosemead Chamber of Commerce to identify businesses and
housing providers for outreach and education opportunities.
• Utilize publications such as the Chamber of Commerce's Rosemead Report, and
the City newsletter (Rosemead Resources) and website to provide information to
housing providers and Rosemead residents about fair housing services.
b. Housing Discrimination Complaints Based on Disability — Over the past five years
the number of housing discrimination complaints based on physical disability has
remained disproportionally high making up 44 % of all housing discrimination
complaints reported by Rosemead residents. This indicates a continuing need for
education of landlords on laws that protect the rights of people with disabilities
and fair housing laws in general.
Actions Proposed to Overcome Potential Impediment.
• Submit regular articles to the Rosemead Resources and Chinese language
newspapers on fair housing and people with disabilities.
• Highlight disability discrimination at fair housing workshops in Rosemead.
• Distribute informational materials in the City that focus on fair housing and . people
with disabilities.
Audit Testing
Potential Impediment.
The HRC conducted 25 phone tests to measure levels of housing discrimination in
the City of Rosemead. The tests measured discrimination against people with
disabilities and families with children. The HRC found that 67% of the disability
phone tests showed evidence of potential 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 from the City's business license database, property search
database, etc. and work with the Rosemead Chamber of Commerce to publish
information in its publications to its members.
Work with other social services organizations serving Rosemead residents to
educate their staff and client community about fair housing laws.
1 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 three years is 43. Of this number 30 were based on
physical or mental disability.
City Council Report
April 28, 2015
Page 5 of 7
• Maintain partnership with a fair housing provider who is able to provide fair
housing services to Rosemead residents.
Community Survey
Potential Impediment:
The HRC conducted a survey of 31 Rosemead residents. The survey showed that
36% of respondents had no knowledge of the fair housing laws and 45% had very
little knowledge of the fair housing laws. According to the 2010 census, the
population of Rosemead was 53,764 with an estimated population in 2013 of 54,561.
From July 1, 2009 to June 30, 2014, the HRC assisted 626 Rosemead residents,
which represents 1.6% of the total population based on 2010 census figure. 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.
• Include public service announcements on the City's website regarding fair
housing laws.
• Submit articles to social service organizations serving Rosemead residents and
in the Rosemead Resources on current fair housing topics.
• Maintain partnership with a fair housing provider who is able to provide fair
housing services to Rosemead residents.
Rosemead Rental Housing Conditions
Potential Impediment.
Tenants often experience habitability problems but do not have the ability to address
the problem with their housing provider because of fear of retaliation or lack of
resources to document the conditions and hold the housing provider accountable for
the necessary repairs. Members of protected classes under fair housing laws
including seniors, disabled persons, minorities, and female heads of households are
often the most vulnerable to poor conditions and may not be or feel empowered to
address the issue without government assistance.
In conducting outreach, some Rosemead Mobilehome Park residents expressed
concern about poor conditions at the Mobilehome Parks. The City of Rosemead has
no jurisdiction over Mobilehome Parks. They are regulated by the California
Department of Housing and Community Development's Manufactured Housing
Program. The City does offer the Owner - Occupied Rehabilitation program to low
and moderated - income residents of mobile home parks. Through these programs,
the City makes funds available to assist homeowners in making needed
rehabilitation improvements.
Actions Proposed to Overcome Potential Impediment.
The City should have information available for its Mobilehome Park residents about
the State's Mobilehome Ombudsman, which receives and processes complaints
related to living in mobile homes.
City Council Report
April 28, 2015
Page 6 of 7
Rosemead Home Mortgage Disclosure Act Data
Potential Impediment:
From the perspective of barriers to fair housing, a detailed analysis of Rosemead
HMDA lending patterns present a stark change in lending in Rosemead since 2008.
First, the evidence of redlining is not as clear as it was in the 2010 Al. The minority
population in Rosemead is now a majority population throughout the City. The large
majority of home purchase loans by all lenders made in Rosemead have been to
Asian applicants.
Of all applicants for home purchase loans and refinance loans in Rosemead in 2013,
75.5% were Asian American. This compares to 55% in 2008. For Hispanics, the
percentages of market demand was 15.5% in 2013, compared to 34% in 2008.
Whites consisted of 7.1 % of the market demand in 2013, compared to 11 % in 2008.
The remaining groups, primarily African American and Native American, consisted of
less than 3% of the market demand. While the denial of loan applications to Asians
was consistent with those of other racial and ethnic categories, the sheer volume of
lending applications by Asians greatly outnumbered every other racial group (963 of
1231 lender actions were for Asians) which indicates that Asians are
disproportionately represented in the home purchase market as the group currently
represents 60.7% of the City's population.
In 2013, East West Bank, a Chinese - American owned mortgage lender
headquartered in Pasadena, processed no applications for home purchase from
Whites, Hispanics, or African Americans, the only non -Asian American application
being from a Native American person. Asians represented 97.4% of the home
purchase market with loans financed by East West Bank, the largest home purchase
lender in the Rosemead market.
Actions Proposed to Overcome Potential Impediment.
• Distribute information materials to Rosemead residents regarding lending
discrimination.
• Conduct a Fair Lending Workshop for Rosemead residents.
• Maintain partnership with a fair housing provider who is able to provide fair
housing services to Rosemead residents about equal access to housing
opportunities, including home ownership programs and education services to
lenders in regards to fair housing and fair lending laws.
• Examine ways in which the City can encourage and motivate East West Bank to
conduct outreach and provide lending information and opportunities to non -Asian
communities in the San Gabriel Valley in an effort to diversity its lending portfolio
in the City of Rosemead.
The Al 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. The City is committed to addressing 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.
City Council Report
April 28, 2015
Page 7 of 7
It is the City's intent to continue to contract with a fair housing organization to implement
a Fair Housing Program within Rosemead that will 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.
Over the next five years, the City will also affirmatively further fair housing and eliminate
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 the City's newsletter and website. 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
over the next five year period (July 1, 2015 — June 30, 2020). 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 Rosemead Reader on April 16, 2015,
as well as through the regular agenda notification process.
Prepared by:
Michelle G. Ramirez
Community Development Director
Attachment A — Analysis of Impediments to Fair Housing Choice Study
ATTACHMENT A
Analysis of Impediments
To
Fair Housing .Choice
Prepared By:
The Southern California Housing Rights Center
3255 Wilshire Boulevard, Suite 1150
Los Angeles, CA 90010
(800) 477 -5977
www.hrc- la.org
April 2015
2015 — 2020 Analysis of Impediments to Fair Housing Choice,
Reserved
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2015 - 2020 Analysis of Impediments to Fair Housing Choice,
Table of Contents
I. Executive Summary
A. Purpose of Analysis
B. Data Sources and Methodology
C. Key Findings and Recommendations
II. Demographic Profile of Rosemead
A. Households and Families
B. Race
C. Age
D. Homeowner /Renter
E. Income
F. Employment
G. Education
H. Government Subsidized Housing
III. Evaluation of Current Fair Housing Profile
A. Client Demographic Profile .
B. Summary of Housing Discrimination Complaints
C. Requests for Assistance with General Housing Concerns
IV. Rental Audit Testing in Rosemead
A. Purpose of the Audit
B. Audit Methodology
C. Audit Results
D. Conclusion
V. Analysis of Rosemead Resident Surveys
A. Demographic Profile of Respondents
B. Analysis
C. Conclusion
VI. Review of Government Policies
A. Direct Conflicts
B. Other Relevant Considerations
VII. Home Mortgage Disclosure Act Data
A. Access to Housing Credit in Rosemead - General Background
B. Access to Housing Credit in Rosemead -Local Practices
C. Access to Housing Credit in Rosemead - Conclusion
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0 1. EXECUTIVE SUMMARY
A. Purpose of the. Analysis of Impediments (AI) to Fair Housing Choice
The City of Rosemead receives annual funding from the U.S. Department of Housing
and Urban Development (HUD) for its Community Development Block Grant (CDBG)
program and HOME Investment Partnerships (HOME) program. The regulations of
these programs require that the grantees certify that they will "affirmatively further fair
housing."
The CDBG program contains a regulatory requirement to affirmatively further fair
housing based upon HUD's obligation under Section 808 of the Fair Housing Act.
Pursuant to CDBG regulations [24 CFR Subtitle A §91.225(a)(1)], to receive CDBG
funds, a jurisdiction must certify that it "actively furthers fair housing choice." HUD
requires each jurisdiction to certify that it will engage in fair housing planning by:
a. Conducting an Analysis of Impediments to Fair Housing Choice (Al);
b. Undertaking actions to overcome the effects of identified impediments; and
c. Maintaining records and make available information and reports, including the Al.
The Al, presents: 1) a demographic profile of the City of Rosemead; 2) assesses the
extent of fair housing issues among specific groups; 3) evaluates the availability of a
range of housing choices for all residents; and 4) analyzes the conditions in the private
market and public sector that may limit the range of housing choices or impede a
person's access to housing.
HUD requires "actions to affirmatively further fair housing" of all jurisdictions that receive
funds through the submission of a five year Consolidation Plan. As a result, each
jurisdiction is required to develop an Al that coincides with the five -year Consolidated
Plan. 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." 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, marital status,
color, religion, ancestry, sex, sexual orientation, disability, national origin or
arbitrary characteristics such as age or sources of income."
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Fair housing is a right protected by numerous federal and State of California laws.
Among these laws, every housing unit in California is subject to anti - discrimination laws
and practices.
Federal Laws
The first federal statute enacted to give African - Americans, and subsequently all
Americans, equal rights to property was Section 1982 of the Civil Rights Act of 1866.
Almost 100 years later, President Kennedy signed Executive Order 11,063
prohibiting discrimination in housing that is owned, operated or assisted by the
federal government. This prohibition extended to race, religion and national origin.
The Civil Rights Act of 1964 prohibited the denial of benefits and discrimination by
any program or activity receiving federal financial assistance. (42 U.S. Code §
2000(d)). It covered discrimination in the location and occupancy of subsidized
housing and in the administration of federal urban revitalization programs. The
federal Fair Housing Act of 1968 and Fair Housing Amendments Act of 1988
(collectively referred to herein as the "federal fair housing act "; 42 U.S. Code §§
3601 -3619, 3631) are federal fair housing laws that prohibit discrimination in all
aspects of housing, including the sale, rental, lease, or negotiation for real property.
In 1994, President Clinton executed Executive Order No. 12,259 strengthening the
government's commitment to an aggressive, expanded fair housing effort through
the establishment of HUD's Fair Housing Council. The order requires all federally
regulated programs to conduct their affairs in a manner that is consistent with the
goal of affirmatively furthering fair housing.
The federal fair housing act prohibits discrimination based on the following protected
classes:
• Race or color
• Religion
• National origin
• Sex
• Familial status
• Disability (mental or physical)
Reasonable Accommodations, Reasonable Modifications, and Accessibility - The
Fair Housing Amendments Act .requires owners of housing facilities to make
"reasonable accommodations" (exceptions) in their rules, policies, and operations
to give people with disabilities equal opportunities to housing. For example, a
landlord with a "no pets" policy may be required to grant an exception to this rule
and allow an individual who is blind to keep a guide dog in the residence. The Fair
Housing Act also requires landlords to allow tenants with disabilities to make
reasonable modifications to their private living space, as well as to common use
spaces in some circumstances, to improve accessibility at the tenant's own expense.
Finally, the Act requires that new multi- family housing with four or more units be
designed and built to allow access for persons with disabilities. This includes
accessible common use areas, doors that are wide enough for wheelchairs,
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kitchens and bathrooms that allow a person using a wheelchair to maneuver, and
other adaptable features within the units.
HUD Final Rule on Equal Access to Housing in HUD Programs - On March 5, 2012,
HUD implemented the final rule on "Equal Access to Housing in HUD Programs
regardless of Sexual Orientation or Gender Identity." The rule makes it explicit that
eligibility determinations for HUD - assisted or HUD - insured housing must be made
without regard to actual or perceived sexual orientation, gender identity (a person's
internal sense of being male or female) , or marital status. The rule also states that
housing assisted or insured by HUD must be made available without regard to actual
or perceived sexual orientation, gender identity, or marital status. In addition to
housing assisted or insured by HUD, the rule applies to all McKinney - Vento- funded
homeless programs, including temporary, emergency shelters with shared
bedrooms or bathrooms.
Other federal laws that prohibit discrimination in housing related matters include:
Equal Credit Opportunity Act, Community Reinvestment Act, Uniform Relocation
Assistance Act, Section 504 of the Rehabilitation Act of 1973, Americans with
Disabilities Act of 1990, Age Discrimination Act of 1975, and Home Mortgage
Disclosure Act.
2. State Laws
The California Fair Employment and Housing Act (FEHA) (Government Code
§ 12955 et seq.) prohibits discrimination and harassment in housing practices.
The following categories are protected by FEHA:
• Race or color
• Ancestry or national origin
• Sex
• Marital status
• Source of income (including whether the renter is receiving government aid)
• Familial status (households with children under 18 years of age, foster children
and pregnant mothers to be)
• Religion
• Mental /physical disability (including when the person is not disabled but
perceived to be)
• Medical condition
• Age
• Sexual Orientation
• Gender Expression /Identity
• Genetic Information
In addition, the FEHA contains similar reasonable accommodations and accessibility
provisions,as the federal Fair Housing Amendments Act.
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Other state laws that provide protection from discrimination in housing include:
• The Unruh Civil Rights Act (Unruh Act) provides protection from
discrimination by all business establishments in California, including housing
and accommodations because of: age, ancestry, color, disability, national
origin, race, religion, sex, and sexual orientation. While the Unruh Act
specifically lists "sex, race, color, religion, ancestry, national origin, disability,
and medical condition" as protected classes, the California Supreme Court has
held that protections under the Unruh Act are not necessarily restricted to these
characteristics.
• The Ralph Civil Rights Act (California Civil Code Section 51.7) forbids acts
of violence or threats of violence because of a person's race, color, religion,
ancestry, national origin, age, disability, sex, sexual orientation, political
affiliation, or position in a labor dispute. Hate violence can be: verbal or
written threats; physical assault or attempted assault; and graffiti, vandalism,
or property damage.
• The Bane Civil Rights Act (Bane Act) (California Civil Code Section 52.1)
provides another layer of protection for fair housing choice by protecting all
people in California from interference by force or threat of force with an
individual's constitutional or statutory rights, including a right to equal access
to housing. The Bane Act also includes criminal penalties for hate crimes;
however, convictions under this Act are not allowed for speech alone unless
that speech itself threatened violence.
• The California Civil Code Section 1940.3 prohibits landlords from questioning
potential residents about their immigration or citizenship status. In addition,
this law forbids local jurisdictions from passing laws that direct landlords to
make inquiries about a person's citizenship or immigration status.
In addition to these acts, Government Code Sections 11135, 65008, and 65580-
65589.8 prohibit discrimination in programs funded by the State and in any land
use decisions. Specifically, Sections 65580 - 65589.8 require local jurisdictions to
address the provision of housing options for special needs groups, including:
• Housing for persons with disabilities (SB 520)
• Housing for homeless persons, including emergency shelters, transitional.
housing, and supportive housing (SB 2)
• Housing for extremely low income households, including single -room
occupancy units (AB 2634)
• Housing for persons with developmental disabilities (SB 812)
Prohibited activities include or involve:
Advertising
• Application and selection process
• Unlawful evictions
Terms and conditions of tenancy
• Privileges of occupancy
• Mortgage loans and insurance
• Public and p riv ate l use practices (zoning)
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Unlawful restrictive covenants
Specifically, it is unlawful under both federal and state law to:
• Refuse to sell or rent after the making of a bona fide offer, or to refuse to
negotiate for the sale or rental of, or otherwise make unavailable or deny, a
dwelling to any person because of race, color, religion, sex, disability, familial
status, or national origin.
• Discriminate against any person in the terms, conditions, or privileges of sale or
rental of a dwelling, or in the provision of services or facilities in connection
therewith, because of race, color, religion, sex, disability, familial status, or
national origin.
• Make, print, or publish, or cause to be made, printed, or published any notice,
statement, or advertisement, with respect to the sale or rental of a dwelling
that indicates any preference, limitation, or discrimination based on race,
color, religion, sex, disability, familial status, or national origin, or an intention
to make any such preference, limitation, or discrimination. This prohibition
applies to housing that would not be covered under current fair housing law -
e.g., if a person is renting a second unit on the property where that person lives
in the only other unit, it would be unlawful to use discriminatory language in the
• Represent to any person because of his /her membership in one of the protected
classes that any dwelling is not available for inspection, sale, or rental when
such dwelling is in fact so available.
• For profit, induce or attempt to induce any person to sell or rent any
dwelling by representations regarding the entry or prospective entry into the
neighborhood of a person or persons of a particular race, color, religion, sex,
disability, familial status, or national origin.
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 encourages:- (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 - A comparison of U.S. Census data from 2000 to
2010 with updated information from the U.S. Census American Community
Survey of 2013. The Al contains occasional references to U.S. Census data
from 1990 in order to evaluate some key demographic changes and what they
might mean to housing availability, accessibility, and affordability.
• Status of Affordable Housing Availability /Housing Conditions - Data collected
from the City of Rosemead, the Housing Authority of the County of Los
Angeles, and interviews of community members and non - profit agencies that
serve residents of the City of Rosemead.
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• Housing Rights Center Complaint Data - Housing complaint statistics for the
period July 1, 2009 to June 30, 2014.
• Rental Audit Testing - Random audit testing of 25 Rosemead rental units to
determine levels of discrimination based on disability and familial status.
• Survey of Rosemead Residents - A survey of 32 Rosemead residents.
• Rosemead Zoning Code - A review of 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 - A comparison of HMDA data
from 2013 to data from 2006 -2008.
C. Key Findings and Recommendations
This Al study analyzed data (U.S. Census, fair housing complaints, City and federal
government, and HMDA), 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.
Demographic profile and Subsidized Housing (Section II)
Potential Impediment.
The Housing Authority of the County of Los Angeles (HACoLA) administers the
Housing Choice Voucher program for those who use their Section 8 vouchers in the
City of Rosemead. HUD implemented the Section 8 voucher program to promote
racial and ethnic integration in its affordable housing programs. Under the Section
8 voucher program the recipient may use the subsidized housing voucher if it is
accepted by a private housing provider.
Similar to data for the state of California, in the Greater Los Angeles area, the
majority of Section 8 voucher participants are Black/African American (36 %). Asians
only represent 11 % of the voucher participants in the Greater Los Angeles area. In
Rosemead, however, Black/African Americans only represent 1% of Section 8
voucher holders and Asians represent 74% of the Section 8 voucher holders.
Considering that Asians represent 60.7% of the total population, they are
disproportionally receiving and utilizing federally subsidized housing in the City of
Rosemead. It is possible that Black/African American Section 8 voucher holders
have difficulty in finding a housing provider in the City of Rosemead who will rent to
them. It is also possible that Black/African American Section 8 voucher holders do
not attempt to rent in Rosemead out of concern that they will feel isolated in a city
with so few African Americans. In addition, some housing providers are reluctant
to accept government housing assistance for low- income renters.
Community Development Department Page 10
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Housing Choice,
Actions Proposed to Overcome Potential Impediment.
• Examine ways in which the City can work with HACoLA to encourage Rosemead
housing providers to advertise available units in areas that are more racially and
ethnically diverse.
• Examine ways in which the City can work with HACoLA to provide more
education and outreach to housing providers about the benefits of the Section 8
rental assistance program in an effort to avoid possible negative stereotyping of
ethnic minorities, Section 8 housing subsidy recipients, and government
assistance programs.
Current Fair Housing Profile and Trends (Section III)
Potential Impediment.
a. Housing Complaints from the Asian Population in Rosemead - According to the
2010 census, the Asian population made up 60.7% of the Rosemead population.
In 2000, the Asian population made up 48.7% of the Rosemead residents.
Approximately 20% of Rosemead residents assisted by HRC over the past five
years were Asian. Conversely, the Hispanic population made up 33.8% of the
Rosemead population and approximately 60% of Rosemead residents assisted
by the HRC over the past four years. 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. At the same time,
a significant number of housing opportunities including home purchases tend to
favor Asians numerically. This may indicate differential treatment in rentals and
home purchase lending against non - Asians in Rosemead which would merit more
education and outreach to the Asian housing providers and lenders about their
responsibilities under fair housing laws.
While various conclusions may be drawn from this data, two questions of
relevance are whether discriminatory housing practices may be
disproportionately impacting non -Asian populations within the City, and /or
whether Asian residents may be turning to resources other than fair housing
organizations for assistance with housing issues, if they do at all. The relatively
low number of Asian clients seeking assistance from HRC becomes even more
noteworthy in light of the relatively large number of Hispanic /Latino residents who
comprised HRC's Rosemead clientele during the 10 -year period in question. One
possible conclusion is that Hispanic residents of Rosemead are outpacing Asian
residents in terms of their need for fair housing services. Another conclusion is
that if the Asian population is significantly foreign -born or recently immigrated, it
may not be using the City's public service programs such as the Housing Rights
Center's (HRC) fair housing services program in a ratio proportionate with its size
due to unfamiliarity with such programs. It is recommended that the City of
Rosemead and the HRC work together in doing more outreach to Asian immigrant
and non - immigrant tenants and housing providers to ensure that they are aware
of their rights and responsibilities under fair housing law.
Community Development Department Page 11
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Nousing Choice
Actions Proposed to Overcome Potential Impediment:
• Advertise all fair housing workshops to housing providers and tenants in English
and Chinese.
• Work with the Rosemead Chamber of Commerce to identify businesses and
housing providers for outreach and education opportunities.
• Utilize publications such as the Chamber of Commerce's Rosemead Report, and
the City newsletter (Rosemead Resources) and website to provide information
to housing providers and Rosemead residents about fair housing services.
b. Housing Discrimination Complaints Based on Disability - Over the past five years
the number of housing discrimination complaints based on physical disability has
remained disproportionally high making up 44 % of all housing discrimination
complaints reported by Rosemead residents. This indicates a continuing need
for education of landlords on laws that protect the rights of people with disabilities
and fair housing laws in general.
Actions Proposed to Overcome Potential Impediment:
• Submit regular articles to the Rosemead Resources and Chinese language
newspapers on fair housing and people with disabilities.
• Highlight disability discrimination at fair housing workshops in Rosemead.
• Distribute informational materials in the City that focus on fair housing and people
with disabilities.
Audit Testing (Section IV)
Potential Impediment:
The HRC conducted 25 phone tests to measure levels of housing discrimination in
the City of Rosemead. The tests measured discrimination against people with
disabilities and families with children. The HRC found that 67% of the disability
phone tests showed evidence of potential 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 from the City's business license database, property search
database, etc. and work with the Rosemead Chamber of Commerce to publish
information in its publications to its members.
• Work with other social services organizations serving Rosemead residents to
educate their staff and client community about fair housing laws.
1 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 three years is 43. Of this number 30 were based on physical
or mental disabilitv.
Community Development Department Page 12
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Housing Choice
Maintain partnership with a fair housing provider who is able to provide fair
housing services to Rosemead residents.
Community Survey (Section V)
Potential Impediment:
The HRC conducted a survey of 31 Rosemead residents. The survey showed that
36% of respondents had no knowledge of the fair housing laws and 45% had very
little knowledge of the fair housing laws. According to the 2010 census, the
population of Rosemead was 53,764 with an estimated population in 2013 of 54,561.
From July 1, 2009 to June 30, 2014, the HRC assisted 626 Rosemead residents,
which represents 1.6% of the total population based on 2010 census figure. 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.
• Include public service announcements on the City's website regarding fair
housing laws.
• Submit articles to social service organizations serving Rosemead residents and
in the Rosemead Resources on current fair housing topics.
• Maintain partnership with a fair housing provider who is able to provide fair
housing services to Rosemead residents.
Rosemead Rental Housing Conditions (Section VII)
Potential Impediment.
Tenants often experience habitability problems but do not have the ability to address
the problem with their housing provider because of fear of retaliation or lack of
resources to document the conditions and hold the housing provider accountable for
the necessary repairs. Members of protected classes under fair housing laws
including seniors, disabled persons, minorities, and female heads of households are
often the most vulnerable to poor conditions and may not be or feel empowered to
address the issue without government assistance.
In conducting outreach, some Rosemead Mobilehome Park residents expressed
concern about poor conditions at the Mobilehome Parks. The City of Rosemead has
no jurisdiction over Mobilehome Parks. They are regulated by the California
Department of Housing and Community Development's Manufactured Housing
Program. The City does offer the Owner - Occupied Rehabilitation program to low
and moderated - income residents of mobile home parks. Through these programs,
the City makes funds available to assist homeowners in making needed
rehabilitation improvements.
Actions Proposed to Overcome Potential Impediment.
The City should have information available for its Mobilehome Park residents about
the State's Mobilehome Ombudsman, which receives and processes complaints
related to living in mobile homes.
Community Development Department Page 13
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Nousing Choice
Rosemead Home Mortgage Disclosure Act Data (Section VIII)
Potential Impediment.
From the perspective of barriers to fair housing, a detailed analysis of Rosemead
HMDA lending patterns present a stark change in lending in Rosemead since 2008.
First, the evidence of redlining is not as clear as it was in the 2010 Al. The minority
population in Rosemead is now a majority population throughout the City. The large
majority of home purchase loans by all lenders made in Rosemead have been to
Asian applicants.
Of all applicants for home purchase loans and refinance loans in Rosemead in 2013,
75.5% were Asian American. This compares to 55% in 2008. For Hispanics, the
percentages of market demand was 15.5% in 2013, compared to 34% in 2008.
Whites consisted of 7.1 % of the market demand in 2013, compared to 11 % in 2008.
The remaining groups, primarily African American and Native American, consisted
of less than 3% of the market demand. While the denial of loan applications to Asians
was consistent with those of other racial and ethnic categories, the sheer volume of
lending applications by Asians greatly outnumbered every other racial group (963 of
1231 lender actions were for Asians) which indicates that Asians are
disproportionately represented in the home purchase market as the group currently
represents 60.7% of the City's population.
In 20.13, East West Bank, a Chinese - American owned mortgage lender
headquartered in Pasadena, processed no applications for home purchase from
Whites, Hispanics, or African Americans, the only non -Asian American application
being from a Native American person. Asians represented 97.4% of the home
purchase market with loans financed by East West Bank, the largest home purchase
lender in the Rosemead market.
Actions Proposed to Overcome Potential Impediment.
• Distribute information materials to Rosemead residents regarding lending
discrimination.
• Conduct a Fair Lending Workshop for Rosemead residents.
• Maintain partnership with a fair housing provider who is able to provide fair
housing services to Rosemead residents about equal access to housing
opportunities, including home ownership programs and education services to
lenders in regards to fair housing and fair lending laws.
• Examine ways in which the City can encourage and motivate East West Bank to
conduct outreach and provide lending information and opportunities to non -Asian
communities in the San Gabriel Valley in an effort to diversity its lending portfolio
in the City of Rosemead.
Community Development Department Page 14
City of Rosemead FY 2015 -2020
2015 -2020 Analysis of Impediments to Fair Housing Choice
Reserved
Community Development Department Page 15
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Non sing Choice
&II. DEMOGRAPHIC PROFILE OF ROSEMEAD
The City of Rosemead is one of 88 incorporated cities in Los Angeles County, California.
Rosemead is located in the San Gabriel Valley and is surrounded by the cities of San
Gabriel to the northwest, Monterey Park to the west, Temple City to the northeast, El
Monte to the East, South El Monte to the Southeast, and the unincorporated area of
South San Gabriel and Montebello to the south. The City of Rosemead includes many
immigrants and descendants of immigrants from Asia and Latin America.
A. Households and Families
The City of Rosemead experienced an increase in population between 1990 and 2000
and again between 2000 and 2010. The City's population increased from 51,638 in 1990
to 53,505 in 2000 representing an increase of 3.62 %. In 2010, the population increased
slightly to 53,764. The estimated population in 2013 was 54,561, a 1.5% increase which
is lower than the 2.9% increase for the state of California from 2010 to 2013. The
number of total households increased from 13,701 in 1990 to 13,913 in 2000 to 14,247
in 2010. The average number of persons per household fluctuated from 3.72 in 1990,
to 3.70 in 2000 to 3.74 in 2010. In 2010, there were 14,247 households while there
were only 13,913 households in 2000. The number of families grew from 11,632 in
2000 to 11,903 in 2010. The number of persons per family increased as well from
3.43 in 2000 to 3.99 in 2010. The number of families with children rose from 2,416 in
2000 to 2,502 in 2010. The number of female- headed households has consistently
grown from 2,106 in 1990 to 2,416 in 2000 to 2,502 in 2010.
Table 2.1
Population, Household, and Family Changes
2000 and 2010
Category
2000
2010
% Change
Total Population
53,505
53,764
+.48
# of Households
13,913
14,247
+2.40
# of Persons per household
3.70
3.74
+1.08
# of Families
11,632
11,903
+2.33
# of Persons per Family
4.19
3.99
-4.77
# of Families with Children
5,686
6,267
+10.22
# of Female- Headed Households
2,416
2,502
+3.56
2 A household consists of all people who occupy a housing unit regardless of relationship. A household may consist
of a person living alone or multiple unrelated individuals or families living together. U.S. Census definition.
3 A family consists of two or more people (one of whom is the householder) related by birth, marriage, or adoption
residing in the same housing unit. U.S. Census definition.
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City of Rosemead FY 2015 -2020
2015 = 2020 Analysis of Impediments to Fair Noosing Cho ce
According to the 2010 U.S. census, there were 14,247 households, out of which 8,028
(56.3 %) were opposite -sex married couples living together, 2,502 (17.6 %) had a female
householder with no husband present, 1,373 (9.6 %) had a male householder with no
wife present .4 There were 571 (4.0 %) unmarried opposite -sex partnerships, and 74
(0.5 %) same -sex married couples or partnerships. 1,739 households (12.2 %) were
made up of individuals and 844 (5.9 %) had someone living alone who was 65 years of
age or older. The average household size was 3.74. There were 11,903 families (83.5%
of all households); the average family size was 3.99.
B. Race
In 2010, of the City's 53,764 residents, the racial makeup of Rosemead was 32,617
(60.7 %) Asian 5 , 11,348 (21.1%) White, (4.7% Non - Hispanic White), 396 (0.7 %) Native
American, 273 (0.5 %) African American, 32 (0.1%) Pacific Islander, 7,940 (14.8 %) from
other races, and 1,158 (2.2 %) from two or more races. Hispanic or Latino of any race
was 18,147 persons (33.8 %).
In 2000, by comparison, there were 53,505 people residing in the City. The racial
makeup of the City was 48.76% Asian, 26.57% White, 0.85% Native American, 0.68%
African American, 0.06% Pacific Islander, 19.69% from other races, and 3.38% from
two or more races. Hispanic or Latino of any race was 41.30% of the population. For
2013, the estimated population was 54,561.
C. Age
The age of the population was spread out with 12,231 people (22.7 %) under the age of
18, 5,225 people (9.7 %) aged 18 to 24, 14,952 people (27.8 %) aged 25 to 44, 14,392
people (26.8 %) aged 45 to 64, and 6,964 people (13.0 %) who were 65 years of age or
older. The median age was 38.1 years. For every 100 females there were 97.3 males.
For every 100 females age 18 and over, there were 94.9 males.
D. Homeowner /Renter .
In 2010, there were 14,805 housing units of which 6,972 (48.9 %) were owner - occupied,
and 7,275 (51.1 %) were occupied by renters.' The homeowner vacancy rate was 0.9 %;
the rental vacancy rate was 3.2 %. 26,324 people (49.0% of the population) lived in
owner - occupied housing units and 27,027 people (50.3 %) lived in rental housing units.
The 2010 U.S. Census also reported that 53,351 people (99.2% of the population) lived
in households, 135 (0.3 %) lived in non - institutionalized group quarters, and 278 (0.5 %)
were institutionalized.
5 For the 32,617 Asians, the largest populations were Chinese (18,794 -35 %), Vietnamese at (8,268 - 15.4 %) and
Filipino (816 - 1.5 %).
6 For the 18,147 Hispanics or Latinos, the largest population was Mexican (15,469 - 28.8 %).
7 A housing unit differs from a household in that it is a house, apartment, mobile home, or a single room that is
occupied or vacant, and meant to serve as separate living quarters.
Community Development Department Page 17
City of Rosemead FY 2015 -2020
1 2015 - 2020 Analysis of Impediments to Fair Housing Choice
E. Income
Even though the median household income increased in 2010 to $46,781 (in 2000, the
median income for a household $44,115), the 2010 census and the 2013 American
Community Survey reflected a significant increase in the percentage of the population
living under the federal poverty line. 8 In 2000, 12.9% of the population lived below the
federal poverty line. In 2010, 17.2% of the population lived below the federal poverty
line. In 2013, 18.8% of the population lived below the federal poverty line.
Table 2.2
Families /Persons under Federal Poverty Level
Percentage of families and persons whose annual income is below
the federal poverty level
2013
All families
16.6%
With related children under 18 years
24.1%
With related children under 5 years only
18%
Married couple families with children under 18 years
23.5%
Families with female householder w /children under 18 years
31.5%
All people
18.8%
F. Employment
Overall, labor force participation rates increased for Rosemead by 5.8 between 2000
and 2014. The unemployment rate increased from 5.8% in 2000, to a high of 11.8% in
2010 and back down to 6.7% in 2014 with a current job growth of 2.50 %. Future job
growth over the next ten years is predicted to be 38.30 %.
Table 2.3
Changes in Labor Force Participation Rate & Unemployment
2000 and 2014
Labor Rates
2000
2014
Difference
Labor Force Participation Rates
52.9
58.7%
+5.8
Unemployment Rates
5.8
6.7
+.9
The income per capita is $17,534, which includes all adults and children. The median
household income is $46,781. The median family income is $48,896.
G. Education
Rosemead has one public high school with 1800 students and ten public elementary
and middle schools. There are 5 colleges and universities within 6 miles of Rosemead.
8 The U.S. Census Bureau uses a set of income thresholds that vary by family size and composition to determine
who is in poverty. If a family's total income is less than the family's threshold, then that family and every individual
in it is considered in poverty and below the federal poverty line. In 2013, the poverty threshold for a single person
under 65 was at an annual income of $11,490; the threshold for a family group of four, including two children, was
$23,550.
Community Development Department Page 18
City of Rosemead FY 2015 -2020
2015 - 2020 Analivsis of Impediments to Fair Housing Choice,
Table 2.4
Education Levels as of 2013
H. Government Subsidized Housing
There are only two subsidized low- income housing properties in Rosemead and both
are owned by the City and are for seniors only. Angelus Senior Apartments is made up
of 50 1- bedroom units and 1 2- bedroom unit, and Garvey Senior Apartments is made
up of 64 1- bedroom units and 8 2- bedroom units - for a total of 123 units. Both are fully
occupied and one waiting list is being maintained for both properties. For the federally
subsidized Section 8 program administered by the Housing Authority of the County of
Los Angeles (HACoLA), there are the following numbers of Section 8 vouchers that are
utilized in the City of Rosemead by year: 2010 - 398, 2011 - 403, 2012 - 413, 2013 -
398, and 2014 - 386.
As of March, 5, 2015, the total number of Section 8 vouchers used in the City of
Rosemead was 382. The most interesting statistic relates to the race and ethnicity of
the Section 8 participants in the City Rosemead, especially when compared to the race
and ethnicity of Section 8 participants in the Greater Los Angeles area.
Similar to data for the state of California, in the Greater Los Angeles area the majority
of Section 8 voucher participants are Black or African American (36 %). Asians only
represent 11% of the voucher participants in the Greater Los Angeles area. In
Rosemead, Black/African Americans only represent 1% of Section 8 voucher holders
and Asians represent 74% of the Section 8 voucher holders. Considering that Asians
represent 60.7% of the total population, their use of the federally subsidized housing in
Rosemead is disproportionate to their number in the City.
Table 2.5 Subsidized Housin
Section 8 participants residing in Rosemead
Rosemead, CA
%
California
U.S.
Total 25 Years and Over Population
37,111
100%
American Indian
1
Less Than High School
14,020
37.78%
18.98%
14.28%
High School Graduate
8,957
24.14%
20.68%
28.24%
Some College or Associate Degree
1 8,828
23.79%
29.88%
28.99%
Bachelor Degree
1 3,979
10.72%
19.35%
17.88%
Master, Doctorate, or Professional De ree
1 1,327
3.58%
1 11.10%
1 10.61%
H. Government Subsidized Housing
There are only two subsidized low- income housing properties in Rosemead and both
are owned by the City and are for seniors only. Angelus Senior Apartments is made up
of 50 1- bedroom units and 1 2- bedroom unit, and Garvey Senior Apartments is made
up of 64 1- bedroom units and 8 2- bedroom units - for a total of 123 units. Both are fully
occupied and one waiting list is being maintained for both properties. For the federally
subsidized Section 8 program administered by the Housing Authority of the County of
Los Angeles (HACoLA), there are the following numbers of Section 8 vouchers that are
utilized in the City of Rosemead by year: 2010 - 398, 2011 - 403, 2012 - 413, 2013 -
398, and 2014 - 386.
As of March, 5, 2015, the total number of Section 8 vouchers used in the City of
Rosemead was 382. The most interesting statistic relates to the race and ethnicity of
the Section 8 participants in the City Rosemead, especially when compared to the race
and ethnicity of Section 8 participants in the Greater Los Angeles area.
Similar to data for the state of California, in the Greater Los Angeles area the majority
of Section 8 voucher participants are Black or African American (36 %). Asians only
represent 11% of the voucher participants in the Greater Los Angeles area. In
Rosemead, Black/African Americans only represent 1% of Section 8 voucher holders
and Asians represent 74% of the Section 8 voucher holders. Considering that Asians
represent 60.7% of the total population, their use of the federally subsidized housing in
Rosemead is disproportionate to their number in the City.
Table 2.5 Subsidized Housin
Section 8 participants residing in Rosemead
2015
Total Number
382
Households with an elderly person
162
Households with a disabled person
168
American Indian
1
Asian
284
White
93
Black/African American
4
Hispanic/Latino
88
Non-Hispanic/Latino
294
Community Development Department Page 19
City of Rosemead FY 2015 -2020
2015- 2020 Analysis of Impediments to Fair Housing Cho
8 Housing Choice Voucher (HCV) Program - HACoLA administers the Section
8 program for persons who chose to use their vouchers in the City of Rosemead. The
HCV Program is the federal government's major program for assisting very low- income
families, elderly, and disabled to afford decent, safe, and sanitary housing in the private
market. Eligibility for a HCV is based on the total annual gross income and family size
and is limited to US citizens and specified categories of non - citizens who have eligible
immigration status. A family that is issued a voucher is responsible for finding a suitable
housing unit of the family's choice where the owner agrees to rent under the program.
A housing subsidy is paid to the landlord directly by the Housing Authority on behalf of
the family. The family must pay 30% of its monthly adjusted gross income for rent and
HACoLA pays the remainder of the contract rent. There are 20,670 vouchers allocated
under this program country wide. HACoLA reports that it has received complaints from
participants that housing providers are overall unwilling to accept Section 8 tenants.
Community Development Department Page 20
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2015 — 2020 Analysis of Impediments to Fair Housing Choice
Reserved
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2015 - 2020 Analwis of Impediments to Fair Housing Choice
* 111111. 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 HRC to affirmatively further
fair housing opportunities for over a decade._ The HRC was originally founded in 1968.
The 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 currently contracts with the HRC to provide its residents with fair
housing services that include education and outreach, counseling and legal services.
A. Client Demographic Profile
1. Income Levels of Clients Served: Fiscal Year 2009 -10 — FY 2013 -14
Overall, 95.5% of Rosemead residents assisted by the HRC in the past five years
were extremely low to low- income individuals and families. There was an 11.5%
increase in the percentage of extremely low to low- income persons served during
this period as compared to those served during FY 2005 through 2009. This
increase is interesting given the fact that the overall number of extremely low to low
income individuals and families decreased in the past five years.
Table 3.1
Income Level of Rosemead Clients
Income Level
Extremely Low
July 1, 2009 to
June 30, 2010
July 1, 2010 to
June 30, 2011
July 1, 2011 to
June 30, 2012
•
July 1, 2012 to
June 30, 2013
July 1, 2013 to
June 30, 2014
Total
Above Moderate
1
1
1
1
1
Community Development Department Page 22
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Housing Choice
2. Race of Clients Served: Fiscal Year 2009 -11 - FY 2013 -14
In 2002, the U.S. Department of Housing and Urban Development required
recipients of CDBG 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 five years, the highest number of Rosemead residents assisted by
the HRC were: Other (34.2 %), followed by American Indian /Alaskan Native (27.8 %),
followed by Asian (19.6 %). The reason the percentage of clients who identified as
"Other' is so high is that Hispanic /Latino is not a separate race category according
to the US Census. Most often when asked their race, Hispanic Latino clients identify
as "Other." In FY 2011 and 2012, the number of clients identifying as American
Indian /Alaskan Native increased but the majority of those persons were
Hispanics /Latinos who would have been classified as Other if not for a temporary
skew in client screening due to HUD variations and clarifications of required current
(Native American) tribal affiliation for inclusion in that racial category and
Hispanic /Latino definitions.
The number of Asian clients served remained consistent with an average of 25 Asian
persons /households served per year but the overall percentage of Asians served
decreased by 3.9% since the FY 2006 -09 fair housing service period. According to
the 2010 census, the Asian population made up 60.7% of the Rosemead population
but only 19.6% of Rosemead residents assisted by HRC over the period July 1, 2009
to June 30, 2013 were Asian. There are a few explanations for this unbalanced
figure. Most of the rental housing market in Rosemead is owned and /or managed by
persons of Asian descent, most of whom are Chinese. There may, therefore, be a
bias in favor of Chinese rental applicants and in -place tenants. Also, language
barriers may make it for difficult for non - Chinese speaking or non - Chinese language
literate persons to apply for rental housing. Finally, recent immigrant landlords and
managers may not have a thorough knowledge of federal and state fair housing
laws.
Recommendation: increase outreach to educate Chinese property owners,
managers, and brokers in addition to tenants about their rights and
responsibilities under federal and state fair housing laws.
Conversely, the Hispanic population made up 33.8% of the Rosemead population
and approximately 60% 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.
Community Development Department Page 23
City of Rosemead FY 2015 -2020
F — 2015 — 2020 Analysis of Impediments to Fair Housing Choice
Table 3.2
Community Development Department Page 24
City of Rosemead FY 2015 -2020
Race of
Rosemead
Clients
009
i
i
Total
Race
June 30,
June 30
June i
Total
/.
0•
2010
2011
2012
,
American
Indian /Alaskan
0
13
75
66
20
174
3.5%
27.8%
+24.3%
Native
American
Indian /Alaskan
0
0
1
1
1
3
3.8%
0.5%
-3.3%
Native & Black
American
Indian /Alaskan
0
0
1
1
10
12
23.2%
1.9%
- 21.3%
Native & White
Asian
29
23
22
20
29
123
23.5%
19.6%
-3.9%
Asian & White
0
0
1
0
1
0.0%
0.2%
+0.2%
Black/African
4
4
3
2
3
16
1.4%
2.6%
+1.2%
American
Black/African
0
0
0
0
0
0
0.0%
0.0%
NA
American & White
Native
Hawaiian /Other
0
0
0
1
0
1
0.1%
0.2%
+0.1%
Pacific Islander
White
8
11
11
21
31
82
18.0%
13.1%
-4.9%
Other
102
88
0
4
20
214
26.5%
34.2%
+7.7%
Total
143
139
1131
117
114
626
100%
100%
Community Development Department Page 24
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Nousng Ch co e
3. Ethnicity of Clients Served: Fiscal Year 09/10 — FY 13/14
Table 3.3
4. Special Populations Served: Fiscal Year 2009 -10 — FY 2013 -14
The number of seniors and persons with disabilities increased significantly in FY
2012/13 and FY 2013/14. Not surprisingly, as indicated in Table 3.5, the highest
number of discrimination complaints received by the HRC in the past five years is
based on disability.
Table 3.4
B. Summary of Housing Discrimination Complaints
From July 2009 to June 2014, the HRC received 43 housing discrimination complaints
from Rosemead residents. The highest number of complaints was based on physical
and mental disability, which together made up 70% of all discrimination complaints. This
is almost identical to the period July 2002 to March 2005 when the highest number of
complaints was also disability, which made up 56% of all complaints.
Community Development Department Page 25
City of Rosemead FY 2015 -2020
EthnicitX
of Rosemead
Clients
1 1 • .
2010 to
2011 to
2012 to
2013 to
Total
. .
EthInicity
June
June
June
June
June
Total
05/06-
09/1
1 2010
30, 2011
30, 2012
30, 2013
1 2014
08/09
Cuban
0
0
0
1
1
2
0.0%
0.3%
+0.3%
Mexican /Chicano
53
59
71
47
49
279
37.8%
44.6%
+6.8%
30
39
6
19
10
104
13.0%
16.6%
+3.6%
HispaOnic /Latino
Puerto Rican
0
0
1
2
0
3
0.1%
0.5%
+0.4%
60
41
35
48
54
238
49.0%
38.0%
- 11.0%
HispanictLatino
Total
143
139
113
117
114
626
100%
100%
4. Special Populations Served: Fiscal Year 2009 -10 — FY 2013 -14
The number of seniors and persons with disabilities increased significantly in FY
2012/13 and FY 2013/14. Not surprisingly, as indicated in Table 3.5, the highest
number of discrimination complaints received by the HRC in the past five years is
based on disability.
Table 3.4
B. Summary of Housing Discrimination Complaints
From July 2009 to June 2014, the HRC received 43 housing discrimination complaints
from Rosemead residents. The highest number of complaints was based on physical
and mental disability, which together made up 70% of all discrimination complaints. This
is almost identical to the period July 2002 to March 2005 when the highest number of
complaints was also disability, which made up 56% of all complaints.
Community Development Department Page 25
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Nolusing Choice
Table 3.5
Housinq Discrimination Com laints Reported b y Rosemead Residents
Basis of
Complaint
July 1, 2009 to
June 30, 2010
July 1, 2010 to
June 30, 2011
July 1, 2011 to
June 30, 2012
July 1, 2012 to
June 30, 2013
July 1, 2013 to
June 30, 2014
Total
Age
Arbitrary
Familial Status
1
1
2
Gender
1
1
1
3
Marital Status
1
1
Mental
Disability
10
1
11
National Origin
2
2
4
Physical
Disability
5
3
2
3
6
19
Race
1
2
3
Source of
Income
General Info.
Total
18
6
8
4
7
43
Of the 43 complaints, 20 were counseled and 23 were investigated. The HRC found
evidence to support the allegation in 19 cases and in 4 cases the evidence was
inconclusive HRC successfully conciliated 12 cases, in 1 case the client withdrew,
and in 10 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 five years, the HRC has received 582 requests for information or assistance
with housing concerns.
9 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.
10 HRC assigns cases a disposition of "No Enforcement Action Possible" when there is inconclusive evidence of
discrimin
Community Development Department Page 26
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Housing Choice
Table 3.6
Number of Rosemead Residents with General Housing Issues
Year
Number of Complaints
July 1, 2009 to June 20, 2010
124
July 1, 2010 to June 30, 2011
133
July 1, 2011 to June 30, 2012
105
July 1, 2012 to June 30, 2013
113
July 1, 2013 to June 30, 2014
107
Total
582
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.
Community Development Department Page 27
City of Rosemead FY 2015 -2020
2015 — 2020 Analysis of Impediments to Fair Housing Choice
Table 3.7
Tvpes of General Housinq Issues
Landlord/Tenant
Complaints
July 1, 2009 to
June 30, 2010
July 1, 2010 to
June 30, 2011
July 1, 2011 to
June 30, 2012
July 1, 2012 to
June 30, 2013
July 1, 2013 to
June 30, 2014
Total
Eviction
6
11
12
11
3
43
Harassment
6
6
2
1
4
19
Illegal Entry
0
1
0
1
0
2
Late Fees
0
0
1
0
0
1
Lease Terms
12
7
6
9
8
42
Lockout
2
1
2
0
0
5
Notices
42
40
24
26
34
166
Parking
1
2
0
0
1
4
Pets
0
1
0
1
0
2
Relocation
0
3
0
0
0
3
Rent Increase
11
10
9
12
10
52
Repairs
11
14
11
17
11
64
Section 8 Information
2
0
0
0
2
4
Security Deposit
8
14
5
9
5
41
Seeking Housing
3
5
11
7
5
31
Substandard
Conditions
10
9
14
6
9
48
Utilities
0
0
1
0
5
6
General Info /Other
11
9
7
13
10
50
Total
125
133
105
113
107
583
Community Development Department Page 28
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Nousing Choice
Reserved
Community Development Department Page 29
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Housing Choice
IV. RENTAL AUDIT TESTING IN ROSEMEAD
A. Purpose of the Audit
1. Introduction
To measure the extent of discrimination in the rental market, the HRC conducted 25
phone tests within the City of Rosemead. Of the 25 tests, 12 measured-the level of
discrimination against people with disabilities and 13 measured the level of
discrimination on the basis of familial status. The results of the audit tests indicate
that discrimination in housing exists in the City of Rosemead.
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 familial status or disability. 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.
With consideration of legitimate business concerns such as income, length of
employment, and length of tenancy (see methodology below), the goal is to
determine whether people with disabilities and families with children under the age
of 18 are given the same housing opportunity as their counterparts without children
and without disabilities in their efforts to find rental housing.
B. Audit Methodology
1. Overview of Testing
Testing is an enforcement tool used by the HRC to determine whether housing
professionals engage in discrimination in violation of federal and state fair housing
laws". The 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 - PT" and a majority group tester referred to as a "control
tester - CT" who both visit the same housing unit for rent or for sale. The protected
tester 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 legitimate
business justifications for rejecting the applicant.
11 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).
Community Development Department Page 30
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Nousing Choice
Once both testers view the unit, they are required to complete a standardized report
documenting their experience. The HRC is careful to ensure the two testers have
no contact with one another until they have completed their reports. The test
coordinator then analyzes the reports to determine if the testers have experienced
discrimination based on the established criteria noted below.
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 its experience with testing, the HRC has 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.
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. For familial
status tests, the protected tester is required to tell the housing provider that he or
she has a child. If these criteria aren't met, the test is incomplete.
3. Number and Type of Tests
The HRC conducted a total of 25 phone inquiry disability and familial status tests.
The HRC chose to conduct disability tests because complaints based on this
protected classification represented the highest number of complaints received by
the HRC over the past five years. (Please see Section III Table 3.5.). HRC chose
to conduct familial status discrimination testing because it is a prevalent form of
discrimination that is well suited for phone testing.
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 westsiderentals.com, craigslist.com, rent.com,
apartmentlist.com and socialserve.com to locate available rental units. HRC also
conducted three site visits to locate potential rental opportunities.
12 In the tests HRC conducted in Rosemead, the Protected Disabled Tester required the use of a service /companion
animal. 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 golicv to accommodate her need for a seeing -eve doq.
Community Development Department Page 31
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Nousing Choice
C. Audit Results
Audits of Possible Discrimination Based on Disability
The HRC conducted 12 phone tests to measure discrimination against people with
disabilities.
1. Audits Finding Evidence of Discrimination and Potential Discrimination
Of the 12 Disability tests conducted in Rosemead, 8 tests (67 %) showed evidence
of potential discrimination based on disability (DI).
Tests DI -1, DI -2, DI -5, DI -6, DI -7, DI -10, DI -11, and DI -12 produced evidence of
differential treatment based on disability. In test DI -2, the housing provider told the
Protected Disabled Tester that the no animal policy was strictly enforced by the
owner after the Protected Disabled Tester told the provider that she had a
prescription for her companion animal. Unlike the Controlled Tester, the Protected
Disabled Tester was offered no information about the terms of the rental.
In test DI -5, the housing provider told the Protected Disabled Testers that there were
no pets allowed after the tester disclosed she had a mental disability and a
prescription for a companion animal. In test DI -6 the housing provider offered the
Protected Disabled Tester with a companion animal less favorable leasing terms
(month to month lease vs. six month lease) and was not offered to be shown the unit
unless the tester presented bank statements and paystubs or income tax returns.
These conditions were not required of the Controlled Tester.
In tests DI -10. DI -11 and DI -12, the housing provider flat out refused the Protected
Disabled Tester because of the companion animal. In test DI -10, only the controlled
tester was offered to be shown an apartment undergoing renovations that would be
available within days. In DI -12, after telling the Protected Disabled Tester that the
owner did not want any pets, the housing provider told the Controlled tester that no
children were allowed either as "kids are too noisy." When the Controlled Tester said
she had no children and no animals, the manager provided the rental information
and offered to show the unit.
Community Development Department Page 32
City of Rosemead FY 2015 -2020
2015 — 2020 Analysis of Impediments to Fair Housing Choice
Audit #1
Protected: with companion animal
Control: without companion animal
Finding
Location
Rosemead, 91770 -4334
The PT spoke with a property manager and the CT spoke
with a receptionist.
Evidence of
♦ The PT told the property manager that she was calling about
Discrimination based
the two - bedroom unit for herself and her companion animal.
on Disability
♦ The property manager told PT, "We are not pet friendly ".
♦ The PT told the property manager that she has a prescription
from her doctor.
The property manager asked the PT if she had a service
animal which the PT confirmed that it was.
♦ The property manager asked PT if her service animal wore a
vest all the time which the PT confirmed that it did.
The property manager asked PT if she had documentation
for her service animal which PT confirmed that she does.
♦ Both testers received the same rental information for the
available unit.
Audit #2
Protected: with companion animal
Control: without companion animal
Finding
Location
Rosemead, 91770 -2260
♦ Both testers spoke with the same manager.
The PT told the manager that she was calling about the one -
bedroom unit for herself and her companion animal.
Evidence of
♦ The manager told the PT that they don't allow animals at the
Discrimination based
on Disability
property.
♦ The PT told the manager that she has a prescription for her
companion animal.
A The manager told PT that he is quoting the owner who stated
that they don't allow animals at the property.
s The CT told the manager that she was calling about the one -
bedroom unit for herself.
♦ The manager told the CT that the rent is $999.00 per month,
the security deposit is $999.00, there is a $25.00 credit check
fee and the unit requires a one -year lease.
Community Development Department Page 33
City of Rosemead FY 2015 -2020
2015 — 2020 Analysis of Impediments to Fair No _using Ch ®ice
Audit #5
Protected: with companion animal
Control: without companion animal
Finding
Location
Rosemead, 91770 -4104
O Both testers spoke with the same manager.
♦ The PT told the manager that she was calling about the one -
bedroom unit for her sister and her sister's companion
Evidence of
animal.
Discrimination based
♦ The manager asked the PT if her sister has a dog.
on Disability
♦ The PT told the manager that her sister has a companion dog
prescribed by her psychiatrist for her depression.
♦ The manager told PT, "I'm sorry but we do not allow dogs" at
the property.
0 The PT told the manager that her sister has a prescription for
the companion dog.
♦ The manager told PT that the contract states "No Pets ".
♦ The CT told the manager that she was calling about the one -
bedroom unit for her mother.
♦ Both testers received the same rental information for the
available unit.
Community Development Department Page 34
City of Rosemead FY 2015 -2020
2015 — 2020 Analysis of Impediments to Fair Housing Choice
Audit #6
Protected: with companion animal
Control: without companion animal
Finding
Location
Rosemead, 91770 -1805
♦ Both testers spoke with the same female assistant.
♦ The PT told the female assistant that she was calling about
the two - bedroom unit for herself and her companion animal.
Evidence of
♦ The female assistant told the PT that they don't allow dogs at
Discrimination based
the property.
on Disability
♦ The PT told the female assistant that her companion animal
was prescribed by her doctor.
♦ The female assistant told the PT that she would have to
speak with her boss about her companion animal and then
call her back.
♦ The PT asked the female assistant for the rental information
for the available unit.
♦ The female assistant told the PT that the rent is $1,550.00
per month, the security deposit is $1,950.00, there is no
charge for the credit check fee and the unit requires a month
to month tenancy.
♦ The female assistant told the PT that the available unit can
be seen by appointment but she would need to bring copies
of her bank statements, paycheck stubs or tax returns.
♦ The female assistant contacted the PT and informed her that
she spoke with her boss regarding her companion animal.
♦ The female assistant told the PT that she would need to
come to their office to complete a rental application, submit
her last two paycheck stubs and a letter from her doctor
regarding her companion animal.
The CT told the female assistant that she was calling about
the two - bedroom unit for herself.
♦ The female assistant told the CT that the rent is $1,550.00
per month, the security deposit is $1,950.00, there is no
charge for the credit check fee and the unit requires a 6-
month lease.
♦ The CT asked the female assistant if she could see the unit
tomorrow.
♦ The female assistant told the CT that she could and asked
her for her phone number.
♦ The female assistant told the CT that when she went to the
property, the handyman would let her in to view the available
unit.
Community Development Department Page 35
City of Rosemead FY 2015 -2020
2015 — 2020 Analysis of Impediments to Fair Housing Cholce
Audit #7
Protected: with companion animal
Control: without companion animal
Finding
Location
Rosemead, 91770 -1947
♦ Both testers spoke with the same manager.
♦ The PT told the manager that she was calling about the one -
bedroom unit.
Possible Evidence of
♦ The PT told the manager that she has a very small dog which
Discrimination based
her physician prescribed for her depression.
on Disability
♦ The manager told the PT that he was sorry.
♦ The CT told the manager she was calling about the one -
bedroom unit for herself.
♦ Both testers received the same rental information for the
available unit.
Audit #10
Protected: with companion animal
Control: without companion animal
Finding
Location
Rosemead, 91770 -2522
♦ The PT spoke with the owner and the CT spoke with the
manager.
♦ The PT told the owner that she was calling about the one-
Evidence of
bedroom unit for herself and her companion animal.
Discrimination based
♦ The owner told the PT that he doesn't accept pets at the
on Disability
property.
♦ The PT told the owner that she has a prescription from her
psychiatrist for her companion animal.
♦ The owner told the PT that he doesn't accept pets at his
property.
♦ The CT told the manager that she was calling about the one -
bedroom unit or herself.
♦ The manager told the CT that he was currently remodeling
the unit, so the unit would be available on February 23, 2015.
♦ The manager told the CT that he doesn't allow pets or
smoking at the property.
♦ The manager told the CT that the rent is $1,000.00, the
security deposit is $1,000.00, there is a $30.00 credit check
fee and the unit requires a one -year lease.
♦ The manager asked the CT to confirm that the unit would be
just for her and she confirmed that it would be.
♦ The manager told the CT that he would gladly show her the
unit before he finished remodeling it and would provide her
with a rental application.
Community Development Department Page 36
City of Rosemead FY 2015 -2020
2015 — 2020 Analysis of Impediments to Fair N*71n:g Choice
Audit #11
Protected: with companion animal
Control: without companion animal
Finding
Location
Rosemead, 91770 -3810
♦ Both testers spoke with the same owner.
♦ The PT told the owner that she was calling about the two -
bedroom unit for herself and her companion animal.
Evidence of
♦ The owner told the PT, "no pets ".
Discrimination based
♦ The PT told the owner that she has a prescription for her
on Disability
companion animal.
♦ The owner told the PT that "we don't allow any pets in any of
our units ".
♦ The CT told the owner that she was calling about the two -
bedroom unit for herself.
♦ The owner told the CT that the rent is $1,475.00 per month,
the security deposit is $1,500.00, there is a $20.00 credit
check fee and the unit requires a month to month tenancy.
♦ The owner told the CT that she would need to schedule an
appointment to view the unit.
Community Development Department Page 37
City of Rosemead FY 2015 -2020
[_ 2015 — 2020 Analysis of Impediments to Fair Housing Cho c1 e
Audit #12
Protected: with companion animal
Control: without companion animal
Finding
Location
Rosemead, 91770 -2638
s Both testers spoke with the same manager.
♦ The PT told the manager that she was calling about the two -
bedroom unit for herself and her companion animal.
Evidence of
♦ The manager told the PT that the owner doesn't allow any
Discrimination based
pets at the property.
on Disability
♦ The PT told the manager that she has a prescription from her
psychiatrist for her companion animal.
♦ The manager told the PT that she would have to ask the
owner because the owner told her that they don't want any
pets at the property.
♦ The manager asked the PT for her phone number and told
her that she would call her back after she spoke with the
owner.
♦ The PT received a return phone call from the manager about
her companion animal.
♦ The manager told the PT that she spoke with the owner but
the owner told her that they didn't want any pets at the
property.
♦ The CT told the manager that she was calling about the two -
bedroom unit for herself.
♦ The manager asked the CT how many people would be living
in the unit.
♦ The CT told the manager that the unit would be for her.
The manager asked the CT, "just yourself ?"
♦ The CT told the manager that the unit would be just for her.
♦ The manager told the CT, "if you are alone it is okay, if kids
too noisy ".
♦ The CT asked the manager to clarify what she said.
♦ The manager told the CT, "only for you is good, kids too
noisy ".
The manager told the CT that the rent is $1,245.00 per
month, the security deposit is $1,245.00, there would be a
$25.00 or $35.00 application fee and the unit would require a
one -year lease.
♦ The manager then asked the CT if she had a job, where she
worked, where she lives now, why she was moving and if she
had any pets.
The CT told the manager that she works for Pasadena City
College as a Financial Aid Advisor.
The CT told the manager that she lives in Monrovia and was
looking to move because her lease is up.
♦ The CT told the manager that she doesn't have any pets.
♦ The manager told the CT to drive by the property and then
call her to schedule an appointment to view the unit.
Community Development Department Page 38
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Housing Choice
2. Audits with No Evidence of Discrimination
Of the 12 Disability tests conducted in Rosemead, 4 tests (33.3 %) showed no
evidence of discrimination against the Protected Disabled Tester. Tests DI -3, DI -4
DI -8, DI -9, did not produce evidence of discrimination.
Audit #3
Protected: with companion animal
Control: without companion animal
Finding
Location
Rosemead, 91770 -1474
Finding
♦ The PT spoke with the manager and the CT spoke with the
Rosemead, 91770 -2438
owner's assistant.
No Evidence of
♦ Both testers received the same rental information for the
Discrimination
available unit.
Audit #4
Protected: with companion animal
Finding
Location
Control: without companion animal
Finding
Location
Rosemead, 91770 -2438
Both testers spoke with the same property owner.
No Evidence of
♦ Both testers received the same rental information for the
Discrimination
available unit.
Audit #8
Protected: with companion animal
Control: without companion animal
Finding
Location
Rosemead, 91770 -4409
♦ Both testers spoke with the same owner.
No Evidence of
♦ Both testers received the same rental information for the
Discrimination
available unit.
Audit #9
Protected: with companion animal
Control: without companion animal
Finding
Location
Rosemead, 91770 -2036
♦ The PT spoke with the property manager and the CT spoke
No Evidence of
with the assistant property manager.
Discrimination
♦ Both testers received the same rental information for the
available unit.
Community Development Department Page 39
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Housing Choice
Audit of Possible Discrimination based on Familial Status
The HRC conducted 13 phone tests to measure the existence of discrimination on the
basis of familial status.
1. Audits Finding Evidence of Discrimination
Of the 13 familial status tests conducted in Rosemead, 5 tests (38 %) showed
evidence of potential discrimination based on familial status (FS). In FS -1, the
Protected Tester with a minor child was only offered a ground floor unit with no
mention of a one year lease. In FS -4, the Protected Tester was quoted a higher
security deposit and told about only one available unit which was located in the noisy
front. In FS -7, the Controlled Tester was quoted a lower rent and lower security
deposit. In FS -12, the PT was told there were 12 applicants ahead of her for the
unit and about a $25 security deposit for each adult. The Controlled tester was then
told the apartment had been rented. There is possible discrimination, however,
because the vacancy caller (and possibly the adults who were given the apartment
to rent) where quoted a lower security deposit.
Audit #2
Protected: With child Control: Only Adults
Finding
Location
Rosemead, 91770 -3954
♦ PT informed the agent she was interested in a 2 bedroom for
her, her husband and 3 year old son.
♦ The agent offered PT a 2 bedroom on the ground floor 860
ft 2 . The unit comes with 1 parking space.
Evidence of
♦ The unit would rent for $1,520 with a $500 deposit. The credit
Discrimination
check would be $44 per adult.
♦ PT asked if she needed to make an appointment. The agent
told PT to call anytime M -F between 8:30 am -5:30 pm.
♦ CT informed the agent she was interested in a 2 bedroom for
her, her husband and 24 year old son.
♦ The agent asked CT if she was interested in an upstairs or
downstairs unit. CT asked if the rent differ, and the agent said
it would be the same $1,520. The deposit would be $500. It
would be a one year lease. Every adult would pay a $44
credit check fee.
♦ CT asked about parking, and was told 2 car carport.
♦ The agent offered to show the unit the next day to CT.
Community Development Department Page 40
City of Rosemead FY 2015 -2020
T 2015 - 2020 Analysis of Impediments to Fair Housing C Imceh
Audit #4
Protected: With child Control: Only Adults
Finding
Location
Rosemead, 91770 -2164
♦ PT informed the agent she was interested in a 3 bedroom for
her, her husband and 4 year old son.
♦ The agent offered PT a unit located toward the front. The
agent stated it could get kind of noisy.
Evidence of
♦ The unit rented for $1,800 on a 12 month lease. The deposit
Discrimination
was 2 month's rent plus a $300 cleaning deposit. The unit
(credit check)
comes with 3 parking space.
♦ The credit check would be $30 for PT or $40 for both PT and
herhusband.
♦ The agent told PT the unit could be viewed the following day
at 4:30 pm.
♦ CT asked for a 3 bedroom unit. CT informed the agent that
the unit would be for her, her husband and her mother.
♦ CT was told the unit rented for $1,800 and the deposit
depended on the credit. CT told the agent that her husband
had over 700 FICO score. The agent said it would be a
$2,000 deposit. The credit check would be $20. The unit was
on a one year lease. The agent told CT the unit came with 2
parking spaces.
♦ The agent offered to show the unit that following Saturday
between 10:00 am -11:00 am.
Audit #5
Protected: With child Control: Only Adults
Finding
Location
Rosemead, 91770 -4038
PT told the agent she was interested in the 3- bedroom house
for her, her husband and 5 year old son.
♦ PT asked the agent for the rental information and was told it
would be $2,195. The deposit would be $2,500. The credit
Possible Evidence of
check would be $18 each. The minimum lease term would be
Discrimination
12 months.
(credit check)
♦ The agent offered to show the unit to PT.
♦ CT told the agent she was interested in the 3- bedroom house
for her, her husband and mother.
CT asked the agent for the rental information and was told it
would be $2,195. The deposit would be $2,500. The
minimum lease term would be 12 months.
♦ The agent said all appointments need to be set up.
♦ The agent told CT that if she had her credit report and score
already she should provide a copy and no fee would be
charged. They can also use their services for an $18 fee.
Community Development Department Page 41
City of Rosemead FY 2015 -2020
2015 - 2020 Analy_s "_s of Impediments to Fair Housing Choice
Audit #7
Protected: With child Control: Only Adults
Finding
Location
Rosemead, 91770 -1947
♦ PT told the agent she was interested in a 1- bedroom for her,
her husband and 4 year old son. The agent confirmed the
number of occupants and told PT that they had an application
Possible Evidence of
already and would have to call her in case the applicant
Evidence of
changed their mind.
Discrimination
♦ PT provided the agent her contact number.
i The agent said the unit rented for $1,150 and the deposit was
the same amount. The lease would be for 1 year.
♦ The agent told PT they would call her in case the other
applicant was not interested.
♦ CT told the agent she was interested in a 1- bedroom for her,
her husband and mother.
♦ The agent told CT they had a 1- bedroom for $1,100 and
$1,100 deposit.
♦ The agent told CT they had an application in already. The
agent told CT she would call if the applicant didn't take the
unit.
♦ The agent told the caller during the vacancy check that the
rent was $980.
Audit #12
Protected: With child Control: Only Adults
Finding
Location
Rosemead, 91770 -1907
♦ PT told the agent she was interested in the 2- bedroom unit.
The agent told PT she was the 13t caller. There were already
12 people before her and she was taking applications.
Possible Evidence of
♦ The agent told PT the rent would be $1225 and a $1200
Discrimination
deposit. The lease would be for 1 year.
♦ PT told the agent the unit would be for her, her husband and
4 year old son.
♦ The agent asked for a $25 credit check fee for each adult.
♦ PT asked if she can view the unit the next day. The agent
offered to show the unit from 2:15 pm -2:30 pm.
♦ CT called and asked about the 2- bedroom unit. The agent
told CT the unit had been rented over the weekend.
♦ The agent told the caller during the vacancy check that the
rent was $1,225 and the deposit $1,000.
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City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Housing Choice
2. Audits With No Evidence of Discrimination
Of the 13 tests conducted to measure the existence of discrimination on the basis of
familial status, 8 (62 %) presented no evidence of discrimination.
Audit #1
Protected: With child Control: Only Adults
Finding
Location
Rosemead, 91770 -1972
♦ PT informed the agent that the unit would be for her and her
2 year old son.
♦ The agent offered PT a studio and a 1 bedroom for rent. The
studio rented for $925 and the 1 bedroom for $1050. Both
No Evidence of
units would have a 1 year lease. The deposit would be $700.
Discrimination
At the time of the appointment the PT can bring the $700
Discrimination
Di scrimination
deposit, copy of SS card, ID and 3 months of paystubs and a
good credit rating. The credit check fee is waived. The owner
would pay water and trash.
♦ CT informed the agent that the unit would be for her and her
mother.
♦ The agent offered CT a 1 bedroom unit. The unit rented for
$1,050. The deposit would be $700. There would be a one
year lease. The owner would pay water and trash.
Audit #3
Protected: With child Control: Only Adults
Finding
Location
Rosemead, 91770 -2164
♦ PT told the agent she was looking for a 2 bedroom for her,
her husband and 3 year old son.
♦ The agent offered PT a 2 bedroom house. The house rented
for $1,400. There would be a $1,000 cleaning deposit.
The agent offered to show PT the house the same day.
Evidence of
♦ The agent offered CT a 2 bedroom unit renting for $1,400.
Discrimination
Di scrimination
The deposit would be $1,000.
♦ CT asked about the credit check for her, her husband and
mother.
♦ CT asked to view the unit that same day. The agent asked
CT to drive by first and if she liked it the agent would show
CT the unit.
Community Development Department Page 43
City of Rosemead FY 2015 -2020
[� 2015 - 202®Anaiysi of impediments to Farr Housing Choice
Audit #6
Protected: With child Control: Only Adults
Finding
Location
Rosemead, 91770 -4409
♦ PT stated she was interested in the 3- bedroom house and
wanted to know if it was still available.
♦ PT was told the unit rented for $1800 and the deposit was
No Evidence of
the same amount. The unit rents on a month to month. PT
Discrimination
asked about the credit check but the agent did not know the
Discrimination
amount.
♦ PT disclosed that she had a 4 year old son and asked about
the backyard. The agent said the area had cement and was
large enough for 4 cars.
♦ CT told the agent she was interested in the 3- bedroom unit
for her, her husband and mother. The agent told CT that her
husband had some people in mind but was not sure if it had
rented out.
CT asked for the rental information. CT was told $1,800 for
the rent and the same for a deposit. CT asked about the
credit check and was told she did not know the amount.
Audit #8
Protected: With child Control: Only Adults
Finding
Location
Rosemead, CA 91770 -1881
♦ PT told the agent she was interested in a 2- bedroom for her,
her husband and 3 year old son.
♦ The agent told PT that unit rented for $1,550. The deposit
would be $1,950.
No Evidence of
♦ PT asked the agent about viewing the unit. The agent told
Discrimination
PT, Monday- Friday from 9:00 am - 5:00 pm with an
appointment.
9 CT told the agent she was interested in a 2- bedroom for her,
her husband and mother.
♦ The agent told CT that unit rented for $1,550. The deposit
would be $1,950.
♦ CT asked for the lease terms and was told 6 month lease
term.
♦ CT asked the agent to view the unit and was told to make an
appointment to view the unit.
Community Development Department Page 44
City of Rosemead FY 2015 -2020
�� 2015 — 2020 Analysis of Impediments to Fair Housing Choice
Audit #9
Protected: With child Control: Only Adults
Finding
Location
Rosemead, CA 91770 -2067
♦ PT told the agent she was interested in a 2- bedroom for her,
her husband and 3 year old son.
♦ The agent told PT the unit would be ready by 2/21/15.
No Evidence of
♦ The rent is $1250 with a $1200 deposit on a month to month
Discrimination
lease. The credit check fee is $30.
♦ CT told the agent she was interesting unit the 2 bedroom and
wanted rental information. CT was told the rent would be
$1250 with a $1200 deposit and a $30 credit check fee. The
lease would be for 12 months.
♦ CT told the agent the unit would be for her, her husband and
mother.
♦ The agent told CT the unit was not ready because they were
still fixing it up.
Audit #10
Protected: With child Control: Only Adults
Finding
Location
Rosemead, CA 91770 -2522
♦ PT told the agent she was interested in a 1- bedroom for her
and 4 year old son.
♦ The agent told PT the rent and deposit would be $1000 with
No Evidence of
a $30 credit check fee. The lease terms are month to month.
Discrimination
♦ PT asked if she can view the unit on that same day. The
agent agreed to show the unit, but asked that PT call 1 /2 hour
before going to the property.
♦ CT told the agent she was interested in a 1- bedroom for her
and her mother.
♦ The agent told CT the rent and deposit would be $1000 with
a $30 credit check fee. The lease terms are month to month.
♦ CT asked if the unit would be ready March 1 st. The agent said
could be available the following week.
Community Development Department Page 45
City of Rosemead FY 2015 -2020
2015 — 2020 Analysis of Impediments to Fair Housing Choice
Audit #11
Protected: With child Control: Only Adults
Finding
Location
Rosemead, CA 91770 -3810
A PT told the agent she was interested in a 2- bedroom for her,
her husband and 4 year old son.
No Evidence of
i The agent told PT the rent would be $1,475 with a $1,500
No Evidence of
deposit. The credit check would be $20 or $30, the agent was
Discrimination
unsure. The lease term is month to month.
♦ PT asked the agent if she would show PT the unit. The agent
told PT that her husband was there at the moment. PT told
the agent she would call when she was ready to stop by.
♦ The agent asked PT her possible move in date. PT replied
by the middle of March. The agent told PT there were several
applicants who would want to move in on March 1s'. PT told
the agent she would like to view the unit first.
♦ CT told the agent she was interested in the 2- bedroom for
her, her husband and mother.
♦ The agent told CT she would be reviewing several applicants
before making a decision.
Audit #13
Protected: With child Control: Only Adults
Finding
Location
Rosemead, 91770 -2638
♦ PT told the agent she was interested in a 2- bedroom for her,
her husband and 4 year old son.
No Evidence of
♦ PT asked for the rental information. The agent replied by
Discrimination
saying the information was in the ad and asked PT, "Didn't
you read the ad ?"
O The agent told PT the rent and deposit would be $1,245.
♦ The agent asked PT if she had a copy of her credit report. PT
told the agent her husband had his credit report. The woman
replied by saying "You don't have a job ?" PT told the agent
she did not but her husband works. The agent asked for the
husband's place of employment. PT disclosed her husband's
workplace. The agent then asked for her husband's position.
PT answered he was an X -Ray Technician.
♦ CT told the agent that the unit would be for her, her husband
and her mother.
♦ The agent asked CT if she works. PT told the agent that her
husband works.
♦ The agent told CT that the rent and deposit would be $1,245.
♦ The agent told CT that she would have to bring her own credit
check.
Community Development Department Page 46
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Nousiog Choice,
D. Conclusion
Of the 20 phone tests conducted, 14 produced evidence of differential treatment based
on disability. Overall 52% of the tests showed some evidence of potential discrimination.
These results show that discrimination is occurring in the pre - application rental process
in Rosemead. It is noteworthy that the tests for differential treatment based on disability
produced greater evidence of discrimination than the tests for familial status
discrimination (67% of tests vs. 33% of tests). This ratio is consistent with HRC's client
complaint statistics.
Community Development Department Page 47
City of Rosemead FY 2015 -2020
(�- 2015 — 2020 Analysis of Impediments to Fair Bolusing Choice
O V. ANALYSIS OF ROSEMEAD RESIDENT SURVEYS
This chapter analyzes data gathered from community members through surveys
conducted by the HRC. The goal of the surveys was to find out if current residents of
the City of Rosemead experienced discrimination when looking for property to rent or
purchase and their familiarity or knowledge of fair housing laws. 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 31 individuals who are currently residents of the
City of Rosemead. The respondents were randomly chosen from the Yahoo! Yellow
Pages. Eighteen (18) were taken via telephone through random selection from the
Yahoo! Yellow Pages. More than 18 residents were called but only 18 provided
complete responses appropriate for reporting purposes. Thirteen (13) residents
completed surveys in public area venues around the City of Rosemead. Nine (9)
residents were male, twenty (20) were female and two (2) did not provide a gender.
All 31 respondents were asked to give their age. Overall, the highest number of
respondents were 56 and over (55 %). Notably, three (3) respondents were 80 and
over.
Table 5.1
Ages of Respondents
Age Male I Female I No Gender given I Percent
17 -25
1
0
26 -35
1
4
36 -45
0
3
46 -55
1
2
56 -65
4
7
66+
2
4
Total
9
20
�a
3.0%
19.5%
13.0%
10.0%
35.5%
19.0%
100.00%
The 31 respondents were also asked to give their annual income. More respondents
had annual incomes of less than $10,000 (22.5 %) than any other income bracket.
Community Development Department Page 48
City of Rosemead FY 2015 -2020
2015 - 2020 Analnis of Impediments to Fair No js ng Choice,
Age
Less than $10,000
$10,001- $20,000
$20,001 - $30,000
$30,001 - $40,000
$40,001 - $50,000
$50,001 - $60,000
More than $60,000
Preferred not to state
income.
Total
9
20
dents
No Gender given
1
1
0
Percent
22.5%
16.0%
16.0%
13.0%
10.0%
6.5%
3.0%
13.0%
100%
Of the 31 respondents, only seven (7) had minor children in the household and one
person was homeless.
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 -five percent (65 %) of the respondents
said they had `never' experienced problems when finding housing in Rosemead and
twelve percent (13 %) indicated that they `always' experienced problems when
looking for housing in Rosemead.
Table 5.3
Problems finding housing in Rosemead
Table 5.2
Income of Respor
Male
Female
4
3
2
3
0
5
2
2
0
2
1
0
0
1
0
4
9
20
dents
No Gender given
1
1
0
Percent
22.5%
16.0%
16.0%
13.0%
10.0%
6.5%
3.0%
13.0%
100%
Of the 31 respondents, only seven (7) had minor children in the household and one
person was homeless.
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 -five percent (65 %) of the respondents
said they had `never' experienced problems when finding housing in Rosemead and
twelve percent (13 %) indicated that they `always' experienced problems when
looking for housing in Rosemead.
Table 5.3
Problems finding housing in Rosemead
Respondents were also asked to state the type of housing in which they lived.
Community Development Department Page 49
City of Rosemead FY 2015 -2020
Frequency
Percent
Never
20
65%
Sometimes
7
22%
Always
4
13%
Total
31
100%
Respondents were also asked to state the type of housing in which they lived.
Community Development Department Page 49
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Nolusing Ch coi e
Table 5.6
Type of housing
Frequency I Percent
Rental Unit (apartment, house, duplex, etc.) 18 58.0%
Mobile Home 1 3.0%
Single - Family Home (purchased) 11 36.0%
Homeless 1 3.0
Total 31 100%
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 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 asked if they had ever experienced language or
communication difficulties when looking for housing in Rosemead. The majority of
respondents who answered this question (90 %) stated they had not experienced
language or communication difficulties when looking for housing in Rosemead. The
remaining 10% said they had difficulty communicating with an Asian housing
provider.
Table 5.7
Language or communication difficulties when looking for housing
Respondents were also asked how familiar they were with housing laws that provide
protection against housing discrimination. Over a third of the respondents indicated
that they were "not at all" aware of the fair housing laws. A majority (45 %) of
respondents stated they were "a little bit" familiar with the fair housing laws. Thus
81% of Rosemead residents have minimal, if any, knowledge of the fair housing
laws. These results indicate that the City of Rosemead needs to increase services
that would provide education and awareness of fair housing laws.
Community Development Department Page 50
City of Rosemead FY 2015 -2020
Frequency
Percent
Yes
3
10%
No
28
90%
Total
31
100%
Respondents were also asked how familiar they were with housing laws that provide
protection against housing discrimination. Over a third of the respondents indicated
that they were "not at all" aware of the fair housing laws. A majority (45 %) of
respondents stated they were "a little bit" familiar with the fair housing laws. Thus
81% of Rosemead residents have minimal, if any, knowledge of the fair housing
laws. These results indicate that the City of Rosemead needs to increase services
that would provide education and awareness of fair housing laws.
Community Development Department Page 50
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Housing Choice
Table 5.8
Familiarity with housing laws that protect against housing discrimination
Frequency I Percent
Not at all
11
36%
A little bit
14
45%
A lot
5
16%
Did not answer
1
3%
Total
31
100%
a. Rental Housing Discrimination - As indicated above. Eighteen (18) respondents
stated they lived in rental housing. Each respondent was asked a series of ten
questions to uncover whether he or she had ever experienced any different
treatment because they belonged to a group protected by the fair housing laws.
Of the 18 respondents who were asked if they had ever felt discriminated against
when renting property in Rosemead, ten (10) persons indicated that they had felt
discriminated against. Thus, fifty -five (55 %) of these renters experienced
discrimination at least once in their pursuit to obtain or retain housing. A few
people indicated multiple forms of discrimination, in all, there were four (4)
instances of discrimination due to having minor children, four (4) due to race, two
(2) due to disability, two (2) due to age of which, one was 29 years old and the
other was 58. One (1) instance of discrimination was reported on the basis of
gender and one (1) on the basis of sexual orientation.
b. Home Purchase /Mortgage Lending Discrimination - Of the eleven (11)
homeowners, none reported any known instances of discrimination against them
in the purchase of their home or mortgage. It should be noted, however, that at
least half of the homeowners were born and raised in Rosemead and owned their
homes for at least 30 years or had inherited it.
C. Conclusion
Overall, results from the survey reveal one major finding. When asked about how
familiar respondents were with fair housing laws that provide protection against housing
discrimination, a third of the respondents (36 %) indicated that they were "not at all"
aware of the fair housing laws. In addition to this, 45% of respondents stated they were
"a little bit" familiar with the fair housing laws. These results indicate that the City of
Rosemead, through its partnership with the HRC, needs to increase the level of fair
housing outreach to the Rosemead community.
Community Development Department Page 51
City of Rosemead FY 2015 -2020
2015 — 2020 Analysis of Impediments to Fair Nousing Choice,
S VI. REVIEW OF GOVERNMENT POLICIES
In the previous Al prepared in 2010, HRC reviewed provisions of the RMC, specifically
Title 15 (Buildings and Construction) and Title 17 (Zoning), for compliance with state
and federal fair housing laws. HRC 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 was divided into three parts. The first presented RMC sections that are in
direct conflict with state or federal fair housing laws. HRC recommended that the City
make it a priority to change these sections to bring the RMC into compliance with fair
housing law. The second part analyzed RMC sections that should be changed to
achieve the goal of affirmatively furthering fair housing. The third part addresses other
relevant considerations. To the extent that these troubling provisions in local law still
exist, the City of Rosemead should undergo immediate efforts to address the issues
identified in the Al.
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 R -1 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
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City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Housing Choice
housekeeping unit that could be termed an alternative family and as such could not
be excluded from the zone or made to apply for a conditional use permit.
More recently, in November of 2014, the U.S. Supreme Court rejected the City of
Newport Beach's request for a hearing on its group home law. Newport Beach had
submitted a petition to the Supreme Court in August of 2014, asking the justices to
reverse a 9th Circuit Court of Appeals ruling that a municipal ordinance governing
group homes could be challenged for discriminatory intent against persons with
disabilities in violation of the fair housing act. The ordinance effectively prohibited
new group homes housing seven or more non - related residents from operating in
most residential areas.
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, definitiomthan the
current definition.
B. Other Relevant Considerations
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.
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.
Community Development Department Page 53
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Housing Choice,
O VIII. HOME MORTGAGE DISCLOSURE ACT DATA
This section examines the impediments to fair housing choice in the City of Rosemead
as they relate to credit markets, including mortgages. The study focuses on credit
treatment by ethnicity because Rosemead is a changing market in that respect. The
comparison charts also show the differences between the recent pre -real estate market
crash and post -real estate market crash. One of the most noticeable changes in
Rosemead in this time period is the increase in ethnic minorities in the housing market.
In fact, many of the census tracts in Rosemead are now more than 90% minority. The
largest of these groups are persons of Asian descent and, in particular, are Chinese or
Chinese American.
The following section was constructed using 2006, 2007, 2008, 2011, 2012 and 2013
Home Mortgage Disclosure Act (HMDA) data. The 2013 data is the most recent HMDA
data available. The section uses HMDA data from the following census tracts: 4322.01,
4322.02, 4329.01, 4329.02, 4336.01, 4336.02, 4813, 4823.03, 4823.04, 4824.01, and
4824.02. These are the primary census tracts for the City of Rosemead.
It is important to note that the review in this section is limited to actions in which the
race/ ethnicity of the applicant is provided. Much of the HMDA data reviewed contains
actions in which the race, ethnicity, gender and other human factors are not provided.
The reasons for not providing the information are not given. It could be that the applicant
refused to provide the information. It could also be that the applicant is a corporation or
some other business entity and the information is not applicable. For that reason the
totals listed in the written portions may not match the totals listed in the graphs.
A. Access to Housing Credit in Rosemead - General Background
1. The legal context of barriers to credit markets
Economic security and advancement are frequently based on home ownership, the
most basic means of obtaining wealth in the United States and passing that
accumulated wealth on to one's heirs. Home ownership provides a great deal of
financial security and often becomes the basis for credit to increase wealth within a
family unit. The recent foreclosure crisis contributed significantly to the greater
wealth gap between Whites and African Americans, and Whites and Latinos.
Acquiring a home also 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 borrowing from family members can be utilized. Often those other channels
are unavailable and the result is wealth inaccessibility. For those households without
this option, homeownership and the economic security this. can bring become
impossible.
Community Development Department Page 54
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Housing Choice
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 (CRA) mandates
that institutions that control economic resources cannot legally discriminate on the
basis of race, gender, age, or disability. The 1968 Fair Housing Act, as amended
in 1988, 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:
Activities constituting discrimination.
It shall be unlawful for any creditor to discriminate against any applicant,
with respect to any aspect of a credit transaction -
(1) on the basis of race, color, religion, national origin, sex or marital
status, or age (provided the applicant has the capacity to contract);
(2) because all or part of the applicant's income derives from any public
assistance program; or
(3). because the applicant has in good faith exercised any right under this
chapter (15 U.S.C. sec.1591).
Federal responsibility for ensuring that financial and housing markets operate
equitably was strengthened in the 1970's. The 1975 HMDA required banks and other
depository institutions to provide annual data on their mortgage Fending 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 the subject area. It also
requires that banks not define their market areas in a manner that discriminates
against minorities. In 1989, HMDA was amended, directing lenders to submit more
detailed evidence (on applications, not just loans), and requiring more types of
lenders (including mortgage companies) to report under HMDA. Required reporting
information now includes loan applications (actions) and the result of the application
- approved, purchased, denied, withdrawn by applicant, incomplete, approved but
not accepted by the reporting institution, etc. Each action also requires the reporting
institution to disclose the race /ethnicity of the applicant and any co- applicant, sex,
income, type of loan, occupancy (homeowner occupied, for example) and the
census tract where the subject property is located.
In sum, federal law makes it illegal for lenders to practice either discrimination or
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 other similarly situated groups or when minorities can make a
given transaction only at a higher cost or worse terms than other similarly situated
Community Development Department Page 55
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Housing Choice
groups. 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. Discrimination disadvantages
borrowers or applicants independent of their 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 pursue elimination of 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 not established a 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.
3. Evidence of potential 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. Several
Community Development Department Page 56
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Housing Choice,
cities have been targeted for studies. that indicate a strong possibility that
discrimination in credit markets exists and several cities have brought suit against
large mortgage lenders to resolve some of the disparities created by the
discriminatory acts.
In Boston, researchers received complete access to lenders' data files on loan
applicants, a circumstance that does not exist in every market. In the Boston study,
strong evidence of discriminatory conduct was uncovered. 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 versus
inner -city, professional versus working class areas, largely white versus 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
The evidence for Rosemead's credit markets
It is important to look into the problem of discrimination because of the tremendous
ethnic diversity of the Los Angeles region. 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 and will also look at
the lending practices of the two largest market shareholders of home purchase
Community Development Department Page 57
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Nousingchoice,
loans. 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 adequately 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 and 2013
HMDA data for the City of Rosemead. 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
Rosemead is a city in demographic transition. That transition is apparent when
comparing the census and HMDA statistics from the 2008 report to the last year for
which HMDA data is available, 2013. The primary lenders are completely different
in 2013 as compared to the ones in 2008. Many of the mortgage lenders that were
most active in the market in 2008 no longer exist. Others, like Bank of America,
have a much smaller market share in 2013 than in 2008.
The housing market was also different in 2013 than it was in 2008. The mortgage
lending landscape changed dramatically with the collapse of the subprime loan
market in 2008. Countrywide, Washington Mutual, and notable companies that were
once high profile lenders in the City of Rosemead no longer exist. Those companies
have been replaced by East West Bank, Cathay Bank, and T.J. Financial among
others.
The supply side- The tables below provides summary data from 2006 -2008. The
totals in the graphs refer alternately to totals of responses given and (usually in the
text) to total actions that occurred. 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 20% 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 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.
Community Development Department Page 58
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Nousing Co c
For 2006 -2008, five lending institutions had a dominant presence in Rosemead:
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, an 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.
Most Active Residential- Credit Lenders in Rosemead, 2006 -2008
(`nmmarr_ial Ranks
"Totals refer to total number of actions in the marKet, ana will often exceea the sample size.
Thrifts (Savinns and 1_nanc)
Lender ID #
2006 -2008 Loans
% of 2006 -2008 market
Bank of America
0000013044
399
8.7
Wells Fargo Bank, NA
0000001741
236
5.2
JPMorgan Chase Bank
0000000008
159
3.5
Citibank, NA
0000001461
84
1.8
Countrywide Bank, NA
0000024141
55
1.2 .
Total, all commercial Banks
1306
28.6
"Totals refer to total number of actions in the marKet, ana will often exceea the sample size.
Thrifts (Savinns and 1_nanc)
Community. Development Department Page 59
City of Rosemead FY 2015 -2020
2006 -2008 Loans
% of 2006 -2008 market
Washington Mutual Bank
FLen
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
Community. Development Department Page 59
City of Rosemead FY 2015 -2020
2015 - Y020 Analysis of Impediments to Fair Housing Choice
Credit Unions
Mortoage Companies
Lender ID #
2006 -2008 Loans
% of 2006 -2008 market
Wescom Credit Union
0000066703
11
0.2
E1 Financial Credit Union
0000086059
7
0.2
USC Credit Union
0000068459
6
0.1
Pentagon Federal Credit Union
0000000227
4
0.1
California Credit Union
0000060784
4
0.1
All Credit Unions Combined
65
1.4
Mortoage Companies
Total for 2006 -2008 4574 100
Note: Only the top lenders for each category are shown
Most Active Residential- Credit Lenders in Rosemead, 2013
In 2006 -2008, the five most popular commercial banks and mortgage companies
controlled 77.8% of the credit market activity in the Rosemead area. By 2013, that
market share was not only owned primarily by institutions that were not in the market
in 2008, the market share for commercial banks and mortgage companies had
dropped to 63.8 %.
Community Development Department Page 60
City of Rosemead FY 2015 -2020
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
Total, Mortgage Companies
2152
49.2
Total for 2006 -2008 4574 100
Note: Only the top lenders for each category are shown
Most Active Residential- Credit Lenders in Rosemead, 2013
In 2006 -2008, the five most popular commercial banks and mortgage companies
controlled 77.8% of the credit market activity in the Rosemead area. By 2013, that
market share was not only owned primarily by institutions that were not in the market
in 2008, the market share for commercial banks and mortgage companies had
dropped to 63.8 %.
Community Development Department Page 60
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Nous! Choice,
Commercial Banks (Home Purchase)
Mortgage Companies
Lender ID #
2013 Loans
% of 2013 market
East West Bank
0000197478
38
13.7%
Wells Fargo Bank, NA
0000001741
34
12.3 %
Flagstar Bank
0000146672
22
7.9%
Citibank, NA
0000001461
21
7.6%
Cathay Bank, NA
0000595869
11
4.0%
Total, all commercial Banks
126
45.5%
Mortgage Companies
Note: Only the top lenders for each category are shown
The demand side - Including all loan types, of all applicants for home purchase loans
and refinance loans in Rosemead in 2013, 75.5% were Asian. This compares to
55% in 2008. For Hispanics, the percentages of market demand was 15.5% in 2013,
compared to 34% in 2008. Whites consisted of 7.1 % of the market demand in 2013,
compared to 11 % in 2008. The remaining groups, primarily African American and
Native American, consisted of less than 3% of the market demand.
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 L.A. County applicants, 553,424 identified their ethnicity. Of this
total, some 0.3% were American Indian, 14% were Asian, 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 large proportions of whites and Hispanics with Asian Americans having
the largest population.
Community Development Department Page 61
City of Rosemead FY 2015 72020
Lender ID #
2013 Loans
% of 2013 market
CitiMortgage Inc.
13- 3222578
17
6.1%
T.J. Financial
95- 4248183
15
5.4%
PMAC Lending
95- 4539048
9
3.2%
Parkside Lending
37- 1493496
6
2.1%
United Shore Financial
38- 2750395
4
1.5%
Total, Mortgage Companies
51,
18.3%
Total for 2013
276
63.8%
Note: Only the top lenders for each category are shown
The demand side - Including all loan types, of all applicants for home purchase loans
and refinance loans in Rosemead in 2013, 75.5% were Asian. This compares to
55% in 2008. For Hispanics, the percentages of market demand was 15.5% in 2013,
compared to 34% in 2008. Whites consisted of 7.1 % of the market demand in 2013,
compared to 11 % in 2008. The remaining groups, primarily African American and
Native American, consisted of less than 3% of the market demand.
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 L.A. County applicants, 553,424 identified their ethnicity. Of this
total, some 0.3% were American Indian, 14% were Asian, 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 large proportions of whites and Hispanics with Asian Americans having
the largest population.
Community Development Department Page 61
City of Rosemead FY 2015 72020
2015 - 2020 Analysis of Impediments to Fair Holusing Cho ciho e
Market Demand in Rosemead by Ethnicity 2013
Race /Ethnicity
Home Purchase
Refinance
Total Actions
Asian
226
737
969"
Hispanic
6
148
199*
White
9
76
91 *
Hawaiian /Pacific Islander
2
12
14
Native American
5
6
11
African American
3
1
4
Totals
251
980
1287
*includes home equity loans
The above table divides actions into home purchases and refinancing, two of the
three categories of loan purpose. The third category, home improvement, was not
used so the Report could demonstrate the stark contract between groups applying
for home purchase loans and refinancing. Most of the loan applications in the City
of Rosemead in 2013 were for the purpose of refinance. The striking element of this
table is in the left column where it shows the number of home purchase applications
by race/ ethnicity. For Asians, 30.7% of the applications listed in the Table above
were for home purchases. For all other races and ethnicities the percentage was
much lower. Only 4% of Hispanics who submitted applications for mortgages in
Rosemead were attempting a home purchase. For whites, the ratio was 11.8 %;
Hawaiian/ Pacific Islanders, 16.7 %; Native Americans, 45.5 %; and African
Americans, 75 %. The latter three groups, however, were not a significant portion of
the market, combined making up only 2.2% of the total residential credit market for
Rosemead.
Lender Action in Rosemead by Ethnicity 2013
Application Application Total Applications
Accepted or Rejected,
Purchased By Withdrawn or
Lender Not Accepted
Race/ Ethnicity By Lender
Asian
Hispanic
White
Hawaiian /Pacific Islander
Native American
African American
Totals
Community Development Department
City of Rosemead
620 1 343 1 963
82 72 154
68 17 85
5 9 14
7 1 4 1 11
3 1 1 1 4
785 1 446 1 1231
Page 62
FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Nolusing Choice
The above table shows lender actions taken in Rosemead in 2013 based on
ethnicity. Lender actions taken on the applications vary between racial and ethnic
lines. In this case, whites had the highest percentage approval rate at 80.0 %.
African Americans were second with a 75% approval rate. Asians were third with a
64.4% approval rate, followed by Native Americans (63.6 %), Hispanics (53.2 %), and
Hawaiian /Pacific Islanders (35.7 %).
East West Bank v. Wells Fargo Bank
A measure of the two largest market shareholders for home purchase loans in 2013
reveals some unusual comparisons. First, East West Bank, the largest market share
holder in 2013, received only one refinance application which it approved. Wells
Fargo received 138 refinance applications, of which it approved 93.
The largest mortgage lender in home purchase loans in' Rosemead in 2013 was East
West Bank. A cursory look at activity conducted by East West Bank revealed that,
East West Bank processed 1900 mortgage loan applications countywide for home
purchases. Reviewing the applications by race and ethnicity, 1582 actions involved
Asian applicants (83.3 %). The remaining 318 actions were divided: 255 involving
Whites (13.4 %), 26 involving Latinos (1.3 %), 23 Alaskan/ Native American (1.2 %),
12 Hawaiian/ Pacific Islander (0.6 %), 2 African American (0.1 %).
The countywide actions involving. loan denials or approvals where the application
was approved but East West Bank refused to accept were reviewed by Race and
Ethnicity. For Asian applicants, 346 applications of all Asian applicants were denied
or refused (21.9 %). For White applicants there were 100 refusals and denials
(39.2 %). Thirteen of the 26 Latino applicants were rejected by East West Bank
(50 %). One of 23 Native American/ Alaskan Native applicants was refused by East
West (4.3 %).
East West Bank Loan Activity Count ywide 2013
Race/ Ethnicity
Applications
Refusal /Denial
Denials/ Refusals as % of Actions
Asian
1582
346
21.9%
White
255
100
39.2%
Hispanic
26
13
50.0%
Native American/ Alaskan
23
1
4.3%
African American
2
0
0.0%
Hawaiian/ Pacific Islander
2
1
50.0%
Total
1900
472
24.8%
Community Development Department Page 63
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Nousing choice
Wells Fargo Rank Lean Activity Countvwide 2013
Race/ Ethnicity
Applications
Refusal /Denial
Denials /Refusals as %of Actions
Asian
10,190
2,448 _
24.0%
White
28,314
7,516
26.5%
Hispanic
13,290
4,348
32.7%
Native American/ Alaskan
840
348
41.4%
African American
2,622
1,082
41.3%
Hawaiian/ Pacific Islander
644
254
39.4%
Total
64,537
15,996
24.8%
Countywide, Wells Fargo received 64,537 home loan applications. Whites
submitted 28,314 of those applications which was 43.9% of the countywide total for
Wells Fargo. - Hispanics submitted 13,290 applications which was 20.6% of
applications countywide. Asian Americans submitted 10,190 for 15.8% of the
countywide market. African Americans were 4.1% of the market with 2,622
applications. Native Americans and Native Hawaiians /Pacific Islanders were 2.3%
of the market for Wells Fargo with 1,484.
Hnmp Purchase Loan Activity For all Lenders_ City of Rosemead. 2013
Race/ Ethnicity
Applications
Refusal /Denial
Denials /Refusals as %of Actions
Asian
208
52
25%
White
8
2
25%
Hispanic
4
3
75%
Native American/ Alaskan
2
2
100%
African American
2
1
50%
Hawaiian/ Pacific Islander
1
0
0%
Total
225
60
26.7%
Home purchase actions reflect the number of applications submitted to institutions
for homes that are new to the applicants. These numbers most accurately reflect the
change in demographic relationships between racial and ethnic groups in home
ownership. In other words, it measures potential wealth producing transactions by
race and ethnicity. Note, the statistics only account for those actions in which race
and ethnicity was disclosed by the data.
In Rosemead in 2013, 208 applications were submitted by Asian Americans, 92.4%
of the market. Whites comprised 3.6% of the market: Hispanics submitted 4
applications for 1.8% of the market. Other groups comprised less than 3% of the
Community Development Department Page 64
City of Rosemead FY 2015 -2020
2015 - 2020 Analysis of Impediments to Fair Nonsing Choice,
home purchase loan market in Rosemead. Refusal rates were much higher for all
groups other than Whites and Asian Americans.
East West Bank Home Purchase Loan Activitv. Citv of Rosemead. 2013
Race/ Ethnicity
Applications
Refusal /Denial
Denials /Refusals as %of Actions
Asian
37
10
27%
White
0
0
0
Hispanic
0
0
0
Native American/ Alaskan
1
0
0
African American
0
0
0
Hawaiian/ Pacific Islander
0
0
0
Total
38
10
26.3%
The home purchase loan activity for the top two Rosemead market lenders show
roughly the same numbers by race /ethnicity. For East West Bank, the striking
statistic is that it processed no applications for home purchase from Whites,
Hispanics, or African Americans, the only non -Asian American application being
from a Native American. That means Asian Americans were 97.4% of the home
purchase market from the largest home purchase lender in the Rosemead market
in 2013.
Wells Farno Rank Home Purchase Loan Activity Citv of Rosemead_ 2013
Race/ Ethnicity
Applications
Refusal /Denial
Denials /Refusals as %of Actions
Asian
27
9
33.3%
White
3
0
0
Hispanic
1
1
100%
Native American/ Alaskan
0
0
0
African American
0
0
0
Hawaiian/ Pacific Islander
0
0
0
Total
31
10
32.3%
Wells Fargo received 27 home purchase applications from Asian Americans in
Rosemead in 2013. That consisted of 87.1% of home purchase applications it
received. Three applications from Whites were all approved and accepted. The
only Hispanic application was denied.
Community Development Department Page 65
City of Rosemead FY 2015 -2020
2015— 2020 Analysis of Impediments to Fair Dousing Choice
Refinance Loan Activitv. All lenders. Citv of Rosemead. 2013
Race/ Ethnicity
Applications
Refusal /Denial
Denials /Refusals as %of Actions
Asian
727
239
32.9%
White
89
28
31.5%
Hispanic
149
60
40.1%
Native American/ Alaskan
8
1
12.5%
African American
1
0
0.0%
Hawaiian/ Pacific Islander
12
7
58.3%
Totals
988
335
33.9%
In refinance actions in the City of Rosemead, there were 727 applications from Asian
Americans which consisted of 73.6 % of refinance actions in Rosemead. Hispanics
submitted 149 applications which was 15.1 % of refinance actions. Whites submitted
89 applications for 9.0% of the refinance actions. Hispanics had a greater
refusal /denial rate than other groups with significant application numbers.
WPllc Farnn Rank Refinance_ Loan Activitv Citv_ of Rosemead 2013
Race/ Ethnicity
Applications.
Refusal /Denial
Denials /Refusals as %of Actions
Asian
102
31
30.4%
White
11
3
27.3%
Hispanic
22
10
45.5%
Native American/ Alaskan
1
0
0.0%
African American
0
0
0.0%
Hawaiian/ Pacific Islander
2
1
50.0%
Total
138
45
32.6%
Wells Fargo had 14% of the entire refinance market in Rosemead in 2013. In
refinance actions in Rosemead, Wells Fargo received 102 applications. from Asian
Americans which consisted of 73.9% of Wells Fargo's refinance actions in
Rosemead. Hispanics submitted 22 applications which was 15.9% of refinance
actions. Whites submitted 11 applications for 8.0% of the refinance actions.
Hispanics had a greater refusal /denial rate than other groups with significant
application numbers.
East West Bank Refinance Loan Activity City of Rosemead 2013
East West Bank had a single refinance loan action in the City of Rosemead in 2013.
That action was a loan to an Asian American family in the 4322.01 Census Tract.
East West Bank had 225 refinance loan actions countywide. Of those actions, 111
involved Asian families, 86 involved Whites and 20 involved Hispanics. No other
Community Development Department
City of Rosemead
2015 - 2020 Analysis of Impediments to Fair Housing Choice,
racial or ethnic groups were involved in refinance actions with East West Bank in
2013.
In East West Bank's countywide refinance actions involving Asian Americans, 38
(34.2%) resulted in denials, refusals or withdrawals. For Whites, the denial, refusal,
withdrawal rate was much higher - 45 (52.3 %). The highest rate of all was
Hispanics. In refinance actions involving Hispanics, 14 (70 %) resulted in denials,
refusals or withdrawals.
C. Access to Housing Credit in Rosemead - Conclusion
From the perspective of barriers to fair housing, this detailed analysis of Rosemead
HIVIDA lending patterns come to three central conclusions. First, the evidence of
redlining is not as clear as it was in the 2010 Al. The minority population in Rosemead
is now a majority population throughout the city. The large majority of home purchase
loans by all lenders made in Rosemead have been to Asian applicants.
Second, "minorities" were, by far, the largest group who acquired home loans in
Rosemead in 2013. Including all loan types, of all applicants for home purchase loans
and refinance loans in Rosemead in 2013, 75.5% were Asian American. This compares
to 55% in 2008. For Hispanics the percentages of market demand was 15.5% in 2013,
compared to 34% in 2008. Whites consisted of 7.1% of the market demand in 2013,
compared to 11% in 2008. The remaining groups, primarily African American and
Native American, consisted of less than 3% of the market demand. While the denial of
loan applications to Asians was consistent with those of other racial and ethnic
categories, the sheer volume of lending applications by Asians greatly outnumbered
every other racial group (963 of 1231 lender actions were for Asians) which indicates
an imbalance that favors Asian lending applications.
The third major finding is that the housing market has changed significantly in
Rosemead and to the apparent advantage of Asian applicants. East West Bank, a
Chinese American owned mortgage lender headquartered in Pasadena, processed no
applications for home purchases from Whites, Hispanics, or African Americans, the only
non -Asian American application being from a Native American. That means Asian
Americans were 97.4% of the home purchase market from the largest home purchase
lender in the Rosemead market in 2013. The City should encourage East West Bank
to conduct outreach and provide lending information to non -Asian communities in Los
Angeles County in an effort to diversity its lending portfolio.
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City of Rosemead FY 2015 -2020