FINAL REPORT 2013 FHIP FHOI Grant No. FH800G13027 I. SUMMARY OF PROGRAM GOALS AND OBJECTIVES

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Kristopher Flynn
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1 NORTHWEST FAIR HOUSING ALLIANCE 35 West Main Avenue Suite 250 Spokane, WA (509) Fax (509) FINAL REPORT 2013 FHIP FHOI Grant No. FH800G13027 I. SUMMARY OF PROGRAM GOALS AND OBJECTIVES Northwest Fair Housing Alliance (NWFHA) received a $325,000 funding award from the Department of Housing & Urban Development (HUD) pursuant to the FY13 Fair Housing Initiatives Program (FHIP) Fair Housing Organizations Initiative (FHOI) to conduct an 18- month project that commenced November 1, 2013 and ended on April 30, During the 18 months of this grant, NWFHA provided fair lending enforcement services to members of all protected classes covered by the Fair Housing Act in 17 counties in Eastern/Central Washington: Whitman, Garfield, Columbia, Asotin, Walla Walla, Grant, Adams, Lincoln, Douglas, Ferry, Okanogan, Pend Oreille, Spokane, Yakima, Benton, Stevens, and Franklin. NWFHA also carried out specific program activities designed to combat lending discrimination targeted at persons with disabilities and pregnant women in our service-region. As set forth in the Statement of Work, specific goals for the 18 months of the grant period included: Review and update protocols referring fair lending and mortgage rescue scam enforcement proposals to HUD FHEO and Washington s Department of Financial Institutions (DFI) Screen 24 inquiries (calls/walk-ins/ s) and evaluate for fair lending and mortgage rescue scam issues Intake and counsel individuals on fair lending and mortgage rescue scam issues Refer all fully jurisdictional fair lending complaints arising from FHIP funding to HUD Refer 10 possible mortgage modifications scams to the WA Dept. Financial Institutions (DFI) for further investigation and enforcement action Continue advocacy for 9 complaints referred to HUD/WSHRC under FY11 FHOI-MRC grant Continue advocacy for 14 agency complaints to WA DFI under FY11 FHOI-MRC grant Review/refine testing methodology and tester training materials for fair lending testing Review and update testing methodology and tester training materials for mortgage rescue scam testing 1

Housing Initiatives Program (FHIP) Fair Housing Organizations Initiative (FHOI) to conduct an 18- month project that commenced November 1, 2013 and ended on April 30, 2015.

2 Recruit 12 testers and offer fair lending, reverse mortgage, and mortgage rescue scam tester training opportunities Complete 5 systemic investigations Conduct 40 mortgage modification scam tests Conduct 12 reverse mortgage tests based on age to identify violations of ECOA Complete 45 tests for discriminatory underwriting policies. Evaluate testing results and complaint data internally to generate increased enforcement actions by HUD Broadcast 2 PSAs on TV Publish 6 English & 6 Spanish print PSAs in Tu Decides Broadcast 2 radio PSAs on KYRS and KDNA in English & Spanish Enhance and update NWFHA s E. WA Lending Awareness webpage with fair lending, housing counseling, foreclosure avoidance, and mortgage rescue scam information, in English and other languages Update and print NWFHA s regional E. Fair Lending and Mortgage Rescue Scam Awareness brochures. Translate 2 brochures into Russian Distribute 1000 English, Spanish and Russian fair lending and rescue scam brochures Provide (6) fair lending trainings for mortgage originators using NMLS approved CE hour curriculum Modify existing NMLS approved live fair housing curriculum for distance learning delivery and submit to NMLS for CE approval Prepare annual summary of NWFHA fair lending complaint and testing data for E.WA and publish on NWFHA website II. OUTPUT GOALS AND OUTPUT RESULTS/ ACHIEVEMENT OUTCOME GOALS END RESULTS SUMMARY OF ACCOMPLISHMENTS: During the 18-month period of the grant (11/1/13-4/30/15), NWFHA s output results met or exceeded the output goals: Screened and evaluated 25 inquiries for fair lending and mortgage rescue scam issues Referred 5 jurisdictional fair lending complaints arising from FHIP funding to HUD Referred 12 possible mortgage modifications scams to the WA DFI for further investigation and enforcement action 2

Evaluate testing results and complaint data internally to generate increased enforcement actions by HUD Broadcast 2 PSAs on TV Publish 6 English & 6 Spanish print PSAs in Tu Decides Broadcast 2 radio

3 Continued advocacy for 9 and resolved 8 of the 9 complaints referred to HUD/WSHRC under FY11 FHOI-MRC grant Continued advocacy for and resolved 14 of the 14 complaints referred to WA DFI under FY11 FHOI-MRC grant Reviewed and refined testing methodology and tester training materials for fair lending testing Recruited 12 testers and offered fair lending, reverse mortgage, and mortgage rescue scam tester trainings Conducted 5 systemic investigations Conducted 40 mortgage modification scam tests Submitted 12 complaints to WA DFI based on results from this testing Conducted 12 reverse mortgage tests based on age to identify violations of ECOA Of the 12 reverse mortgage tests, 4 indicated a need for future testing. The remaining tests did not show any evidence of discrimination. Completed 52 tests for discriminatory underwriting policies Submitted 5 fair lending enforcement proposals to HUD/WSHRC based on results from this testing Broadcasted 2 PSAs on TV Published 6 English & 6 Spanish print PSAs in Tu Decides Broadcast 2 radio PSAs on KYRS and KDNA in English & Spanish Updated and printed NWFHA s regional E. Fair Lending and Mortgage Rescue Scam Awareness brochures and translated the 2 brochures into Russian Distributed 1,084 English, Spanish and Russian fair lending and rescue scam brochures Provided 9 fair lending trainings for mortgage originators using NMLS approved CE hour curriculum Modified existing NMLS approved live fair housing curriculum for distance learning delivery and received approval from NMLS and HUD. INTAKES AND INQUIRIES: NWFHA LENDING INQUIRIES AND INTAKES, 11/1/13-4/30/15 Race Color Nat Or Dsblty Gndr Fam Sts Religion Any Totals Inquiries Received Complaints 1 4* 4* 4 filed w/ HUD Complaints 1 1 3

scam tester trainings Conducted 5 systemic investigations Conducted 40 mortgage modification scam tests Submitted 12 complaints to WA DFI based on results from this testing Conducted 12 reverse

4 filed w/ WSHRC *some intakes had multiple protected classes TESTING: During this project, NWFHA completed 52 fair lending policy tests (exceeding goal of 45) 40 mortgage modification scam tests (meeting goal of 40) 12 matched pair reverse mortgage tests (meeting goal of 12) ENFORCEMENT PROPOSALS: During this project, NWFHA referred 5 jurisdictional fair lending complaints arising from FHIP funding to HUD All 5 of these enforcement actions were based on evidence collected during NWFHA s fair lending testing. 12 possible mortgage modifications scams to the WA Dept. Financial Institutions (DFI) for further investigation and enforcement action, exceeding the grant goal of 10. All 12 of these referrals were based on the results of mortgage modification scam testing. All of these enforcement proposals are currently pending with their respective agencies, and no dispositions have been issued, nor conciliations reached. EDUCATION/OUTREACH ACTIVITIES: NWFHA participated in a variety of education and outreach activities in Eastern and Central WA, particularly focused on providing information about the Fair Housing Act s fair lending protections and NWFHA s services to service providers and potential borrowers in low-income and minority communities. During this grant, NWFHA: Broadcast 2 public service announcements on television Published 6 English & 6 Spanish print public service announcements in Tu Decides Broadcast 2 radio public service announcements on KYRS and KDNA in English & Spanish 4

funding to HUD All 5 of these enforcement actions were based on evidence collected during NWFHA s fair lending testing. 12 possible mortgage modifications scams to the WA Dept.

5 Updated and printed NWFHA s regional E. Fair Lending and Mortgage Rescue Scam Awareness brochures and translated the 2 brochures into Russian Distributed 1,084 English, Spanish and Russian fair lending and rescue scam brochures Attended Unity in the Community and ran a service provider booth, fielding fair lending questions from community members. Spoke both over the phone and in person with representatives from area service agencies regarding NWFHA s fair lending program and services, and advised these representatives of NWFHA s fair lending training opportunities. Spoke both over the phone and in person with representatives from service area loan officers and mortgage brokers regarding NWFHA s fair lending program and services, and advised these representatives of NWFHA s fair lending training opportunities. IMPROVEMENT OF EXPERTISE The further development of NWFHA s fair lending unit during the period of this grant has greatly enhanced our capacity and ability to: Provide fair lending investigation and advocacy services for people in Eastern WA through: o The full-time Fair Lending Investigator continues to conduct fair lending investigations and testing, as well as field inquiries related to fair lending o Staff attendance at national fair lending trainings provided by HUD, the National Fair Housing Alliance, and the National Community Reinvestment Coalition (NCRC) o Continued relationships with regional housing counselors, legal advocates, and the WA Dept. of Financial Institutions to enhance quality complaint referrals o Development and improvement testing methodology o Recruitment and training of new and existing testers to conduct fair lending and mortgage rescue scam testing o Conducting complex fair lending tests in a variety of ways, in order to best address current patterns and trends in fair lending discrimination. o Conducting mortgage rescue scam phone testing Provide fair lending education: o The full-time Fair Lending Specialist continues to provide fair lending education for mortgage loan originators and housing counselors o Providing live fair lending trainings for mortgage loan originators o Development of fair lending resources and inclusion on our website (English and Spanish fair lending and mortgage rescue scam brochures; and fair lending and mortgage rescue scam videos); and translation of those materials into Russian for increased exposure in the LEP population. CONCLUSION The activities reported on in our Quarterly Reports and supporting documentation show that our objectives were met and, in a number of instances, exceeded. Overall, this project has enhanced the capacity of Northwest Fair Housing Alliance to provide effective fair lending enforcement services in Eastern Washington. 5

Unity in the Community and ran a service provider booth, fielding fair lending questions from community members.

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