St Paul Housing Study

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    TABLE of conTEnTs

    Introduction

    Subprime Mortgage Lending

    Foreclosures

    Vacant Houses

    Home Values

    Recommendations

    ............................................................................................4

    ..................................................................5

    .............................................................................................8

    .........................................................................................10

    .........................................................................................12

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    Wieig the Gap:How the Housing Crisis Deepened Racial Disparitiesin St. Paul and How to Fix It

    Wieig the Gap: How the Housing Crisis Deepened Racial Disparities in St. Paul and How to Fix It 3

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    InTroducTIon And summAry of fIndInGs

    Te subprime mortgage meltdown has resulted in a record number o oreclosures and plunged the United Statesinto the worst nancial crisis since the Great Depression. St. Paul has not been immune rom this crisis. Al-though the housing crisis has afected individual homeowners o all races and ethnicities, minority neighborhoodshave sufered rom an extreme concentration o housing problems.1

    Predatory subprime lenders targeted people o color or high cost loans. In some cases, the sub-prime lenders, whose loans were more likely to be made in minority neighborhoods, were ownedor bankrolled by mainstream nancial institutions such as Wells Fargo and US Bank, whose loanswere more likely to be in predominantly white neighborhoods.

    Predatory subprime loans stripped homeowners o their wealth and lead to an epidemic o ore-closures.

    Foreclosures ravaged neighborhoods and let behind a trail o vacant homes.

    Te unprecedented numbers o oreclosures and vacant homes caused a steep and continuingdecline in home values throughout the city, but especially in lower income and minority neighbor-hoods.

    wenty-eight percent o the loans made in St. Paul by Wells Fargo Financial were in minorityneighborhoods, compared to just 15% o the loans made through Wells Fargo Bank.2

    Subprime loans accounted or 42% o the home renance loans made by New Century, a sub-prime lender in which US Bank was a major investor, compared to just 14% o the renanceloans made by US Bank3

    Te number o oreclosures in Ramsey County skyrocketed rom 632 in 2005 to a peak o over3,000 in 2008. Although the number o oreclosures has passed its peak, it appears that therewill be thousands more in the next ew years.4

    Lower-income amilies and households o color have been hit the hardest, resulting in clus-ters o oreclosures in the Tomas-Dale and East Side neighborhoods o St. Paul, with some

    blocks having six to eight vacant buildings.5

    Tere are 1,300 vacant residential buildings in St. Paul6 and 90% o them are in low and mod-erate income neighborhoods.

    Almost hal o the citys vacant housing is located in a minority neighborhood, although mi-nority neighborhoods contain just 20% o the housing units in the city.7

    Homes in the Daytons Blu, Payne-Phalen, and Tomas-Dale neighborhoods experiencedthe greatest loss o value since 2006, whereas homes in the Mac-Groveland, Highland, and St.Anthony Park neighborhoods lost the lowest percentage o their value.8

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    Wieig the Gap: How the Housing Crisis Deepened Racial Disparities in St. Paul and How to Fix It 5

    suBPrImE morTGAGE LEndInG

    Low-income and minority communities have longbeen excluded rom traditional banking services.A study by economists ound that the number obanking oces in low- and moderate income ar-eas decreased 21% over a two decade period, whilethe number o total banking oces in all areas rose

    29% during this same time. Tis is signicant be-cause studies have documented that the proxim-ity o a banks branches to low and moderate in-come neighborhoods is directly related to the levelo lending made by the bank in those neighbor-hoods.9

    Arican-American and Latino loan applicantshave regularly been turned down more oten thanwhite applicants. A report rom the Urban Insti-

    tute, prepared or HUD, corroborated this statisti-cal analysis, concluding that minority homebuyersace discrimination rom mortgage lenders. Tereport cited paired testing which showed thatminorities were less likely to receive inormationabout loan products, received less time and inor-mation rom loan ocers, and were quoted higherinterest rates.10

    Tis history o racial exclusion created an envi-ronment that was ertile or predatory lenders tomarket high-rate loan products. Tese unscrupu-lous actors aggressively targeted underserved com-munities with a bombardment o mailings, phonecalls, and door-to-door solicitations.

    A number o reports have documented the star-tling racial and economic disparities in mortgagelending. Residents o low income and minorityneighborhoods have been much more likely thanresidents in upper income and predominantlywhite neighborhoods to receive a high-cost sub-prime loan.

    While not all subprime lenders were predatory, the

    overwhelming majority o predatory loans weresubprime, and the subprime industry was a ertilebreeding ground or predatory practices. Subprimeloans were said to be or people who were unable toobtain a conventional prime loan, and the higherinterest rates on subprime loans were supposedlyto compensate or the potentially greater risk thatthe borrowers represent. However, predatory lend-ing occurred when loan terms or conditions be-came abusive or when borrowers who would havequalied or credit on better terms were targeted

    instead or these higher cost loans.

    oo oten higher rate subprime loans were alsoloaded with abusive eatures such as high ees,large and extended prepayment penalties, nancedsingle premium credit insurance which cost bor-rowers even more money, and kept them trappedinto the higher interest rates.

    While predatory lenders sometimes appeared tobe small-time storeront operators, the masters obehind predatory lending could be ound amongsome o the worlds largest nancial institutions.In act, many o the same institutions which rstcreated the situation by their ailure to serve cer-tain communities later seized the opportunity toreap enormous prots.

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    Sometimes these institutions had direct ownershipo subprime lending subsidiaries, such as WellsFargo and Wells Fargo Financial. In other cases,these institutions bankrolled predators by invest-ing in them directly, such as US Bank and NewCentury Financial, or by serving as the trustee or

    securitized pools o subprime mortgages, whichboth US Bank and Wells Fargo did.

    Te loans made through the parent bank hadgreater concentrations in predominantly whiteneighborhoods, while the loans made through thesubprime subsidiary were more concentrated inminority neighborhoods. Tis created a shame-ul pattern o proteering; preying on the mostvulnerable among us, and creating a devastatingimpact on already-struggling neighborhoods.

    A.Subprime Refnance Lending

    Te vast majority o subprime loans were or re-nances, rather than home purchases. For instance,rom 2004 to 2007, Wells Fargo Financial madea total o just three home purchase loans in St.Paul.

    Subprime loans were promoted as a way to con-

    solidate debt, provide money or home improve-ments, or or household or personal needs, ratherthan being sought by borrowers as a way to lowertheir interest rates or lock in a xed rate.

    Tere are circumstances where renancing to usesome o the equity in ones home makes sense, butcash-out renances were rie with potential orabuse by predatory lenders. oo oten homeownerswith signicant amounts o equity were convincedto renance under conditions that let them con-

    siderably worse o than they were beore.In some cases, homeowners were sold renanceloans which produced just a ew thousand dol-lars in cash at closing, but which renanced theirexisting mortgages at higher rates, high ees, andoten with abusive loan terms.

    B. Wells Fargo

    In July 2011, the Federal Reserve Board assessedan $85-million civil penalty against Wells Fargo,the largest ne the Federal Reserve has ever im-posed in a consumer case.12 Te Federal Reservecharged thatbetween 2004-2008 WellsFargo Financial

    steered custom-ers into moreexpensive sub-prime loans eventhough they qualied or better rates. As part o itssettlement with the Federal Reserve, Wells Fargowill have to repay up to $200 million to customersthat it overcharged.13

    Previously, the Illinois Attorney General sued

    Wells Fargo or steering Arican-American andLatino homeowners to higher cost subprimemortgages while giving white borrowers who hadsimilar incomes lower cost loans. Te suit chargedthat Wells Fargo drained wealth rom amiliesand neighborhoods and added to the stockpile oboarded-up homes . . .14

    Tere is evidence that Wells Fargo has engagedin the same pattern o practices in the win Cit-ies. Wells Fargo has served upper income and pre-

    Wieig the Gap: How the Housing Crisis Deepened Racial Disparities in St. Paul and How to Fix It 6

    Well fag Bak Well fag fiaial us Bak new cet

    % i miit

    neighbh

    14.9% 28.2% 14.1% 42.4%

    % i White

    neighbh

    27.4% 7.9% 31.2% 7.8%

    Mortgages in St. Paul11

    Wells Fargo drained wealt

    from families and neigh

    borhoods and added to thstockpile of boarded-up

    homes . . .

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    Wieig the Gap: How the Housing Crisis Deepened Racial Disparities in St. Paul and How to Fix It 7

    -dominantly white neighborhoods through itsbank, providing prime loans with good terms andlow rates. In contrast, Wells Fargo has served low-to-moderate income and minority neighborhoodsdisproportionately through its nance company,Wells Fargo Financial, which makes higher rate

    subprime loans.

    C. US Bank

    US Bank was a major investor in New Century Fi-nancial, the poster child or bad practices in themortgage industry. By 2007, when the companyled or bankruptcy, New Century was the secondlargest subprime mortgage lender in the country.16

    In 1998 and 1999 when it was dicult or sub-prime lenders to raise capital, US Bank came toNew Centurys rescue and invested $40 million inthe company. US Bank reaped a prot o nearly$18 million rom this investment within just a ewyears.17

    In contrast to US Bank, New Century, which made

    loans with high rates and enormous ees, made alarge percentage o its loans to minority neighbor-hoods. From 2004 to 2006, New Century s last yearo business, almost hal o the renances New Cen-tury made in St. Paul were in minority neighbor-hoods. Whereas just 14% o US Banks renances

    in St. Paul were in minority neighborhoods.

    Te investments in New Century were just a smallpart o US Banks involvement with subprime lend-ers. Troughout the last decade, US Bank served asa trustee or billions o dollars in securitized poolso home mortgages made by New Century andothers. Te list o lenders whose loans US Bankserved as a trustee or reads like a whos who othe subprime industry: Aames, Ameriquest, BNC,Citinancial, Conseco, Countrywide, Downey,

    Equicredit, First Franklin, First Plus, Fremont,Greenpoint, Household, and New Century.18 Asthe rustee, US Bank was responsible or distrib-uting the cash fow rom the mortgage pools to allthe dierent investors, ater US Bank took its cutrst. rustees take a percentage each month o theoverall pool balance.19

    Renance Loans in St. Paul15

    Renance Loans in St. Paul

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    Te number o oreclosures in Ramsey County sky-rocketed rom 632 in 2005 to a peak o over 3,000in 2008. Although the number o oreclosures haspassed its peak, Ramsey County still experiencedover our times more oreclosures in 2010 than in2005, and it appears that there will be thousandsmore in the next ew years.

    A recent Star ribune article noted that there maybe an increase in oreclosures coming in Minneso-ta. Te article attributed the decline in oreclosuresin part to the hold that lenders put on oreclosuresdue to the robo-signing scandal, and quoted a realestate expert who said that theres denitely an-other round o oreclosure coming down the pipe-line.20

    Lower-income amilies and households o colorhave been hit the hardest, resulting in clusters ooreclosures in the Tomas-Dale and East Sideneighborhoods o St. Paul, with some blocks hav-ing six to eight vacant buildings.21

    Te areas in the win Cities that have been themost aected by oreclosures are the North Side oMinneapolis and the Payne-Phalen neighborhoodon St. Pauls East Side. 22 In St. Paul, the zip codes

    with the most oreclosure activity since last Aprilare all on the East Side. 23

    According to the Center or Responsible Lendingapproximately 8 percent o Arican-American andLatino amilies have lost their homes to oreclo-sure compared to 4.5 percent o white amilies.24

    Many o these oreclosures can and should beavoided. A report rom state regulators stated:

    [T]oo many homeowners experience oreclo-sure when fnding an alternative solution

    would be in the interest o both the homeown-er and the mortgage holder. Preventing theseunnecessary oreclosures would help not onlythe struggling homeowners and mortgageinvestors, but also the neighborhoods and lo-cal governments that bear the indirect costs o

    oreclosures.25

    Te regulators ound that mortgage servicers wereonly reaching a minority o delinquent homeown-

    ers with their oreclosure prevention eorts.

    Nearly three years into the oreclosure crisis,we fnd that more than 60% o homeownerswith seriously delinquent loans are still notinvolved in any loss mitigation activity.26

    Tere have been almost 120,000 oreclosures inMinnesota since 2006 over 80,000 since 2009when the ederal Home Aordable Modica-tion Program began. In contrast, there have been

    less than 13,000 permanent loan modications inMinnesota under HAMP.27

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    forEcLosurEs

    ZIP CODEFORECLOSURE

    ACTIONS SINCE APRIL2011

    55106 406

    55119 229

    55117 214

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    As the oreclosure crisis has exploded, mortgageservicers have ailed to adequately meet the num-ber o delinquent homeowners. In a recent GAOsurvey o non-prot housing counselors, or exam-ple, seventy-six percent o the counselors reportedthat overall their clients had a negative or verynegative experience with the mortgage servicers.Te most commonly cited problems were o hom-eowners receiving inconsistent or conusing inor-mation, speaking to a dierent representative eachtime they called, o servicers losing their paper-work, and o the decision-making process takingtoo long.28

    Even worse, in a rush to oreclose on delinquent ho-meowners, many mortgage servicers were accused

    o engaging in negligent and raudulent practices,where servicer employees admitted to preparing-massive numbers o oreclosure documents withoutappropriate verication and, in some cases, evenwithout the appropriate signatures. Servicers havebeen oreclosing on homeowners without proothat the lender is the actual holder o the note orthat the borrower is even in deault.

    Te Oce o the Comptroller o the Currency(OCC) conducted examinations o the oreclosure

    processes o US Bank and Wells Fargo and oundthat both banks engaged in unsae or unsoundpractices,29 such as:

    Filing legal adavits in which bank employeesmade assertions that they claimed, alsely, werebased on personal knowledge or review o therelevant records

    Filing numerous adavits courts that were notsigned in the presence o a notary

    Failing to devote adequate oversight, internalcontrols, policies and procedures to theiroreclosure processes

    Failing to suciently oversee outside lawyersand other third-parties handling oreclosures

    In addition the OCC ound that Well Fargo:

    Initiated oreclosures without always ensuringthat mortgage documents met legal require-ments

    Failed to devote sucient nancial, stangand managerial resources to its oreclosure pro-cesses

    yea 2005 2006 2007 2008 2009 2010 2011

    fele 632 1498 2346 3023 2519 2608 2078

    Foreclosures in Ramsey County 2005-2011

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    Foreclosures not only impact the individual homeown-ers but also local governments, neighbors, and otherproperty owners. Especially when a oreclosure leaves ahome vacant and unsecured, it can cost cities and coun-ties tens o thousands o dollars.

    Foreclosures result in decreased revenue or cities andcounties through lower property values, delayed anduncollected taxes, and unpaid services. At the sametime that oreclosures mean less revenue or cities andcounties, they also impose additional requirements tothose cities and counties or increased policing, build-

    ing inspection, demolition, property maintenance, andmanaging the oreclosure process.

    Ater peaking in 2008, the number o vacant houses hasstarted to decline, but there are still almost our timesmore properties on St. Pauls vacant building list thanthere were in 2004.

    Te vacant buildings are disproportionately concentrat-ed in St. Pauls lower income and minority neighbor-hoods.31 Ninety percent o the citys vacant housing isin low and moderate income neighborhoods.

    Almost one out o every two vacant buildings in St. Pauis in a minority neighborhood, although just one out ove o the citys housing units are in these neighbor-hoods. In contrast white neighborhoods contain onein ve o the citys housing units, but only one in ortyvacant homes.

    Vacant homes have been the site o numerous crimesIn addition to burglary and trespassing, there have beenseveral high prole incidents in St. Paul recently. InMarch, police charged nine men and teens with drag-ging a 14 year old girl into a vacant home and sexuallyassaulting her. Tat same month, a man was killed on

    the porch o a vacant home where he had gone to settlea drug debt. In December, a homeless man died aterstarting a re in a vacant house in Minneapolis.32

    yea 2004 2008 2012

    Bilig 370 2000 1291

    Vacant and Boarded Buildings in St. Paul30

    VAcAnT HousEs

    Wieig the Gap: How the Housing Crisis Deepened Racial Disparities in St. Paul and How to Fix It 10

    Ward# o VacantResidentialBuildings

    % o Total VacantResidential Buildings

    7 293 24.1%

    6 238 19.6%1 228 18.7%

    5 226 18.6%

    2 143 11.8%

    4 63 5.2%

    3 22 1.8%

    st. Pal

    neighbh

    % cit Vaat

    Bilig

    % cit

    Hig uit

    Minority Neighborhoods 45.1% 22.7%

    Integrated Neighborhoods 52.4% 56.0%

    White Neighborhoods 2.5% 21.3%

    st. Pal

    neighbh

    % cit Vaat

    Bilig% cit Hig uit

    Low and Moderate Income 90.6% 61.7%

    Middle Income 8.6% 25.2%

    Upper Income 0.9% 21.3%

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    In contrast to St. Paul, Minneapolis has many ewer vacant buildings and charges property owners a muchhigher vacant building ee.

    Number of Vacant Buildings by Census Tract

    0 mi 2 4

    Numberof VacantBuildingsbyCensusTract

    80

    9

    1

    2004 2005 2006Vaat Bilig

    regitati fee

    St. Paul 370 2000 1452 $1200

    Minneapolis 286 857 802 $6746

    Ppetie cit Vaat Bilig Lit33

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    Te unprecedented numbers o oreclosures andvacant homes caused a steep and continuing de-cline in home values throughout the city, but es-pecially in minority neighborhoods. Home equityaccounted or nearly two-thirds o the net worth

    o Latinos in 2005 and 59% o the net worth oArican-Americans, but just 44% o the net wortho whites.34

    From 2005 to 2009 the median level o home eq-uity that Latino homeowners had nationally wascut in hal rom $99,983 to $49,145. For Arican-American homeowners, the median level o homeequity declined rom $76,910 to $59,000 duringthis period. For white homeowners, it decreasedrom $115,364 to $95,000.35

    A recent report rom the Pew Research Centeround that the bursting o the housing bubble andthe ensuing recession resulted in36:

    a 66% decrease in the wealth o Latino house-holds rom an average o $18,359 in 2005 to$6,325 in 2009

    a 53% drop in the wealth o Arican-Ameri-

    can households rom an average o $12,124 to$5,677 in 2009

    just a 16% decline in the wealth o white house-holds rom an average o $134,992 to $113,149

    In St. Paul, homes in the Daytons Blu, Payne-Phalen, North End, and Tomas-Dale neigh-borhoods experienced the greatest loss o value,dropping 50% since 2006, whereas homes in theMac-Groveland, Highland, and St. Anthony Parkneighborhoods lost the smallest percentage, drop-ping less than 20%.37

    HomE VALuEs

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    neighbh Apil 2006Jaa

    2012dlla Peetage

    Thomas Dale $168,000 $77,600 -$90,400 -53.8%

    Daytons Bluff $170,500 $81,900 -$88,600 -52.0%

    Payne Phalen $182,000 $93,200 -$88,800 -48.8%

    North End $180,500 $95,200 -$85,300 -47.3%

    Greater East Side $186,500 $99,900 -$86,600 -46.4%

    Battle Creek $207,500 $113,200 -$94,300 -45.5%

    St Paul City $205,300 $122,600 -$82,700 -40.3%

    West Side $187,000 $112,400 -$74,600 -40.0%

    Summit-University $212,800 $133,500 -$79,300 -37.3%

    West 7th $186,500 $117,400 -$69,100 -37.1%

    Midway $196,500 $130,600 -$65,900 -33.5%

    Como $233,000 $167,600 -$65.400 -28.1%

    Merriam Park $305,100 $225,500 -$79,600 -26.1%

    St. Anthony $341,500 $268,900 -$72,600 -21.3%

    Macalester-

    Groveland$306,000 $245,500 -$60,500 -19.8%

    Highland $301,500 $247,000 -$54,500 -18.1%

    Summit Hill $490,200 $408,200 -$82,000 -16.7%

    sigle fail

    He Piechage 2006 t 2012

    In total, St. Paul has lost over $61 billion in home value, which could drain $46.3 million in annual taxrevenue rom Ramsey County and $15.5 million in annual tax revenue rom the city.38

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    1. The tate mieta, tie, aitie hl apt a ele eia-ti pga t pevet eea e-

    le.

    Tere is growing recognition o the eectiveness ooreclosure mediation programs in preventing un-necessary oreclosures. Te number o states andmunicipalities that have such programs continuesto grow, and there are now jurisdictions in 24 statesthat have oreclosure mediation.

    Foreclosure mediation benets all o the involvedparties:

    Servicers avoid a long and costly oreclosureprocess since more than 70 percent o mediatedcases reach a settlement.39

    More than hal o homeowners in mediatedcases get to keep their homes, while those orwhom that is not a sustainable option also ben-et by negotiating a graceul exit in how andwhen they move out.

    For government, mediation can reduce the

    number o vacant homes and stabilizes propertyvalues and tax revenue.

    In 2009 the Minnesota legislature passed the Ho-meowner-Lender Mediation Act which wouldhave required lenders to oer homeowners the op-portunity to participate in non-binding mediationbeore the lender could oreclose, however Gover-nor ime Pawlenty vetoed the bill.40

    Under the Act, lenders would have been required

    to serve a mediation notice to the homeowner andled proo o it with the Attorney Generals oce.Homeowners would have 20 days ater this to le arequest or mediation. I the homeowner does notrequest it, then the lender could proceed with theoreclosure.

    Although a state level mediation program wouldbe optimal in that it could benet rom an econ-omy o scale and would serve the largest numbero homeowners, cities and counties can implementtheir own mediation programs.

    2. mieapli hage ppet we$6,746 aall t egite vaat bil-ig, while st. Pal hage jt $1,200.

    Te city o St. Paul should increase its vacant build-ing registration ee to oset the signicant costs tothe city o vacant buildings, but also to reduce thenumber o vacant buildings by spurring owners tosell or rehab their properties.

    3. Lal gveet, hl ba, apbli ageie hl eqie that abak the bie with eet ep-ible lee iteia that ile igbet patie ele peveti.

    rEcommEndATIons

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    Wieig the Gap: How the Housing Crisis Deepened Racial Disparities in St. Paul and How to Fix It 15

    4. Lal gveet, hl ba, apbli ageie hl eqie that abak the bie pblil ileiati egaig it ele, i-lig:

    a. Te number o homeowners eligible or loanmodications

    b. Te number that received or were denied per-manent modications

    c. Te principal and/or rate reduction in eachmodication

    d. A breakdown or each o the above categories

    by the race, ethnicity, and census tract o the ho-meowners.

    5. mtgage evie hl pl withthe llwig bet patie elepeveti:

    a. Stop oreclosure proceedings while they areevaluating a borrowers eligibility or a loanmodication or other oreclosure preventionoptions

    b. Respond within 72 hours to requests or in-quiries about loan modications

    c. Ensure that the loan modication processtakes less than 30 days

    d. Modiy troubled loans so that they are or nomore than the value o the home

    e. Allow tenants o oreclosed properties to con-tinue to rent the property until it is sold

    . ake steps to ensure that its loans are not be-ing used or property fipping or oreclosure res-cue scams.

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    Minority neighborhoods are dened as census tracts in which people o color make up more than hal o thepopulation.Based on Home Mortgage Disclosure Act (HMDA) data or rst lien conventional renance loans 2004-2006Based on Home Mortgage Disclosure Act (HMDA) data or rst lien conventional renance loans 2004-2006Data rom Ramsey County Sheri s Oce

    Equitable Development oolkit: Reclaiming Foreclosed Properties or Community Benet, Policy Link, August26, 2009Data rom city o St. Paul Vacant Building Registration List, 938 single amily, 345 duplexes, 48 multi-amily2000 Census dataZillow Home Values Index, calculated September 1, 2011Te Community Reinvestment Act Ater Financial Modernization: A Baseline Report, U.S. reasury Depart-ment, April 2000.What We Know About Mortgage Lending Discrimination, Te Urban Institute, September 1999.Based on Home Mortgage Disclosure Act (HMDA) data or rst lien conventional renance loans 2004-2006Wells Fargo, Countrywide Mortgage Settlements Give Homeowners a Bit o Relie, Daily Finance on AOL.com,Catherine New, July 22, 2011Up to 10,000 customers, up to $20,000 each, equals $200 million

    July 31, 2009 Press Release, Madigan Sues Wells Fargo or Discriminatory and Deceptive Lending PracticesBased on Home Mortgage Disclosure Act (HMDA) data or rst lien conventional renance loans 2004-2006New Century, Biggest Subprime Casualty, Goes Bankrupt, Bloomberg, April 2, 2007, Bradley Keoun and StevenChurch.U.S. Bancorp Prots Handsomely rom Its Investment in New Century,National Mortgage News, March 11, 2002,Brad FinkelsteinInormation rom ABSNetInormation rom ABSNetMore home oreclosures on horizon in Minnesota, Star ribune, Jim Buchta, April 16, 2012Equitable Development oolkit: Reclaiming Foreclosed Properties or Community Benet, Policy Link, August26, 2009Fostering Equitable Foreclosure Recovery, Sarah reuhat, Kalima Rose, and Jennier ran, Policy Link, January

    2012, p. 14Realty rac. Includes pre-oreclosure notices and sheri s salesSpeculators, Not CRA, Behind Foreclosures in Black Neighborhoods, September 7, 2011,American Banker, JohnI. Gilderbloom and Gregory D. SquiresAnalysis o Mortgage Servicing Perormance, Data Report No. 4, January 2010, State Foreclosure Prevention

    Working GroupRedeault Rates Improve or Recent Loan Modications, State Foreclosure Prevention Working Group Memo-randum on Loan Modication Perormance, August 2010Making Home Aordable: Summary Results, Program Perormance Report Trough Oct 2011,GAO-11-367R Survey o Housing Counselors about HAMP, May 26, 2011, United States General AccountingOceUnited States o America, Department o the reasury, Comptroller o the Currency, Consent Order AA-

    EC-11-18 In the Matter o US Bank National Association, and United States o America, Department o thereasury, Comptroller o the Currency, Consent Order AA-EC-11-19 In the Matter o Wells Fargo Bank N.A.In housing meltdown, cities turn into buyers, Star ribune, Chris Havens, February 7, 2010 and City o St. Paul

    vacant building list as o March 1, 2012, http://www.stpaul.gov/index.aspx?NID=2272Minority neighborhoods are dened as census tracts in which people o color make up a majority o the population.Integrated neighborhoods are dened as census tracts in which people o color make up between 10%-49% o thepopulation. White neighborhoods are dened as census tracts in which people o color make up less than 10% othe population.Vacant houses not always emply,Star ribune, April 30, 2012, Chao Xiong.

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    Cities using ederal money to address oreclosures, Star ribune, September 18, 2010, Chris HavensWealth Gap Rise to Record Highs Between Whites, Blacks, Hispanics, Pew Research Center, July 26, 2011Wealth Gap Rise to Record Highs Between Whites, Blacks, Hispanics, Pew Research Center, July 26, 2011Wealth Gap Rise to Record Highs Between Whites, Blacks, Hispanics, Pew Research Center, July 26, 2011Zillow Home Values Index, calculated September 1, 2011According to Zillow.com, the value o the average home in St. Paul has declined $82,700 rom April 2006 to January 2012.

    Tere are 74,000 single amily, duplex, triplex, condo units, and townhomes in the city o St. Paul, according to the WilderResearch Centers Census Facts. Tis calculates to a total o $6.1 billion in total lost home value. Using the RamseyCounty tax rate o 1.01% o a homes value, the loss in value means $61.8 million in lost property taxes. Te city receives

    about 25% o the total property tax. http://www.stpaul.gov/DocumentView.aspx?DID=17200Walk the alk: Best Practices on the Road to Automatic Foreclosure Mediation, Alon Cohen, Center or American Prog-ress, November 2010Minnesota AG to push or Foreclosure Mediation,Housing Wire, Jon Prior, January 8, 2010

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