Opportunity and Equity

in Southeast Florida

May 17, 2013

REGIONAL ANALYSIS OF IMPEDIMENTS TO

FAIR HOUSING

RAI

 The purpose of an AI or RAI is to Affirmatively Further Fair Housing Choice (AFFH)

 It is a review of impediments or barriers that affect the rights of fair housing choice

 Serves as the basis for fair housing planning

 Provides essential information to policy makers, administrative staff, housing providers, lenders and fair housing advocates

 Assists in building public support for fair housing efforts

WHAT IS AN RAI?

IMPEDIMENTS TO FAIR HOUSING CHOICE

Any actions, omissions, or decisions which directly restrict or have the effect of restricting housing

choices or the availability of housing choices taken because of:

Race Color Religion Sex Disability Familial status

National origin

  All households - regardless of race, color, ancestry, national origin, religion, sex, disability, marital status, familial status, or any other arbitrary factor - are entitled to equal access to housing opportunities.

 Both federal, state and local civil rights laws define these fundamental liber ties. §  The Civil Rights Act of 1968 provides specific fair housing

protections under Title VII, the Fair Housing Act.

§  The Florida Fair Housing Act reiterates federal law by declaring it illegal to discriminate in the sale, rental, advertising, financing, or brokerage of housing.  

§  The Broward County Human Rights Act provides additional protections against discrimination in employment, housing and public accommodations.

CIVIL RIGHTS: UNDERSTANDING FAIR HOUSING LEGISLATION

SEFLA RAI

  FHEA is quite similar to the Regional AI in scope and content.

  The Regional AI includes an analysis that identifies both jurisdictional and regional impediments to fair housing choice.

  Seven50 utilizes both documents in tandem  Our end goal is to create a Fair Housing and Opportunities

Action Plan   The Fair Housing and Opportunities Action Plan’s

strategies and actions will be implicitly reflected in all final product(s) of the Sustainable Communities Regional Planning Grant.

FHEA AND RAI

1. Regional Background ²  Basic Existing Conditions Analysis at the

County and Regional Scale: ²  Demographics ²  Segregation ²  Housing ²  Poverty ²  Labor and Commuting

HOMEOWNERS AND RENTERS

87%

9%

17%

75%

19%

26%

White

Black or African American

Hispanic or Latino (of any race)

Renter-occupied housing units

Owner-occupied housing units

1,517,837

751,424

COST BURDENED HOUSEHOLDS

82%

57% 61% 47%

31%

91% 89%

74%

43%

21%

Less than $20,000

$20,000 to $34,999

$35,000 to $49,999

$50,000 to $74,999

$75,000 or more

Owner-occupied Renter-occupied

A disproportionate number of renters

are minorities

Renters are more-cost burdened than

homeowners

Thus, a disproportionate

number of minorities are cost-burdened

POVERTY

13% 14%

10% 12% 12%

17%

11%

²  Over 850,000 people below poverty level in the region

POVERTY AND ETHNICITY

9%

23%

16% White

Black or African American

Hispanic or Latino origin (of any race)

POVERTY AND GENDER

371,490

482,267

Male Female

31% of Single Mothers with children present are below the poverty

level

Tenancy

0%

10%

20%

30%

40%

50%

60%

70%

80%

Owner-occupied housing units

Renter-occupied housing units

Race/Ethnicity

WHO TRAVELS HOW

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%

White

Black or African American

Hispanic or Latino origin (of any race)

MODE OF TRAVEL

0% 10% 20% 30% 40% 50% 60% 70% 80%

Drive Alone

Carpool

Public Transportation

Indian River County, Florida St. Lucie County, Florida

Martin County, Florida Palm Beach County, Florida

Broward County, Florida Miami-Dade County, Florida

Monroe County, Florida 7-County SE Florida Region

25 24

27

42

Mean travel time to work

Fair Housing Legal Evaluation ²  Assisted Housing Inventory ²  Fair Housing Discrimination complaints

FAIR HOUSING ASSISTANCE AGENCIES WITHIN SEFLA

County Name Agency Type

N/A- State Level Federal Commission on Human Rights State Agency; Government

Palm Beach

Legal Aid Society of Palm Beach County Private

Palm Beach County Office of Equal Opportunity

Government  

Broward Broward County Office of Equal Opportunity | Civil Right Division

Government

Miami

Housing Opportunities for Project Excellence, H.O.P.E Inc. Private

Miami-Dade Office of Human Rights and Fair Employment Practices (OHRFEP)

Government

EXISTING ASSISTED HOUSING INVENTORY

2,856 2,480 1,219

12,652 17,129

40,514

838

77,688 Number of Properties Total Units

Assisted Units

% Assisted

Indian River 26 2,858 2,856 99.9% St. Lucie 18 2,623 2,480 95% Martin 17 1,221 1,219 100% Palm Beach 93 13,802 12,652 92% Broward 121 21,116 17,129 81% Miami-Dade 334 42,346 40,514 96% Monroe 17 861 838 97% 7-County SE Florida Region 626 84,827 77,688 94.3%

ASSISTED HOUSING BY INCOME RESTRICTIONS

0 5000 10000 15000 20000

Indian River

St. Lucie

Martin

Palm Beach

Broward

Miami-Dade

Monroe

<=35% AMI 40-50% AMI 55-60% AMI 65-80% AMI >80% AMI

ASSISTED HOUSING TARGET POPULATIONS

Family

Elderly

Farmworker

Fisher

Homeless

Persons with Disabilities

RACE AND ETHNICITY OF ASSISTED HOUSING TENANTS

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Indian River St. Lucie Martin Palm Beach Broward Miami-Dade Monroe 7-County SE Florida Region

% Minority % Black % Hispanic

FAIR HOUSING DISCRIMINATION COMPLAINTS: 2007-2012

17%

0.3%

14%

2%

7%

11%

43%

1% 6%

RACE

COLOR

NATIONAL ORIGIN

RELIGION

SEX

FAMILIAL STATUS

DISABILITY

AGE

OTHER

FAIR HOUSING COMPLAINTS OVER THE FIVE YEAR PERIOD

0%

5%

10%

15%

20%

25%

30%

2007 2008 2009 2010 2011 2012

Basis % Rank DISABILITY 43% 1

RACE 17% 2 NATIONAL ORIGIN 14% 3 FAMILIAL STATUS 11% 4

SEX 7% 5 OTHER 6% 6

RELIGION 2% 7 AGE 1% 8

COLOR 0.3% 9

BASES FOR DISCRIMINATION COMPLAINTS

0%

10%

20%

30%

40%

50%

60%

Indian River St. Lucie Martin Palm Beach Broward Miami-Dade Monroe

DISABILITY RACE NATIONAL ORIGIN FAMILIAL STATUS

TOP FOUR BASES FOR DISCRIMINATION COMPLAINTS

OVER TIME

0

50

100

150

200

250

300

350

400

450

2007 2008 2009 2010 2011 2012

DISABILITY RACE NATIONAL ORIGIN FAMILIAL STATUS

Lending Profile ²  Discriminatory Lending Practices ²  Home Mortgage Disclosure Act Data

Analysis

LOAN DENIAL RATES

Overall Loan Dispositions for the Seven County Southeast Florida Region & The State of Florida

County Originated/Approved

Denied Other Total

Broward 12954 (55.87%)

5277 (22.76%)

4957 (21.38%)

23188

Indian River County

1133 (67.76%)

261 (15.61%)

278 (16.05%)

1672

Martin County 1193 (68.88%)

261 (15.07%)

278 (16.05%)

1732

Miami-Dade County

10807 (51.41%)

5390 (25.64%)

4824 (22.95%)

21,021

Monroe County 707 (59.97%)

242 (20.53%)

230 (19.51%)

1179

Palm Beach County

9765 (60.21%)

3241 (19.98%)

3213 (19.81%)

16219

St. Lucie County 2571 (61.35%)

802 (19.14%)

818 (19.52%)

4191

Florida 144931 (61.59%)

46139 (19.61%)

44259 (18.81%)

235329

  The most prevalent reason for loan application denials among the counties in South Florida in is the loan applicant’s debt to income ratio

  The second leading reason for loan denials in South Florida was collateral

LOAN DENIAL REASONING

LOAN DENIAL DISPARITIES BY RACE AND ETHNICITY

Loan Application Denial Disparities Across the Seven County South Florida Region By Race Applicant Race

Broward County

Disparity Indian River

County Disparity

Martin County

Disparity Miami-Dade

County Disparity

Monroe County

Disparity Palm Beach

County Disparity

St. Lucie County

Disparity Hispanic 1.15 0.88 1.89 1.08 1.15 1.38 1.2

Black or African American

1.42 0.8 2.14 1.15 0.85 1.52 1.34

Asian 1.04 N/V 0.79 1.01 0.67 1.03 1.38

Native Hawaiian or Other Pacific Islander

1.78 N/V N/V 2.16 N/V 1.27 1.24

American Indian or Alaska Native

1.27 N/V 1.78 1.01 1.17 1.59 1.64

Subprime/High Cost Loans in the Seven County Southeast Florida Region Compared to the State of Florida

County High Cost Non-High Cost or Unknown

Total

Broward County 334 (2.91%)

11148 (97.09%)

11482

Indian River County

19 (2.25%)

826 (97.75%)

845

Martin County 25 (2.73%)

891 (97.27%)

916

Miami-Dade County

410 (4.58%)

8551 (95.42%)

8961

Monroe County 5 (1.54%)

320 (98.46%)

325

Palm Beach County

201 (2.48%)

7896 (97.52%)

8097

St. Lucie County 51 (2.55%)

1950 (97.45%)

2001

Florida 4177 (3.50%)

115111 (96.50%)

119288

SUBPRIME LENDING

High Cost Loan Disparity Across the Seven County South Florida Region By Race Applicant Race

Broward County Disparity

Indian River County Disparity

Martin County Disparity

Miami-Dade County Disparity

Monroe County Disparity

Palm Beach County Disparity

St. Lucie County Disparity

American Indian or Alaska Native

No High Cost Loans

No High Cost Loans

No High Cost Loans

3.09 No High Cost Loans

2.79 No High Cost Loans

Asian 0.45 No High Cost Loans

3.73 ,78 No High Cost Loans

0.31 No High Cost Loans

Black or African American

1.64 2.5 No High Cost Loans

0.71 No High Cost Loans

1.42 1.28

Hispanic Ethnicity

1.37 0.69 No High Cost Loans

1.42 1.69 2.14 0.74

Native Hawaiian or Other Pacific Islander

1.03 Not Listed Not Listed No High Cost Loans

No High Cost Loans

No High Cost Loans

No High Cost Loans

White N/A N/A N/A N/A N/A N/A N/A

SUBPRIME LENDING DISPARITIES BY RACE AND ETHNICITY

Identified Impediments

TOP TEN IDENTIFIED IMPEDIMENTS

1. • Lack of Knowledge, Awareness of, or Education on Fair Housing Protections

2. • Fair and Equal Lending Disparities

3. • Housing/Lending Discrimination on the Basis of Race, Color, National Origin, Religion, Sex, Familial Status and Disability

4. • Shortage of Affordable Housing Opportunities

5. • Violations of Federal, State and Local Housing Laws

6. • Housing Market Segregation

7. • Predatory Lending

8. • Limited Funding to Meet Need for Affordable Housing

9. • Zoning/Land Use

10. • Improvement of the Housing Discrimination Complaint Process

WHERE ARE WE

NOW?

AFFIRMATIVELY FURTHERING FAIR HOUSING

1.  Conduct an analysis to identify impediments to fair

housing choice within the jurisdiction ✔

2.  Prepare a Fair Housing Strategies & Action Plan that will identify appropriate actions to overcome the effects of any impediments identified through the analysis

3.  Maintain records reflecting the analysis and actions taken in this regard

1.  Await HUD guidance on local jurisdictions opting in to the Regional AI.

2.  Utilize datasets from Regional AI through Seven50 data warehouse and SFRPC Data Commons.

3.  Review cross-jurisdictional impediments and coordinate

regional responses

LOCAL JURISDICTIONS AND RAI

37

THANK YOU!

For further information, contact James Carras

Phone: 954.415.2022

Email: carras@bellsouth.net Principle Researchers

FHEA: Urban Revitalization Strategies – Rebecca Walter and Serge Atherwood

RAI: – Anna McMaster and Rasheed Shotoyo