Public Review Draft May 30, 2012 Table of Contents

Table of Contents ...... i

Chapter 1: Introduction ...... 1 A. Purpose of the Report ...... 1 B. Legal Framework ...... 1

Chapter 2: Community Profile ...... 7 A. Neighborhood Service Areas ...... 7 B. Demographic Profile ...... 9 C. Household Characteristics ...... 27 D. Housing Characteristics ...... 34 E. Housing Problems ...... 40 F. Income and Employment ...... 45

Chapter 3: Lending Practices ...... 53 A. Background and Legislative Protection ...... 53 B. Overall Lending Patterns ...... 57 C. Lending Patterns by Race/Ethnicity and Income Level ...... 62 D. Lending Patterns by Census Tract Characteristics ...... 63 E. Major Lenders ...... 64 F. Subprime Lending ...... 66 G. Purchased Loans ...... 70 H. Review of Lending Patterns by Specific Lender ...... 71 I. Foreclosures ...... 73

Chapter 4: Public Policies ...... 76 A. Local Plans and Codes ...... 76 B. Rent Stabilization ...... 107 C. Building Codes ...... 113 D. Systematic Code Enforcement ...... 113 E. California Environmental Quality Act (CEQA) ...... 114 F. Housing Authority of the City of Los Angeles (HACLA) ...... 115 G. U.S. Department of Housing and Urban Development (HUD) ...... 122 H. Community Participation ...... 123

Chapter 5: Fair Housing Profile ...... 133 A. Fair Housing Practices in the Homeownership Market ...... 133 B. Fair Housing Practices in the Rental Market ...... 140 C. Fair Housing Services ...... 147 D. Fair Housing Statistics ...... 152 E. NIMBYism ...... 170

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Chapter 6: Progress since Previous AIs ...... 171 A. 1996 City of Los Angeles AI ...... 171 B. 2002 City of Los Angeles Fair Housing Impediment Study ...... 184 C. 2005 City of Los Angeles AI ...... 184

Chapter 7: Fair Housing Action Plan ...... 203 A. Impediments and Actions ...... 203

Appendix A: Community Outreach Program

Appendix B: Home Mortgage Disclosure Data (HMDA) – This appendix contains summary tables only. Detailed HMDA tabulations are bound under separate cover

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List of Tables

Table 1: Population Growth by Area (1990–2010) ...... 9 Table 2: Race and Ethnicity (2010) ...... 12 Table 3: Indices of Dissimilarity (2010) ...... 19 Table 4: LAPD Hate Crime Statistics (2007-2011) ...... 23 Table 5: Special Needs Individuals and Households (2010) ...... 27 Table 6: Large Households: Low/Moderate Income and Housing Problems ...... 28 Table 7: Elderly Households - Low/Moderate Income and Housing Problems ...... 29 Table 8: Housing Characteristics ...... 34 Table 9: Median Home Prices for Selected Areas ...... 36 Table 10: Average and Monthly Rent (2008) ...... 37 Table 11: Housing Affordability Matrix – Los Angeles County (2012) ...... 39 Table 12: Housing Problems by Household Characteristic (2006-2008) ...... 40 Table 13: Housing Cost Burden (2006-2010) ...... 40 Table 14: Overcrowding and Severe Overcrowding (2006-2010) ...... 41 Table 15: Age of Housing (2010)...... 42 Table 16: Defined Lead Poisoning Cases (2006-2010) ...... 43 Table 17: Income Categories ...... 45 Table 18: Household Income Distribution (2000 and 2006-2008) ...... 46 Table 19: Income by Household Type (2006-2008) ...... 48 Table 20: Top 25 Employers in Los Angeles (2012) ...... 49 Table 21: Employment and Wages ...... 51 Table 22: Disposition of Home Loans (2007 and 2010) ...... 57 Table 23: Disposition of Conventional Home Purchase Loans (2007 and 2010) ...... 58 Table 24: Disposition of Government-Backed Home Purchase Loans (2007 and 2010) ...... 59 Table 25: Disposition of Refinance Loans (2007 and 2010) ...... 60 Table 26: Disposition of Home Improvement Loans (2007 and 2010) ...... 61 Table 27: Lending Patterns by Race/Ethnicity for Los Angeles (2007 and 2010) ...... 63 Table 28: Outcomes Based on Census Tract Income (2010) ...... 64 Table 29: Outcomes Based on Minority Population of Census Tract (2010) ...... 64 Table 30: Top Lenders (2007 and 2010) ...... 65 Table 31: Top Lenders by Race/Ethnicity of Applicant (2010) ...... 66 Table 32: Reported Spread on Loans by Race/Ethnicity (2007 and 2010) ...... 68 Table 33: Percent of Purchased Loans by Race (2010) ...... 71 Table 34: Community Plan Areas List ...... 77 Table 35: General Plan Land Use Categories ...... 79 Table 36: Dwelling Unit Capacity by Subregion ...... 92 Table 37: Licensed Community Care Facilities (2012) ...... 101 Table 38: TOD and Population ...... 105 Table 39: RSO Complaints ...... 111 Table 40: Voucher Recipient Demographics ...... 116 Table 41: Potential Discrimination in Listings of For-Sale Homes in Los Angeles (2012) ...... 134 Table 42: Potential Discrimination in Listings of Homes for Rent (2012) ...... 140

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Table 43: Clients Served (2004-2011) ...... 152 Table 44: Clients Served by Race (2004-2011) ...... 153 Table 45: Clients Served by Ethnicity (2006-2011) ...... 153 Table 46: Clients Served by Ethnicity (2004-2011) ...... 154 Table 47: Clients Served by Other Characteristics (2004-2011) ...... 154 Table 48: Discrimination Complaints (2004-2011) ...... 155 Table 49: Discrimination Cases (2004-2011) ...... 156 Table 50: Selected Case Summaries ...... 156 Table 51: Findings and Dispositions (2004-2011) ...... 161 Table 52: Summary of Housing Issues (2004-2011) ...... 162 Table 53: Basis for Discrimination of Complaints filed with DFEH (2005-2011) ...... 163 Table 54: Closing Categories for Fair Housing Complaints Filed with DFEH (2005-2011) ...... 163 Table 55: Basis for Discrimination of Cases filed with HUD (2005-2010) ...... 164 Table 56: Closing Categories for Fair Housing Cases Filed with HUD (2005-2010) ...... 165

List of Figures

Figure 1: Neighborhood Service Areas ...... 8 Figure 2: Hate Crimes in Los Angeles (2007-2011) ...... 21 Figure 3: Hate Crimes by Bureau (2007-2011) ...... 21 Figure 4: Hate Crimes by Bias Motivation in the City of Los Angeles (2007-2011) ...... 22 Figure 5: Hate Crimes (2007-2011) ...... 25 Figure 6: Concentration of Hate Crimes by LAPD Area (2007-2011) ...... 26 Figure 7: High-Risk Lead Hazard Areas ...... 44 Figure 8: Income Distribution (2010) ...... 46 Figure 9: Low and Moderate Income Areas and Minority Population Concentrations ...... 47 Figure 10: Major Employers and Public Transportation Routes ...... 50 Figure 11: Foreclosures in the City of Los Angeles (October-December 2011) ...... 75 Figure 12: Community Planning Areas ...... 78 Figure 13: Transit Stations and Minority Population (2010) ...... 106 Figure 14: Distribution of Housing Choice Voucher Recipients and Public Housing Units ...... 117 Figure 15: Fair Housing Service Providers and Areas of Coverage ...... 149

City of Los Angeles Page iv Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 Chapter 1: Introduction

A. Purpose of the Report

The City of Los Angeles has established a commitment to support the provision of equal housing opportunities for its existing and future residents. Through the federally-funded Community Development Block Grant (CDBG), HOME Investment Partnerships (HOME), Housing Opportunities for Persons with AIDS (HOPWA), and Emergency Solutions Grant (ESG) programs, and other state and local programs, the City seeks to provide a decent living environment for all.

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” through the following:

. Completion of an Analysis of Impediments to Fair Housing Choice (AI); . Actions to eliminate identified impediments; and . Maintenance of fair housing records.

This report, the Analysis of Impediments to Fair Housing Choice (commonly known as the “AI”), presents: 1) a demographic profile of the City of Los Angeles; 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.

B. Legal Framework

Fair housing is a right protected by both Federal and State of California laws. Among these laws, virtually every housing unit in California is subject to fair housing practices.

1. Federal Laws

The federal Fair Housing Act of 1968 and Fair Housing Amendments Act of 1988 (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. The Fair Housing Act prohibits discrimination based on the following protected classes:

. Race or color . Religion . Sex . Familial status . National origin . Disability (mental or physical)

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Specifically, it is unlawful 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.

. Represent to any person because of race, color, religion, sex, disability, familial status, or national origin 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.

Reasonable Accommodations 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 housing opportunities. 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 access-related modifications to their private living space, as well as to common use spaces, 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, 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, the U.S. Department of Housing and Urban Development (HUD) published the Final Rule on “Equal Access to Housing in HUD Programs Regardless of Sexual Orientation or Gender Identity.” It applies to all McKinney-Vento-funded homeless programs, as well as to permanent housing assisted or insured by HUD. The rule creates a new regulatory provision that generally prohibits considering a person’s marital status, sexual orientation, or gender

City of Los Angeles Page 2 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 identity (a person’s internal sense of being male or female) in making homeless housing assistance available.

2. California Laws

The State Department of Fair Employment and Housing (DFEH) enforces California laws that provide protection and monetary relief to victims of unlawful housing practices. The Fair Employment and Housing Act (FEHA) (Government Code Section 12955 et seq.) prohibits discrimination and harassment in housing practices, including:

. Advertising . Application and selection process . Unlawful evictions . Terms and conditions of tenancy . Privileges of occupancy . Mortgage loans and insurance . Public and private land use practices (zoning) . Unlawful restrictive covenants

The following categories are protected by FEHA:

. Race or color . Ancestry or national origin . Sex . Marital status . Source of income . Sexual orientation . Familial status (households with children under 18 years of age) . Religion . Mental/physical disability . Medical condition . Age

In addition, the FEHA contains similar reasonable accommodations and accessibility provisions as the federal Fair Housing Amendments Act.

The Unruh Civil Rights 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 Civil Rights 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.

Furthermore, 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.

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Hate violence can be: verbal or written threats; physical assault or attempted assault; and graffiti, vandalism, or property damage.

The Bane Civil Rights 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 the Act are not allowed for speech alone unless that speech itself threatened violence.

And, finally, California Civil Code Section 1940.3 prohibits landlords from questioning potential residents about their immigration or citizenship status. Landlords in most states are free to inquire about a potential tenant’s immigration status and to reject applicants who are in the United States illegally.1 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, recent changes to 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)

3. Fair Housing Defined

In light of the various pieces of fair housing legislation passed at the federal and state levels, fair housing throughout this report is defined as follows:

A condition in which individuals of similar income levels in the same housing market have a like range of choice available to them regardless of race, color, ancestry, national origin, religion, sex, disability/medical conditions, age, marital status, familial status, sexual orientation, gender identity, source of income, or any other category which may be defined by law now or in the future.

Housing Issues, Affordability, and Fair Housing

HUD’s Fair Housing and Equal Opportunity (FHEO) Division draws a distinction between housing affordability and fair housing. Economic factors that affect a household’s housing choices are not fair housing issues per se. Only when the relationship between household

1 http://www.nolo.com/legal-update/california-landlords-ask-immigration-citizenship-29214.html

City of Los Angeles Page 4 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 income, household type, race/ethnicity, and other factors create misconceptions, biases, and differential treatments would fair housing concerns arise.

Tenant/landlord disputes are also typically not related to fair housing. Most disputes between tenants and landlords result from a lack of understanding by either or both parties on their rights and responsibilities. Tenant/landlord disputes and housing discrimination cross paths when the disputes are based on factors protected by fair housing laws and result in differential treatment.

4. Impediments Identified

Within the legal framework of federal and state laws, and based on the guidance provided by HUD’s Fair Housing Planning Guide, impediments to fair housing choice can be defined as:

. Any actions, omissions, or decisions taken because of race, color, ancestry, national origin, religion, sex, disability/medical conditions, age, marital status, familial status, sexual orientation, gender identify, or source of income which restrict housing choices or the availability of housing choices; or

. Any actions, omissions, or decisions which have the effect of restricting housing choices or the availability of housing choices on the basis of race, color, ancestry, national origin, religion, sex, disability/medical conditions, age, marital status, familial status, sexual orientation, gender identity, or source of income.

To affirmatively promote equal housing opportunity, a community must work to remove impediments to fair housing choice. Furthermore, eligibility for certain federal funds requires the compliance with federal fair housing laws.

5. Organization of the Report

This report is divided into eight chapters:

. Chapter 1: Introduction - Defines “fair housing” and explains the purpose of this report.

. Chapter 2: Community Profile - Presents the demographic, housing, and income characteristics in the City of Los Angeles. Major employers and transportation access to job centers are identified. The relationships among these variables are discussed. In addition, this section evaluates if community residential care facilities, public and assisted housing projects, as well as Housing Choice Voucher (Section 8) recipients in the City, are unduly concentrated in low and moderate income areas. Also, the degree of housing segregation based on race is evaluated by computing the Index of Dissimilarity.

. Chapter 3: Lending Practices - Assesses the access to financing for different groups. Predatory and subprime lending issues are discussed.

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. Chapter 4: Public Policies - Analyzes various public policies and actions that may impede fair housing within the City.

. Chapter 5: Fair Housing Profile - Evaluates existing public and private programs, services, practices, and activities that assist in providing fair housing in the City of Los Angeles. This chapter also assesses the nature and extent of fair housing complaints and violations in the City. Trends and patterns of impediments to fair housing, as identified by public and private agencies, are included.

. Chapter 6: Progress since Previous AIs - Evaluates the progress toward addressing impediments to fair housing choice, as identified in previous AI reports.

. Chapter 7: Fair Housing Action Plan - Summarizes the findings regarding fair housing issues in the City and provides a plan of action for furthering fair housing practices.

This report also includes a Signature Page with the signature of the Chief Elected Official of the City (or his/her designee), together with a statement certifying that the Analysis of Impediments represents the City of Los Angeles’ official conclusions regarding impediments to fair housing choice and the actions necessary to address identified impediments.

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The City of Los Angeles is the second largest city in the nation, after New York, which has twice the population. The people of Los Angeles represent hundreds of countries and every continent, including many immigrants from Latin American and Asia. The City’s ethnic diversity reflects various socioeconomic characteristics, contributing to the unique spatial distribution of the Angeleno population.

Various characteristics may affect the ability of households with similar income levels, in the same housing market, to access a like range of housing choice. This chapter of the AI analyzes the demographic profile, income distribution, housing stock characteristics, and access to public transportation in Los Angeles.

A. Neighborhood Service Areas

In an effort to give greater voice to local neighborhoods, the Los Angeles City Charter was amended in 1999. Among other changes, it created Neighborhood Service Areas (NSA) as a new regional geography within the City, based on the combination of adjacent Community Plan areas designated by the City’s General Plan. The NSAs within Los Angeles include:

. North San Fernando Valley . South San Fernando Valley . West Los Angeles . Central Los Angeles (covering most of the downtown, central city and surrounding neighborhoods, mid-City and Hollywood) . East Los Angeles . South Los Angeles . Harbor (including the Port of Los Angeles, Wilmington and San Pedro)

Figure 1 illustrates the Neighborhood Service Areas. In order to provide additional insight on demographic, economic and social trends in the City, information presented in this chapter is presented by NSA, whenever possible.

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Figure 1: Neighborhood Service Areas

City of Los Angeles Page 8 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 B. Demographic Profile

The examination of demographic characteristics provides better insight regarding the need for and extent of equal access to housing in a community. Factors such as population growth and race/ethnicity all help determine a community’s housing needs, and play a role in exploring potential impediments to fair housing choice.

1. Population Growth

Consisting of 14 families, Los Angeles’ first settlers founded the City on September 4, 1781. They named the area “El Pueblo de Nuestra Senora la Reina de los Angeles de Porciuncula” (“The Town of Our Lady, the Queen of the Angels of Porciuncula”). The City of Los Angeles was incorporated on April 4, 1850. At the time of its incorporation, the City had a population of 1,610 and an area of 28 square miles.2 By 1900, spurred by the completion of a railroad into the area, the City population jumped to 102,000. The City also experienced tremendous growth in the post World War II period. Los Angeles’ population increased by 31 percent between 1940 and 1950 from 1,504,277 to 1,970,358. By 2000, Los Angeles had a population of over 3,600,000 and an area of 465 square miles. Close to 3.8 million people called Los Angeles home by 2010.

Table 1: Population Growth by Area (1990–2010) 2010 1990 2000 % Change Average Census Census Population % of Total Land Area Density 1990-2010 (Per Sq. Mi.) North Valley 582,008 651,944 699,830 18.5% 127.01 5,567 20.2% South Valley 634,800 703,013 725,154 19.1% 97.30 7,530 14.2% West Los Angeles 375,523 394,671 404,002 10.7% 87.59 4,660 7.6% Central Los Angeles 633,633 658,983 648,083 17.1% 51.17 12,795 2.3% East Los Angeles 410,426 405,114 396,264 10.4% 38.08 10,514 -3.5% South Los Angeles 666,955 687,927 723,761 19.1% 43.65 16,754 8.5% Harbor 182,054 193,168 195,486 5.2% 28.72 6,876 7.4% Total 3,485,399 3,694,820 3,792,580 100.0% 473.52 8,092 8.8% Note: The Central NSA also includes Griffith Park and low density areas of Hollywood Hills, resulting in a lower population density for the area. Source: Bureau of the Census, 1990-2010.

The jurisdictional boundary is irregularly shaped because the City has grown over the years through the annexation of surrounding territory and cities. Several cities – such as Beverly Hills, Santa Monica, West Hollywood, and Culver City – are surrounded partially or completely by the City of Los Angeles.

Among the NSAs, the two San Fernando Valley areas (North and South) are the largest with a land mass of approximately 224 square miles. These two NSAs have seen the highest rate of growth since 1990 (Table 1). By comparison, the Harbor NSA is the smallest in area (34 square miles) and in population, with the Port of Los Angeles comprising a significant portion of the

2 State Department of Finance, Population Estimates.

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NSA. The East Los Angeles area, encompassing neighborhoods such as Boyle Heights, Echo Park and Silverlake, is primarily built out and actually experienced a decline in population of about four percent between 1990 and 2010.

The Central and South Los Angeles NSAs are the most densely developed. Specifically, the South Los Angeles NSA had a population density (16,754 persons per square mile) that was twice the citywide density (8,092 persons per square mile) in 2010.

2. Racial and Ethnic Characteristics

The federal government considers race and Hispanic origin to be two separate and distinct concepts. In the 2010 Census, the following race categories were used:

. “White” refers to people having origins in any of the original peoples of Europe, the Middle East, or North Africa.

. “Black or African American” refers to people having origins in any of the Black racial groups of Africa.

. “Asian” refers to people having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian subcontinent.

. “Other” refers to people having origins in any of the original peoples of Hawaii, Guam, Samoa, Philippines, or other Pacific Islands, as well as people having origins in any of the original peoples of North and South America (including Central America), and who maintain tribal affiliation or community attachment.

Hispanic origin is an ethnicity and in the Census, the terms Hispanic and Latino are used interchangeably.3 People who identify with the terms "Hispanic" or "Latino" are those who classify themselves in one of the following specific Hispanic or Latino categories: “Mexican", "Puerto Rican", or "Cuban", as well as those who indicate that they are "other Spanish, Hispanic, or Latino." A person of Hispanic Origin can be of any race.

Increasingly, the nation is becoming more diverse in its racial and ethnic composition. The 2010 Census shows that at least three out of ten U.S. residents are non-Whites. The Hispanic population currently outnumbers the Black population in the U.S. by over 12 million people and it is projected that by the year 2030, one out of four residents will be either Hispanic or Asian.4

3 Persons of Hispanic origins in Los Angeles have different socioeconomic characteristics than other ethnic groups. To more accurately portray the racial/ethnic composition of City residents and their associated fair housing concerns, this report isolates the Hispanics (of all races) from non-Hispanic Whites, non-Hispanic Blacks, non-Hispanic Asians, and non-Hispanic others. Throughout this report, unless otherwise noted, “Whites” refer to non-Hispanic Whites, “Blacks” refer to non-Hispanic Blacks, “Asians” refer to non-Hispanic Asians, and “Others” refer to non-Hispanic others. 4 U.S. Department of State, International Information System, 2000.

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One of the factors that distinguishes Los Angeles from other metropolitan cities across the nation is its rapid transformation into one of the most diverse and multicultural cities in the country. The City of Los Angeles has already surpassed the projected national profile for 2030 – as of 2010, three out of every five City residents were either Hispanic or Asian (Table 2). The City’s diversity is apparent in the countless restaurants offering a vast variety of world cuisine, as well as by public school children in the Los Angeles Unified School District who speak 90 different languages in their homes.5

The City’s diverse character is attributable primarily to the 1965 reforms in U.S. immigration policy, officially ending the bias in favor of Northern European immigrants and opening the doors to immigration from Latin America and Asia. Los Angeles, with its historic connections with and proximity to Mexico, as well as its prominent position on the Pacific Rim, became the nation's leading port of entry for immigrants.

The City has a significant Mexican-American population, with 66 percent of the City’s Hispanic population being of Mexican heritage, according to the 2010 Census. People from El Salvador, Guatemala, and Nicaragua form the largest Hispanic communities after those of Mexican origin.

The City’s Asian population is diverse. Originally, Chinese were the largest Asian group in the City until the early 20th century when Japanese immigrants began to arrive. Later, a community of Korean political exiles settled in Los Angeles during the Japanese occupation of Korea in the first half of the 1900s. By 1990, Los Angeles was home to the largest Korean community outside of Korea. Filipinos have immigrated to Los Angeles primarily in search of economic opportunity. Vietnamese have come to the region principally as refugees at the end of the Vietnam War and because of other conflicts in Southeast Asia during the 1970s. In 2010, the Census found that the largest Asian groups in Los Angeles were Filipinos (29 percent), Koreans (26 percent), Chinese (15 percent), Asian Indian (eight percent), and Japanese (eight percent).

Los Angeles is also home to one of the largest Jewish communities in the U.S. Jews from Eastern and Northern Europe first settled in the area in the 19th century, and Russian Jewish immigration increased dramatically during Germany’s Nazi dictatorship. After World War II, large groups of Jews from the Middle East also made their home in Los Angeles. Prominent among these later Jewish immigrants are refugees from the 1979 Islamic Revolution of Iran, who usually identify themselves as Persians.

Other large Middle Eastern communities in Los Angeles include Armenians, Arabs, Iranians, and Israelis. These groups have grown dramatically since 1970 primarily because of conflict in their home regions, but also because of the search for educational and economic opportunities.

In 1990, Los Angeles became the first of the largest U.S. cities in which no ethnic or racial group formed a majority. According to the 2010 Census, Hispanics, who may be of any race, became the largest ethnic group in the City, representing 49 percent of the City population. Non-

5 Los Angeles Unified School District, Office of the Superintendent, Communications & Media Relations, 2004.

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Hispanic Whites made up 29 percent of the City population, Blacks 10 percent, Asians 12 percent, and less than two percent Others (such as Pacific Islanders).

Concentrations of White residents are apparent in the South Valley and West Los Angeles areas (Table 2). Hispanics are highly concentrated in East Los Angeles as well as in the North Valley, South Los Angeles and the Harbor areas. Blacks are concentrated in South Los Angeles, where the White population comprised only three percent of the population. In East Los Angeles where the majority of the population is Hispanic, Blacks comprised only two percent of the population. Asian concentrations are found in the Central area. Two predominantly Asian neighborhoods surround downtown Los Angeles – Chinatown to the northeast and Little Tokyo to the east. In addition, 25 percent of the residents in Koreatown are Asian, although today, almost two-thirds of the residents in this community west of the City are actually Hispanics (of any race).

Table 2: Race and Ethnicity (2010) North South West LA Central East LA South LA Harbor Total Valley Valley White 25.9% 47.8% 60.0% 30.4% 14.1% 3.2% 21.1% 28.7% Hispanic 57.1% 36.0% 16.2% 40.5% 68.4% 63.6% 60.6% 48.5% Black 3.7% 4.7% 5.2% 7.0% 1.8% 29.1% 7.7% 9.5% Asian 12.1% 10.0% 16.8% 20.7% 14.7% 2.7% 8.6% 12.0% Other 1.2% 1.5% 1.8% 1.4% 1.0% 1.4% 2.0% 1.4% Source: Bureau of the Census, 2010.

Race and ethnicity have implications on housing choice in that certain demographic and economic variables correlate with race. In addition, race and ethnicity are often related to a household’s proficiency in the English language which could lead to potential language barriers in terms of housing advertisements, applications, and leases. Along with a more diverse population comes an increase in the number of families with children and increased homes with multiple generations living under one roof due to cultural preferences, resulting in larger household sizes. For example, the average household size for Los Angeles was 2.81 in 2010. The average household size for Hispanics, however, was 3.95, while the average household size for Whites was 2.25.

Economic variables correlate with race/ethnicity as well. Annual household incomes for many of the City’s minority groups trail that of White households. According to 2006-2010 American Community Survey data, median household income was lower for Black households ($42,071) and Hispanic households ($44,989) than for White households ($71,768). Hispanic and Black households may have fewer housing choices available to them and are more likely to encounter discrimination in a highly competitive housing market because of their comparatively limited economic means.

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Discrimination Based on Race/Ethnicity

According to the 2002 Urban Institute study, Discrimination in Metropolitan Housing Markets, when Blacks and Hispanics visited real estate or rental offices to inquire about the availability of advertised homes and apartments, they faced a significant risk of receiving less information and less favorable treatment than comparable White customers received. However, new estimates from the U.S. Department of Housing and Urban Development (HUD), based on Urban Institute6 research, indicate that while discrimination persists against Blacks and Hispanics searching for homes in major metropolitan areas, its incidence has generally declined since 1989.7 Specifically, compared with their non-minority counterparts:

. Black renters received consistently unfavorable treatment in 21.6 percent of their inquiries, down 4.8 percentage points since 1989. Black homebuyers received consistently unfavorable treatment in 17.0 percent of their inquiries, down 12.0 percentage points since 1989.

. Hispanic renters received consistently unfavorable treatment in 25.7 percent of their inquiries, essentially the same as in 1989. Hispanic homebuyers received consistently unfavorable treatment in 19.7 percent of their inquiries, down 7.1 percentage points since 1989.

Despite signs of progress, significant discrimination remains. This discrimination raises the cost of housing searches for Blacks and Hispanics, creates barriers to homeownership and housing choice, and helps perpetuate involuntary racial and ethnic segregation.

According to the Housing Rights Center, the fair housing service provider for the City of Los Angeles area, 15 percent of housing discrimination complaints filed in the City during between 2004 and 2011 were related to issues of race, the third most frequent of all types of complaints, after issues related to physical disability and familial status.

Residential Segregation

Recent immigrants tend to concentrate in ethnic neighborhoods. Many of these neighborhoods have their origins in discriminatory housing practices in the early part of the 1900s. As specific groups moved into the region and began to have a larger presence in the City, many gravitated to ethnic neighborhoods where services catered to their language and culture. Not until they reached a certain economic status could they afford to move to other areas. Some of the more well-known ethnic neighborhoods in the City include:

. Boyle Heights: From the 1920s to the 1950s Boyle Heights, located in East Los Angeles, was the City’s most diverse neighborhood, serving as home to large concentrations of Jews, Mexicans, and Japanese Americans, as well as Russian Molokans, Blacks, and

6 Urban Institute is a nonpartisan economic and social policy research organization established in 1968 by President Johnson, originally as a blue-ribbon commission of government officials and civil leaders to look at the nation’s cities and urban populations. 7 Turner, Margery Austin, Stephen L. Ross, George Galster, and John Yinger. “Urban Institute, Discrimination in Metropolitan Housing Markets: National Results from Phase I of HDS2000.” Urban Institute: 2002.

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people of Armenian, Italian, and Chinese descent. Today Boyle Heights is primarily Latino and continues to serve as a port-of-entry for the City's Latino immigrant groups.8

. Pico-Union: Located west of Downtown, the Pico-Union neighborhood is mostly populated by Latinos, particularly of Central American descent. Pico-Union has served as an attractive destination point for new immigrants. Early residents of the area included middle- and upper-income Norwegians, Swedes, Welsh, and Russian Jews. Presently, the Pico-Union neighborhood is predominantly Latino.9

. Chinatown: The present day Chinatown is the City’s second Chinatown; the original one was located where Union Station now rests. Many Chinese settled in this once-rural area during the second half of the 19th century. Although most Angelenos of Chinese descent are well integrated into the City's suburbs, many new low to moderate income and elderly Chinese immigrants still regard Chinatown as their entry community because of language and culture. The more affluent have settled and conduct business in the suburban centers of the San Gabriel Valley, Palos Verdes, and Cerritos, none of which are within the City of Los Angeles.

. Leimert Park Village: Located southwest of Downtown and bounded by Crenshaw Blvd., Vernon Ave., Leimert Blvd., and 43rd Place, Leimert Park Village has emerged as one of Los Angeles' premier Black cultural centers and commercial districts.10

. Little Tokyo: Like the nearby Chinatown, this redeveloped ethnic neighborhood is no longer home to the majority of Angelenos of Japanese ancestry; the neighboring City of Gardena has that distinction. However, Little Tokyo functions as the cultural focal point of the Japanese community.

. Fairfax District/Pico Robertson: Since the 1940s, the Fairfax district has been the best- known distinctively Jewish section of Los Angeles with the presence of Orthodox synagogues, kosher butcher shops, and Israeli/Russian/Hebrew bookstores.11 The district is home to many Orthodox, Hasidic, and Reform Jews and is an intricate part of the City's Jewish community. As the neighborhood declined, many affluent and assimilated Jews moved out of the area into the Pico/Robertson neighborhoods and Cheviot Hills.

. Koreatown: Generally bounded by Western Avenue, Melrose Avenue, Vermont Avenue and Olympic Boulevard, Koreatown is a hub for cultural, social, and business life for Korean Americans. From a modest population of less than 10,000 in 1970, the Korean population in this area once grew to an estimated 160,000 people, making it the largest concentration of Koreans outside of Korea. Because of the changing demographics in

8 University of Southern California, Boyle Heights Neighborhood Sites and Images, 2004. 9 Loukaitou-Sideris, Anastasia. “The Byzantine Latino Quarter: Creating Community in Los Angeles’ Inner City.” Journal DISP Volume 140: 2000. 10 U.S. Dept. of Transportation. “LANI and the Leimert Park Project.” Public Roads Vol. 64 Number 2: Sept/Oct 2000. 11 Allen, James P. and Turner, Eugene. “The Ethnic Quilt; Population Diversity in Southern California.” California State University, Northridge: 1997.

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Los Angeles, most of the people now living in this area are of Mexican or Central American descent, but Koreans remain the predominant business owners.

. Cypress Park: The boundaries of Cypress Park are roughly considered to be the Los Angeles River to the west, the Arroyo Seco to the south, Mt. Washington to the east, and Division St. to the north. The neighborhood is a mostly Latino, working class neighborhood.

. Eagle Rock: Eagle Rock is bordered by the City of Glendale on the north and west, Highland Park on the southeast, Glassell Park on the southwest and the cities of Pasadena and South Pasadena on the east. A large portion of the Asian residents in this neighborhood are of Filipino descent, making Eagle Rock noted for its large Filipino community as well as its Hispanic population.

. Highland Park: The boundaries of this neighborhood are roughly the Pasadena Freeway (California Route 110) and the city limits of South Pasadena on the southeast, the city limits of Pasadena on the east, Oak Grove Drive on the north, and Avenue 50/51 on the west. Highland Park experienced White flight, from the development of Mid-Wilshire district in the 1920s through the late 1960s and early 1970s with the development and creation of new neighborhoods in Temple City to the east and the San Fernando Valley to the northwest. By the mid-1960s, the neighborhood had become a largely Latino enclave and by the mid-1970s, it emerged as a predominantly Latino area.

. Lincoln Heights: Lincoln Heights is bounded by the Los Angeles River on the west, the San Bernardino Freeway (I-10) on the south, and Indiana Street on the east; the district's Eastern border is unclear due to the area's uneven terrain. Lincoln Heights is considered to be the oldest neighborhood in Los Angeles, dating to the 1830s. Perched on bluffs above the Los Angeles River, it was originally home to some of the City's wealthiest residents, who built a large number of Victorian mansions in the district. By the turn of the 20th century, however, the rapid industrial development along the riverbanks made it less appealing for wealthy Angelenos, who moved on first to the Arroyo Seco area and Hollywood, then (from the 1920s onward) to rapidly developing Mid-Wilshire. As wealthy residents departed, Lincoln Heights became home to a large Italian American population, as well as an increasingly large Mexican American population. Beginning just after World War II, Italians and some Mexicans began migrating out of Lincoln Heights and into working-class and middle-class suburbs. This process accelerated during the 1950s with the construction of the Golden State Freeway, which split the district right down the middle and devastated the neighborhoods through which it passed. Ever since, Lincoln Heights has been a poor-to-working class Chicano and Latin American immigrant barrio. Many Chinese immigrants, mainly from Southeast China and Vietnam also reside in Lincoln Heights, due to its proximity to Chinatown.

. Historic Filipinotown: The district is bounded by the Hoover Street on the west to Glendale Boulevard on the east, Temple Street on the north, Beverly Boulevard on the southern end. Despite the fact that there are other enclaves of Filipinos living outside this district, it was declared Historic Filipinotown since it was one of the few areas where Filipinos first settled during the early part of the 20th century and home to key

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Filipino organizations, Filipino churches, housing and social service centers. While the district still has a sizable Filipino population, they are the minority, overshadowed by a sizable Mexican and Central American population. Nevertheless, the area still has one of the highest concentrations of Filipino Americans in Southern California and still remains the cultural heart of Filipinos throughout Los Angeles.

. Little Armenia: This neighborhood is bounded on the north by Hollywood Boulevard between the 101 Freeway and Vermont Avenue, on the east by Vermont Avenue from Hollywood Boulevard to Santa Monica Boulevard, on the south by Santa Monica Boulevard between Vermont Avenue and U.S. Route 101 and on the west by Route 101 from Santa Monica Boulevard to Hollywood Boulevard. It is home to a large number of Armenian-Americans as well as a large number of Armenian stores and businesses that had already opened in the neighborhood by the early 1970s. Though Hollywood was once home of the biggest Armenian community in the region, Glendale has surpassed Hollywood in both the number and proportion of Armenians, while Burbank, Pasadena, and La Crescenta also have large Armenian communities.

. Baldwin Hills: Baldwin Hills is bordered on the southeast by Los Angeles' Leimert Park neighborhood, on the south by View Park-Windsor Hills, on the west by Culver City, on the north by the Los Angeles Mid-City district, and on the east by the Crenshaw district. Baldwin Hills is among the wealthiest majority Black communities in the United States and includes the following sub-communities: Baldwin Hills Estates, Baldwin Vista, Village Green, and Baldwin Village.

. Crenshaw District: The Crenshaw District's boundaries are roughly Van Ness and Arlington Avenues on the east, Exposition Boulevard on the north, La Brea Avenue near Baldwin Hills on the west, and roughly Stocker Street & Slauson Avenue on the south. Developed from the early 1920s onward, Crenshaw was initially a very diverse neighborhood of Whites and covenants on property deeds barred Blacks and Asians from owning real estate in Crenshaw. After courts ruled segregation covenants to be unconstitutional, the area opened up to other races. A large Japanese American settlement ensued and Blacks started arriving in the 1960s. By the 1970s, Blacks comprised the majority of the population in this neighborhood.

. Leimert Park: This neighborhood is roughly bounded by Rodeo Road on the north, 4th Avenue and Roxton Avenue on the east, Vernon Avenue on the south, and Crenshaw Boulevard on the west. Leimert Park is considered the center of the Black arts scene in Los Angeles, with flourishing blues and jazz clubs, as well as venues for hip hop and numerous dramatic performances and poetry readings. Initially white-dominated, Leimert Park and the neighboring Crenshaw District eventually became one of the largest black middle class neighborhoods in the United States. Unlike other parts of Los Angeles, Leimert Park remains almost entirely Black, with a minuscule Latino population.

. Watts: This neighborhood’s boundaries are Firestone Boulevard on the north, Alameda Street on the east, Imperial Highway on the south, and Central Avenue on the west. Watts did not become predominantly Black until the 1940s, as the Second Great

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Migration brought tens of thousands of migrants, mostly from Louisiana, Mississippi, Arkansas and Texas, who left segregated Southern states in search of better opportunities in California. During World War II, the City built several large housing projects (including Nickerson Gardens, Jordan Downs, and Imperial Courts) for the thousands of new workers in war industries. By the early 1960s, these projects had become nearly 100 percent Black, as Whites moved on to new suburbs outside the central city. Beginning in the 1980s, due to gentrification, Blacks began moving to other parts of South Los Angeles and suburban locations. The black population in Watts has been replaced by successor migrants, primarily Hispanic immigrants of Mexican and Central American ancestry, as well as a smaller proportion of Ethiopian and Indian ancestry.

. West Adams: West Adams is an area stretching roughly from Figueroa Street on the east to West Boulevard on the west, and from Pico Boulevard on the north to Jefferson Boulevard on the south. The neighborhood was once the wealthiest district in the City and home to Downtown businessmen and professors and academics at USC. The development of the West Side in the 1910s, siphoned away much of West Adams' upper- class White population and upper-class Blacks began to move in, although the district was still off limits to all but the very wealthiest Blacks. West Adams' transformation into an affluent Black area was sped along by the Supreme Court's 1948 invalidation of segregationist covenants on property ownership. Mirroring changes seen throughout Los Angeles, the district's Latino population has been growing in recent years. The area's architecture and proximity to USC have also brought the return of some upper-middle- class Whites and many Black gays have moved into the neighborhood, making it the center of Black gay life in Los Angeles.

. Pacoima: This neighborhood is is bordered by the Los Angeles districts of Mission Hills on the west, Arleta on the south, Sun Valley on the southeast, Lake View Terrace on the northeast, and by the city of San Fernando on the north. Throughout its history, Pacoima was a place where Southern Californians escaping poverty in rural areas settled. In the post-World War II era, many Blacks settled in Pacoima after having been excluded from other neighborhoods due to racially discriminatory covenants. However, by the late 1960s, immigrants from rural Mexico began to move to Pacoima due to the low housing costs and the neighborhood’s proximity to manufacturing jobs. Blacks who were better established began to move out and, in less than two decades, the Black population was replaced by a poorer Latino immigrant population.

. Tarzana: This neighborhood is surrounded by Reseda to the north, Woodland Hills to the west, Encino to the east, and the Santa Monica Mountains (also a part of Los Angeles) to the south. Tarzana features a burgeoning Iranian-American population, and the community is well known for its Persian restaurants, booksellers, and language training institutes. A thriving and long-established Jewish community also exists and provides the customer base for the second branch of the Hebrew language bookselling chain Steimatzky constructed outside of Israel.

. Beverlywood: This district's boundaries are roughly Robertson Boulevard on the east; the Culver City limits on the south; Beverwil Drive and the Hillcrest Country Club on

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the west; and Monte Mar on the north. Largely residential, Beverlywood is one of the centers of Jewish life in Los Angeles. Renowned Nazi-hunter Simon Wiesenthal's Museum of Tolerance is adjacent to Beverlywood. The neighborhood is also home to a modest Persian population (many of whom practice Judaism) as well as a notable Israeli American population.

. Carthay: This neighborhood is roughly bounded by Wilshire Boulevard on the north, La Cienega Boulevard on the west, Pico Boulevard on the south, and Fairfax Avenue on the east. Initially limited by restrictive covenants to Whites, Carthay has since become fairly diverse, with many middle class Black, Latino, and Asian residents now living within the district. As with most of the Mid-Wilshire area, much of the White population is Jewish. A large portion of Carthay's Black residents are also of Ethiopian ancestry, which accounts for the numerous Ethiopian restaurants and shops in the part of the Carthay neighborhood known as Little Ethiopia.

. Harvard Heights: The boundaries of Harvard Heights are Pico Boulevard on the north, Western Avenue on the west, the Santa Monica freeway (I-10) on the south, and Normandie Avenue on the east. An upper middle class neighborhood through the first half of the 20th century with a notably large Greek-American population, Harvard Heights began to go into decline after World War II, as suburbs and the newer neighborhoods of the Westside drew away much of its population. The overturn of segregation covenants in 1948 led to an infusion of working and middle class Blacks, but by the 1980s most of the Black residents also moved on to other parts of the City. Latinos have become the predominant demographic in this neighborhood, with a particularly heavy concentration of Central Americans. In the late 1970s and 1980s, Harvard Heights became the home of Los Angeles' vibrant but severely impoverished Salvadoran and Guatemalan community. Since the late 1990s, the City of Los Angeles has referred to this neighborhood as the Byzantine-Latino Quarter.

Highly segregated neighborhoods play a contributing factor in many fair housing violations when real estate advertisements are geared towards people speaking a certain language or owners and managers prefer tenants of one ethnicity to another. Apartment vacancies that are filled by word-of-mouth advertising in concentrated ethnic neighborhoods may result unintentionally in limiting the choices of residents who speak a different language and are looking for a home.

Residential segregation refers to the degree to which groups live separately from one another. The term segregation historically has been linked to the forceful separation of racial groups. However, as more minorities move into suburban areas of Los Angeles County and outside of urban areas, segregation is becoming increasingly self-imposed. Originally, many ethnic groups gravitated to ethnic urban neighborhoods where services catered to them, and not until they reached a certain economic status could they afford to move to suburban areas. Today, living in an ethnic neighborhood is a voluntary choice for many. While some people believe that newly arrived immigrants in highly concentrated ethnic communities may resist blending into the mainstream, primarily because of the proliferation of native-language media and retail businesses, others feel that immigrants living with persons of similar heritage create a comfort zone that may help them transition to the mainstream and improve their economic situation.

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The availability of public transit and neighborhood-serving retail in urban neighborhoods may have also attracted new immigrants, who are more likely to not own cars.

The Dissimilarity Index is the most commonly used measure of segregation between two groups, reflecting their relative distributions across neighborhoods (as defined by Census block groups). The index represents a summarized level of segregation based on block group level analysis where the percentage of the minority group that would have to move to new neighborhoods to achieve perfect integration of that group. An index score can range in value from zero percent, indicating complete integration, to 100 percent, indicating complete segregation. In general, an index value of 60 or above is considered high, an index value of 40 to 50 is usually considered moderate, and values of 30 or below are considered low. The Dissimilarity Indices among different racial/ethnic groups are presented in Table 3 on page 19.

Citywide, segregation exists almost equally between Whites and Hispanics (70 percent) and Whites and Blacks (71 percent). Asians are moderately segregated from Whites (49 percent). However, Asians are generally more segregated from Hispanics (60 percent) than from Whites. In most NSAs, the greatest level of segregation was between Whites and Hispanics. The exceptions are West Los Angeles, where Blacks and Whites are most segregated (54 percent) and South Los Angeles, where Hispanics and Asians are most segregated (76 percent). Compared to other racial/ethnic groups, Asians seemed to be more integrated with the White population.

Table 3: Indices of Dissimilarity (2010) Race/Ethnic % of Total Indices with Indices with Population Group Population Whites Hispanics White 1,086,903 28.7% --- 0.70 City of Los Hispanic 1,838,790 48.5% 0.70 --- Angeles Black 359,360 9.5% 0.71 0.57 Asian 454,254 12.0% 0.49 0.60 White 181,133 25.9% --- 0.62 Hispanic 399,498 57.1% 0.62 --- North Valley Black 25,824 3.7% 0.54 0.51 Asian 84,923 12.1% 0.37 0.56 White 346,501 47.8% --- 0.57 Hispanic 260,893 36.0% 0.57 --- South Valley Black 34,309 4.7% 0.42 0.46 Asian 72,695 10.0% 0.36 0.47 White 196,717 30.4% --- 0.71 Hispanic 262,633 40.5% 0.71 --- Central Black 45,553 7.0% 0.58 0.58 Asian 134,123 20.7% 0.65 0.52 White 55,787 14.1% --- 0.63 Hispanic 271,191 68.4% 0.63 --- East Los Angeles Black 7,063 1.8% 0.50 0.59 Asian 58,350 14.7% 0.47 0.53 South Los White 22,981 3.2% --- 0.67

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Angeles Hispanic 460,573 63.6% 0.67 --- Black 210,692 29.1% 0.66 0.44 Asian 19,289 2.7% 0.48 0.76 White 242,464 60.0% --- 0.49 Hispanic 65,526 16.2% 0.49 --- West Los Angeles Black 20,876 5.2% 0.54 0.46 Asian 68,039 16.8% 0.38 0.44 White 41,320 21.1% --- 0.62 Hispanic 118,476 60.6% 0.62 --- Harbor Black 15,043 7.7% 0.62 0.52 Asian 16,835 8.6% 0.55 0.58 Source: Bureau of the Census, 2010; Veronica Tam and Associates.

Linguistic Isolation

Since language barriers can impede fair housing choice and a majority of Los Angeles households speak a language other than English at home, it is important to understand the degree to which the City’s households are linguistically isolated. A household is considered “linguistically isolated” if all members 14 years old and older have at least some difficulty with English. According to 2006-2010 American Community Survey data, 18 percent of Los Angeles households were considered linguistically isolated. Among households that did not speak English at home, households who spoke Asian and Pacific Island languages were more isolated than other groups (38 percent). Spanish speaking households were the next most isolated (35 percent), followed by households that spoke other Indo-European languages (26 percent) and those who spoke “Other” languages at home (17 percent).

A higher proportion of households that speak Spanish or Asian/Pacific Islander languages experience linguistic isolation compared to households that speak other languages.

Hate Crimes

The Los Angeles County Commission on Human Relations 2010 Hate Crime Report indicated that for the third year in a row, hate crimes in Los Angeles County decreased. In 2010, the number of hate crimes declined 29 percent, from 593 in 2009 to 427 in 2010. This is the lowest total in 21 years. The majority of hate crimes (51 percent) committed were based on race and Blacks were targeted the most frequently (53 percent). According to the report, hate crimes between Blacks and Hispanics were disturbingly high, with 59 percent of Black victims being targeted by Hispanics and 68 percent of Hispanic victims being targeted by Blacks. The number of sexual orientation crimes in 2010 was nearly equal to the previous year and comprised 26 percent of the total. These hate crimes were more likely to be of a violent nature than either racial or religious crimes. Gay men were targeted in 86 percent of these cases. Religious- motivated crimes fell to 17 percent of all hate crimes and only a small percentage of these were violent. Hate crimes committed by gang members fell 55 percent and constituted just nine percent of all hate crimes. The majority of these were cases of Latino gang members targeting black victims. Hate crimes occurred throughout Los Angeles County but the largest numbers

City of Los Angeles Page 20 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 were concentrated in the San Fernando Valley, followed by the Metro region. However, if one accounts for population size, the highest rate of hate crimes took place in the Antelope Valley, followed by the Metro region.

The Commission’s 2002 annual report referenced a study called “Taking America’s Pulse II” conducted by the National Conference of Community and Justice. The study found that while Whites see race relations with Blacks as the worst, minorities see relations between themselves and other minorities as the worst.

Detailed data on hate crimes was also collected by the Los Angeles Police Department (LAPD) from 2007 to 2011. This data tracked the number and type of hate crimes committed in the City of Los Angeles by sub-bureau. Over time, the number of reported hate crimes in Los Angeles has decreased (Figure 2). The Valley Bureau consistently had the highest number of hate crimes while the South Bureau had the lowest (Figure 3).

Figure 2: Hate Crimes in Los Angeles (2007-2011) 350

300

250

200

150

100

50

0 2007 2008 2009 2010 2011

Source: Los Angeles Police Department (LAPD), 2007-2011.

Figure 3: Hate Crimes by Bureau (2007-2011) 120

100

80

60

40

20

0 2007 2008 2009 2010 2011

Central South Valley West

Source: LAPD, 2007-2011.

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As shown in Figure 4, a majority of the hate crimes recorded in the City involved racially-based hate crimes (55 percent) followed by religiously motivated hate crimes (23 percent).

Figure 4: Hate Crimes by Bias Motivation in the City of Los Angeles (2007-2011) Gender Physical 2% Disability Mental Disability 0% 1%

Sexual Orientation 19%

Race/Ethnicity Religion 55% 23%

Source: LAPD, 2007-2011.

Certain bureaus within the City had higher numbers of hate crimes than others. Specifically, the Valley Bureau (with 421 incidents) had the most number of hate crimes in the City of Los Angeles between 2007 and 2011, while the South Bureau had the fewest number of hate crimes (160 incidents). Furthermore, certain sub-bureaus had especially high numbers of recorded hate crimes, including the Van Nuys (eight percent of total hate crimes), North Hollywood (eight percent of total hate crimes), Central (seven percent of total hate crimes) and Hollywood (six percent of total hate crimes) sub-bureaus (Table 4).

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Table 4: LAPD Hate Crime Statistics (2007-2011) Physical Mental Race/ Sexual # Bureau Name Gender Religion Total Disability Disability Ethnicity Orientation Central Bureau 1 Central 9 0 0 42 4 18 73 2 Rampart 2 0 0 35 4 23 64 4 Hollenbeck 0 0 0 28 4 7 39 11 Northeast 0 0 0 27 14 20 61 13 Newton 2 0 0 34 3 5 44 Total 13 0 0 166 29 73 281 South Bureau 3 Southwest 1 0 1 28 4 12 46 5 Harbor 0 0 0 41 4 9 54 12 Seventy-Seven 1 0 5 12 1 6 25 18 Southeast 0 0 0 27 0 8 35 Total 2 0 6 108 9 35 160 Valley Bureau 9 Van Nuys 0 0 0 38 34 14 86 10 West Valley 0 0 0 30 18 8 56 15 North Hollywood 0 0 0 43 31 10 84 16 Foothill 3 0 0 46 11 4 64 17 Devonshire 0 0 0 38 19 1 58 19 Mission 1 0 0 21 14 6 42 21 Topanga 1 0 0 17 11 2 31 Total 5 0 0 233 138 45 421 West Bureau 6 Hollywood 1 0 0 31 12 27 71 7 Wilshire 0 0 0 22 25 11 58 8 West Los Angeles 1 1 0 10 29 6 47 14 Pacific 1 0 0 33 10 12 56 20 Olympic 1 0 0 8 5 2 16 Total 4 1 0 104 81 58 248 All Bureaus Total Total 24 1 6 611 257 211 1,110

The type of hate crimes also varied somewhat by bureau and sub-bureau. The South Bureau, for example, had a particularly high proportion of racially motivated hate crimes (68 percent of recorded incidents in the bureau). In contrast, only 42 percent of the hate crimes in the West Bureau involved race-based hate crimes. Hate crimes involving sexual orientation were the most prevalent in the Central Bureau (26 percent) and least common in the Valley Bureau (11 percent). The Rampart (23 incidents) and Hollywood (27 incidents) sub-bureaus recorded the highest number of hate crimes involving sexual orientation. Religiously motivated hate crimes were also more likely to occur in the Valley (33 percent) and West (33 percent) Bureaus as opposed to the Central (10 percent) and South (six percent) Bureaus.

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Figure 5 illustrates the number and type of hate crimes committed in the City of Los Angeles by LAPD sub-bureaus between 2007 and 2011. During this time, religiously motivated hate crimes were most common in the North and South Valley, while race-based hate crimes made up the majority of hate crime incidents in Central and East Los Angeles. Hate crimes involving the sexual orientation of the victim were the most common in Central Los Angeles.

Figure 6 illustrates the concentration of hate crimes by LAPD area. This map takes into account the existing population of each LAPD sub-bureau to determine whether hate crimes were more likely to occur in certain areas of the City. Hate crimes were most prevalent in the Central, Hollywood, and Van Nuys sub-bureaus and least common in the 77th Street and Olympic sub- bureaus.

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Figure 5: Hate Crimes (2007-2011)

Source: LAPD, 2007-2011.

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Figure 6: Concentration of Hate Crimes by LAPD Area (2007-2011)

Source: LAPD, 2007-2011.

City of Los Angeles Page 26 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 C. Household Characteristics

Changes in household characteristics can help determine the need for housing and services in a community. The Census Bureau defines a household as all persons occupying a housing unit. Family households are those where the head of the household is related to one or more persons in the home by blood, adoption, or marriage; the Census Bureau defines any other household arrangement as non-family.

Certain segments of the population may have a more difficult time finding decent, affordable housing due to special circumstances. In Los Angeles, these “special needs” households include the large households, the elderly, single-parent households, persons with disabilities, persons living with HIV/AIDS, and the homeless. Table 5 summarizes the proportion of certain special needs households in various parts of the City.

Table 5: Special Needs Individuals and Households (2010) North South West South Central East LA Harbor Total Valley Valley LA LA Large Households 25.3% 12.3% 5.2% 8.8% 21.0% 28.1% 20.3% 16.0% Elderly Households 19.3% 18.7% 20.0% 15.8% 18.7% 17.4% 19.6% 18.0% Single-Parent Households 10.7% 8.6% 4.5% 7.2% 11.7% 18.8% 13.2% 10.1% Female-Headed Households with 7.3% 6.0% 3.2% 5.1% 8.4% 14.4% 9.4% 7.2% Children Persons with Disabilities ------9.3% Persons living with HIV/AIDS ------0.4% Homeless ------0.6% Notes: 1. Large household is one with five or more members. 2. Elderly household is one headed by an elderly person age 65 or over. 3. HIV/AIDs data for the County; City specific data not available. Source: Bureau of the Census, 2010.

Large Households

Many ethnic minority groups have a younger age profile and tend to have larger families than the White population. Having more children translates into a higher cost of living, need for larger homes, and increased vulnerability to housing discrimination.

Large households, defined as those with five or more persons, have special housing needs due to their income and the lack of adequately sized, affordable housing. To save for necessities such as food, clothing, and medical care, low and moderate income large households may reside in smaller units, resulting in overcrowding that tends to accelerate deterioration of the structure. Large households are also discriminated against in the housing market, particularly in the rental housing market. Some landlords and managers may be concerned with the potential increase in wear and tear, noise, and liability issues related to large households, especially those with children.

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The 2010 Census reported 213,959 large households in the City, representing 16 percent of all households (Table 5). The North Valley, East Los Angeles, South Los Angeles and Harbor NSAs had the highest proportions of large households, with approximately a quarter of all households in those NSAs having five or more persons. Furthermore, this special needs group experienced a higher level of housing problems than other households did (Table 6). According to Comprehensive Housing Affordability Strategy (CHAS) data calculated from information collected in the 2006-2008 American Community Survey, low and moderate income large households made up 63 percent of all large households, compared to 53 percent of total households. Of the City’s large households, over 80 percent experienced one more housing problems. Housing problems include overcrowding, cost burden, or substandard housing conditions. By contrast, 58 percent of the general population was experiencing housing problems (Table 6).

Table 6: Large Households: Low/Moderate Income and Housing Problems Percent of Low/Moderate Income Housing Problems Households Large Households 16% 63% 81% All Households 100% 53% 58% Notes: 1. Low/Moderate Income = households with incomes not exceeding 80 percent of the County Median Family Income (MFI) 2. “Housing Problems” include housing cost burden (paying more than 30 percent of household income on housing), overcrowding (more than one person per room, not counting bathroom, kitchen, or hallway), and inadequate housing (lacking complete kitchen or bathroom) Sources: Bureau of the Census, 2010; Department of Housing and Urban Development (HUD) Comprehensive Housing Affordability Strategy (CHAS), 2006-2008.

Elderly

One of the fastest growing segments of the population in the next 20 to 30 years is expected to be those aged 65 years and older. The aging of the “baby boomer” generation (currently in their middle ages) will increase the demand for a wider range of housing types. Elderly or senior households (householder 65 years or older) are also vulnerable to housing problems and discrimination. Due to limited income, prevalence of physical or mental disabilities (e.g. dementia), limited mobility, and high health care costs, seniors are considered a special needs group.

In a tight housing market, seniors, particularly the elderly with disabilities, can have difficulty in finding housing accommodations or face targeted evictions. The elderly and persons with disabilities are often targeted for eviction in order to circumvent rent stabilization laws and in order to bring in new tenants at higher rents. Many elderly have only limited incomes and cannot afford the rising market rents. Some landlords may also be concerned with the potential liability of frail elderly persons sustaining injuries on the property. A senior on a fixed income can face great difficulty finding safe and affordable housing or relocating after an eviction. Subsidized housing and federal housing assistance programs (such as the Housing Choice Voucher Program) are increasingly challenging to secure and often involve a long waiting list.

According to the 2010 Census, the City had 396,696 persons over the age of 65, representing about 11 percent of all residents citywide. Also, approximately 19 percent of all households

City of Los Angeles Page 28 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 were headed by an elderly person. Table 5 shows the proportion of elderly households in each NSA, with West Los Angeles having the highest proportion (20 percent). According to 2006- 2008 CHAS data, a higher proportion (58 percent) of seniors had low and moderate incomes compared to all residents (53 percent) (Table 7). In addition, approximately one-half of elderly residents experienced housing problems, such as cost burden or substandard housing.

Table 7: Elderly Households - Low/Moderate Income and Housing Problems Low/Moderate Percent of Households Housing Problems Income Elderly 19% 58% 50% All residents 100% 53% 58% Notes: 1. Low/Moderate Income = households with incomes not exceeding 80 percent of the County’s MFI 2. “Housing Problems” include housing cost burden (paying more than 30 percent of household income on housing), overcrowding (more than one person per room, not counting bathroom, kitchen, or hallway), and inadequate housing (lacking complete kitchen or bathroom) Sources: Bureau of the Census, 2010; Department of Housing and Urban Development (HUD) Comprehensive Housing Affordability Strategy (CHAS), 2006-2008.

In addition to affordable housing located near transportation, the housing needs of the elderly also include supportive housing, such as intermediate care facilities, group homes, and other housing that includes a planned service component. Approximately 175 state-licensed residential care facilities for seniors and 31 adult day care facilities serve the elderly population throughout the City. The elderly residential facilities have a combined capacity of 8,292 beds.

Single-Parent Households

Single-parent households are likely to have special needs for housing near day care and recreation facilities and to have access to public transportation. Households headed by females are especially likely to need assistance because women continue to earn less on average than men do in comparable jobs. Women in general are disproportionately responsible for household-supporting activities, such as trips to the grocery store or accompany young children to and from schools. Women reliant on public transit are often forced to look for employment near home that will allow them time to complete these household-sustaining trips.12 The factors discussed above may lead to comparatively limited housing choices for female-headed single- parent households.

In 2010, single-parent households accounted for 10 percent of City households and approximately 25 percent of all households with children under 18 years were headed by females. The area with the highest proportion of families with children under the age of 18 and of female-headed households with children is South Los Angeles (Table 5). Some landlords and managers are reluctant to rent to single-female parents, due to concerns about their ability to consistently pay rent and manage the children. According to statistics provided by the HRC, 19 percent of housing discrimination complaints was based on familial status.

12 Blumenberg, Evelyn. “Reverse Commute Transit Programs and Single Mothers on Welfare: A Policy Mismatch?” Institute of Transportation Studies, Volume 1, Number 2: December 2002.

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Persons with Disabilities

Both federal and California laws prohibit housing discrimination against persons with disabilities, including persons with HIV/AIDS. Under the federal Fair Housing Act, a disability, with respect to a person, is defined as:

. A physical or mental impairment which substantially limits one or more of such person's major life activities; . A record of having such an impairment; or . Being regarded as having such an impairment, but such term does not include current, illegal use of or addiction to a controlled substance.

The California Fair Employment and Housing Act provides protections independent from those in the federal law. Although the federal law provides a floor of protection, California law affords additional protections and contains broad definitions of physical disability, mental disability, and medical condition. In addition, the definitions of “physical disability” and “mental disability” under the California require a “limitation” upon a major life activity, but do not require a “substantial limitation” as under the federal law. This distinction is intended to result in broader coverage under the California law than under that federal law. Both federal and California laws offer protection for persons in recovery from substance abuse, as opposed to current users.

Fair housing choice for persons with disabilities can be compromised based on the nature of their disability. Persons with physical disabilities may face discrimination in the housing market because of the use of wheelchairs, need for home modifications to improve accessibility, or other forms of assistance. Landlords/owners sometimes fear that a unit may sustain wheelchair damage or may refuse to exempt disabled tenants with service/guide animals from a no-pet policy. Refusal to make such reasonable accommodations for persons with disabilities is a direct violation of fair housing laws.

A major barrier to housing for people with mental disabilities is opposition based on the stigma of mental disability. Landlords often refuse to rent to tenants with a history of mental illness. Neighbors object when a house becomes a group home for persons with mental disabilities. Often jurisdictions use special-permit requirements and other zoning restrictions to deny housing to people with (or perceived as having) a mental disability.

According to 2008-2010 American Community Survey data, 354,291 City residents had sensory, physical, mental, work, mobility, and/or self-care limitations, representing approximately nine percent of the City's population.13 Residents between the ages of 16 and 64 years represented the majority of persons with disabilities; however, approximately 40 percent of residents over age 65 had a disability. About 38 percent of persons with disabilities reported having cognitive difficulties, while 56 percent reported having ambulatory difficulties.

13 The five year ACS estimates for 2006-2010 did not provide disability data and therefore the three year ACS estimates for 2006-2008 were used.

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Persons with disabilities are overrepresented in the homeless population. The Los Angeles Homeless Services Authority (LAHSA) conducted a homeless count in Los Angeles County (excluding Glendale, Long Beach, and Pasadena) in January 2011. The count located 23,539 homeless persons within the City of Los Angeles, which represents a nine-percent decrease from the previous count in 2009. Approximately 12,977 (55 percent) were unsheltered, and 10,562 people (45 percent) were living in either emergency shelters or transitional housing programs at the time of the census. About 21 percent of the homeless population in the City of Los Angeles had a physical disability and 35 percent were mentally ill.

Given the prevalence of disabilities among the homeless people, the need for emergency shelters and transitional or supportive housing is evident. A continuum of housing options for this special group is needed, ranging from short-term emergency shelters, transitional housing, supportive housing, to permanent housing. Specifically, housing that connects to substance abuse treatment programs and other supportive services is needed. Addressing the provision of such housing will help mitigate the impediment to decent housing for disabled homeless people.

Persons with physical, mental, and developmental disabilities often require special housing to accommodate their special conditions. For many who are physically disabled, features such as handrails, ramps, wider doorways, specially designed cabinetry and electrical outlets, special door and faucet handles, and non-skid flooring are necessary. The Fair Housing Amendment Act of 1988, which was signed into law on September 13, 1988 and became effective on March 12, 1989, requires that a portion of the dwellings within new multi-family housing developments with four or more units be designed and built to allow access for persons with disabilities. However, over 90 percent of the City’s rental housing stock was built prior to 1990 and therefore may not be accessible to persons with disabilities.

Furthermore, pursuant to Section 504 of the Rehabilitation Act of 1973, each Area Housing Authority is required to assess its public housing stock for handicap accessibility. Section 504 requires five percent of the units in a public housing project be accessible to the mobility impaired and two percent of the units be accessible to the visually/hearing impaired. On an ongoing basis, the Area Housing Authorities utilize funding from the HUD Comprehensive Grant Program to complete the required modifications in compliance with ADA.

Persons Living with HIV/AIDS

Persons living with HIV/AIDS face an array of barriers to obtaining and maintaining affordable, stable housing. For persons living with HIV/AIDS, access to safe, affordable housing is as important to their general health and well-being as access to quality health care. For many, the persistent shortage of stable housing is the primary barrier to consistent medical care and treatment. Despite federal and state anti-discrimination laws, many people face illegal eviction from their homes when their illness is exposed.

There were a total of 42,364 persons living with HIV/AIDS in Los Angeles County as of December 31, 2010. The number of persons living with HIV/AIDS in the County has increased steadily since 2006. Males currently represent about seven out of eight (87 percent) persons living with HIV/AIDS in Los Angeles County. Over two-thirds (70 percent) of persons living

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 31 Public Review Draft May 30, 2012 with HIV/AIDS are 40 years or older, the majority of whom are age 40 to 49 years. About 39 percent of persons living with HIV/AIDS in the County are Latino, 35 percent White, 21 percent Black, and three percent Asian/Pacific Islander.

Severe HIV Disease is also known as Acquired Immunodeficiency Syndrome, or AIDS. The annual number of AIDS diagnoses in the County has decreased substantially from a high of approximately 4,131 cases in 1992 to 1,396 cases in 2006, according to the 2010 Annual HIV Surveillance Report. The annual number of AIDS cases decreased for all races/ethnicities in the last 10 years. The most dramatic decreases were among Blacks, whose annual total dropped 38 percent from 454 cases in 1999 to 310 cases in 2008. White cases decreased 37 percent, from 540 in 1999 to 382 in 2008. The number of cases among Latinos decreased 33 percent, from 763 in 1999 to 514 in 2008.

Housing resources for persons living with HIV/AIDS is an important component of consistent medical care and treatment. An estimated one-third to one-half of persons living with AIDS in the United States are either homeless or at imminent risk of homelessness. In Los Angeles, different types of housing are available to low income persons living with HIV/AIDS, each with varying lengths of stay and levels of service, ranging from emergency shelter to permanent, independent housing. As of 2003, a total of 3,401 units or beds, through facility- based housing and housing assistance programs, are available to persons living with HIV/AIDS in Los Angeles County.14 In the 2002 Needs Assessment Survey, 19 percent of persons living with HIV/AIDS who were diagnosed after 1999 were homeless and 37 percent were in some form of transitional living situation. Shelter Partnership’s study of persons living with HIV/AIDS in the City and County of Los Angeles found that 65 percent of survey respondents had been homeless at some point in their lives. For respondents who had reported being homeless at one point in time, nearly half (46 percent) were currently homeless. Moreover, up to 50 percent of the respondents who were not currently homeless believed that they were at imminent risk of becoming homeless.

Homeless

HUD has clarified that fair housing laws cover emergency shelters. The limited supply and high costs of housing exacerbate the problem of homelessness. Formerly homeless persons have a very difficult time finding permanent housing to move to from transitional housing or other assistance program. Housing affordability for those who are or were formerly homeless is challenging from an economic standpoint, but this group may also encounter fair housing issues when rental property owners have concerns about formerly homeless persons as economically (and sometimes mentally) unstable. These difficulties are more severe for homeless families that need larger affordable units.

The National Coalition for the Homeless found that poverty and the lack of affordable housing are the principal causes of homelessness among families.15 A 2003 Economic Roundtable study commissioned by the Los Angeles Homeless Services Authority (LAHSA) indicated that the

14 Information based on the 2003 Strategic Plan for Providing HIV/AIDS Housing with Supportive Services in Los Angeles County. A more recent Strategic Plan was unavailable. 15 National Coalition for the Homeless, 2002.

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City’s homeless rate was higher than most U.S. cities because of the pervasiveness of poverty and the high cost of housing.16

The 2011 Greater Los Angeles Homeless Count, the nation’s largest count of homeless individuals and families, took place from January 25-27, 2011. The homeless census covered more than 4,000 square miles and included all of Los Angeles County, except the cities of Glendale, Pasadena and Long Beach, which conducted their own homeless counts. In the City of Los Angeles in January 2011 there were an estimated 23,539 homeless persons, which represents a nine percent decrease from the prior count in 2009. This significant difference can be attributed to the resources the City of Los Angeles has dedicated to homelessness.17

Nearly one-quarter (24 percent) of the homeless population were chronically homeless single adults. Of the chronically homeless survey respondents, there was an increase in mental illness and a decrease in substance abuse. The stressors associated with a tough economy may exacerbate mental illness and increase the rate among already vulnerable homeless populations. More specifically, many individuals may lose their ability to pay for and maintain critical prescription interventions that stabilize the disabling condition of mental illness. Additionally, the chronic homeless population in Los Angeles has aged. Persons aged 55 and older made up 34 percent of the chronic homeless population in 2011, compared to 20 percent in 2009. At the time of the homeless census, about 18 percent of the homeless in Los Angeles were veterans; a three- percent increase from the 2009 count. In addition, there was a six-percent decrease in family homelessness since 2009.

Of the Los Angeles Continuum of Care (CoC) homeless population, 28,540 (or 63 percent) persons were unsheltered and 16,882 (or 37 percent) persons were sheltered. In addition to counting homeless persons living in shelters and on the streets, LAHSA also conducts an enumeration of persons living in institutions such as local and County jails, hospital emergency rooms and beds, and residential alcohol and drug treatment programs who would be homeless if they were not residing in one of these programs. The 2011 count found 6,069 persons residing in institutions, which is a one percent decrease from the last time LAHSA conducted a similar count of institutions in 2007. As of the beginning of 2012, HUD requires all CoCs to conduct an annual sheltered point-in-time (PIT) count. The count is to be performed during the last ten days in January 2012 and include population and subpopulation data. HUD will continue to require an unsheltered count biennially.

According to LAHSA, given the high unemployment and foreclosure levels over the past few years, as well as the increase in national poverty, there was concern that homelessness would rise. However, despite the tough economy, there was a slight decrease in homelessness in the Los Angeles Continuum of Care (LA CoC). Overall, the homeless population in the LA CoC area decreased three percent between 2009 and 2011, and the homeless population in the City of Los Angeles decreased nine percent during the same period. This is largely because social service agencies, housing departments and federally funded programs like the Homelessness Prevention and Rapid Re-Housing Program have effectively helped those who are homeless

16 http://www.thegivingspirit.org/data/resources/File/news/JusttheFactsHomelessnessLA.pdf 17 2011 Greater Los Angeles Homeless Count Report

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 33 Public Review Draft May 30, 2012 move into housing and get back on their feet.18 Specifically, the City attributed this decrease to resources that have been dedicated to reducing homelessness, such as setting aside 10 percent of Housing Choice Vouchers for homeless households, committing to the construction of 2,200 permanent supportive housing units, and supporting CDBG funding on homeless services.

D. Housing Characteristics

Household characteristics (seniors, large households, families with children) described in previous sections strongly influence housing preferences and needs. For instance, single-person households often occupy smaller apartments or condominiums, such as one-bedroom units. Married couples often prefer larger single-family homes, particularly if they have children. These patterns underscore the need to provide a diversity of housing types that allow different households the opportunity to live in the City. Table 8 describes characteristics of the housing stock in Los Angeles.

Table 8: Housing Characteristics North South West LA Central East LA South LA Harbor Total Valley Valley Housing Units 2000 196,974 276,242 183,820 276,827 128,654 213,209 65,977 1,343,703 2010 212,123 293,247 198,165 303,763 135,367 217,414 69,899 1,431,988 % Change 7.7% 6.2% 7.8% 9.7% 5.2% 2.0% 5.9% 6.6% Housing Type Single-Family 67.2% 48.4% 37.9% 17.7% 58.4% 55.1% 53.2% 45.6% Multi-Family 30.1% 51.3% 61.8% 82.1% 41.1% 44.3% 44.4% 53.6% Other 2.7% 0.3% 0.3% 0.2% 0.5% 0.4% 2.4% 0.8% Tenure Owner 59.4% 45.3% 42.8% 16.8% 38.1% 32.4% 43.5% 38.4% Renter 40.6% 54.7% 57.2% 83.2% 61.9% 67.6% 56.5% 61.6% Sources: Bureau of the Census, 2000-2010; American Community Survey (ACS), 2006-2010.

1. Housing Growth

In comparing Table 8 (Housing Characteristics on page 34) and Table 1 (Population Growth by Area on page 9), it can be seen that housing production in the City outpaced population growth in every NSA except South LA. At the City level, the population grew three percent between 2000 and 2010 while housing units increased by seven percent.

2. Tenure (Owner versus Renter)

Tenure is primarily related to household income and composition, and age of the householder. Table 8 shows that, except for in the North Valley area, most households in the City are renters.

18 Los Angeles Homeless Services Authority (LAHSA), “Homelessness Rate in Los Angeles Declines Despite Tough Economy”, press release, June 14, 2011.

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Citywide, 62 percent of households rented their homes. In the Central area, due to the high proportion of rental housing in and around downtown, that figure jumps to 83 percent.

Tenure in Los Angeles is closely related to the cost of land and the supply of available single- family housing. Less than one-half (46 percent) of the City’s housing stock is comprised of single-family housing; the majority is multi-family housing.

According to the 2010 Census, ethnic minorities in Los Angeles have not achieved homeownership as readily as the White population. Census figures indicate that homeownership rates for Blacks (29 percent), Hispanics (29 percent) and Asians (36 percent) were much lower than for Whites (50 percent).

Minority households are more reliant on rental housing for accommodation and may be disproportionately impacted by fair housing issues in the rental market.

3. Housing Costs and Affordability

Many housing problems such as overpayment or overcrowding are directly related to the cost of housing in a community. If housing costs are high relative to household income, a correspondingly high prevalence of housing problems occurs. This section evaluates the affordability of the housing stock in Los Angeles to lower and moderate income households.

Housing affordability alone is not necessarily a fair housing issue. Only when housing affordability issues interact with other factors covered under fair housing laws, such as household type, composition, and race/ethnicity do fair housing concerns arise.

Ownership Housing Costs

Like with most jurisdictions in the State of California, the City of Los Angeles experienced sharp declines in its median home prices during the peak of the housing crisis which started in 2007. For the most part, home prices in the City have leveled out; however, overall home prices in the City are still decreasing. The City’s median home price in 2011 was $300,000, a six percent decrease from the year before and 12 percent below the $340,000 reported in 2004. It should be noted, though, that home prices varied considerably depending on the location within the City. Table 9 shows the change in housing prices in specific areas of the City. Despite the decreases, home prices in Los Angeles place homeownership out of reach for most low and moderate income households.

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Table 9: Median Home Prices for Selected Areas Single-Family Homes Condominiums Area Median % Change Price/ Median % Change # Sold # Sold Price from 2010 Sq. Ft. Price from 2010 90003 287 $150,000 5.3% $141 0 n/a n/a 90016 219 $261,000 -6.8% $208 50 $176,000 -10.8% South Los 90018 171 $245,000 -2.0% $175 4 $309,000 108.8% Angeles 90037 180 $190,000 1.1% $137 1 $320,000 0.0% 90047 503 $215,000 -2.3% $173 0 n/a n/a 90062 179 $199,000 -0.5% $150 0 n/a n/a 90004 121 $850,000 3.0% $445 46 $400,000 3.9% 90006 44 $320,000 0.5% $185 29 $278,000 -22.9% 90010 0 n/a n/a n/a 23 $420,000 -17.6% 90015 12 $265,000 -8.6% $161 108 $359,000 -7.9% Central Los 90019 187 $480,000 -9.4% $274 22 $320,000 0.0% Angeles 90020 34 $1,900 -28.0% $404 88 $210,000 -16.0% 90027 171 $940,000 -0.3% $484 51 $307,000 -5.0% 90029 32 $320,000 -14.1% $264 7 $290,000 -42.6% 90036 99 $950,000 -4.3% $463 17 $395,000 -16.8% 90057 11 $350,000 30.8% $187 27 $180,000 -3.7% 90011 260 $155,000 -0.3% $134 0 n/a n/a 90012 7 $350,000 -1.7% $241 113 $265,000 -9.7% East Los 90023 92 $175,000 11.5% $175 0 n/a n/a Angeles 90039 179 $520,000 -2.8% $445 23 $360,000 -8.9% 90063 162 $175,000 -5.4% $166 0 n/a n/a West Los 90034 145 $628,000 -8.4% $437 39 $377,000 -6.9% Angeles 90035 121 $875,000 -2.0% $477 57 $445,000 -10.6% Source: DQNews, 2012.

Rental Housing Costs

Given the high costs of homeownership in the City, low and moderate income households are usually confined to the rental housing market. Yet the problem of affordability also persists in the rental market. The 2006-2010 American Community Survey indicated that the median gross rent in Los Angeles was $1,077, representing a 60-percent increase since 2000.

The City of Los Angeles Housing Department conducted its own rent survey in 2007, using a sample of 4,859 randomly selected renter-occupied units of various household sizes. Of the housing units included in this survey, the average size was 3.48 persons and the median size was 3.00 persons. These renters completed a telephone-based questionnaire that provided information about their attitudes, finances, and experiences as home renters. The telephone survey was conducted by the Social Science Research Center (SSRC) at California State University, Fullerton, using computer-assisted telephone interviewing. The survey began in September 2007 and ended in April 2008.

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According to the results of this survey, the average and median monthly rent reported by Los Angeles renters in the survey were $951 and $850, respectively. Average and median monthly rents across the seven NSAs, shown in Table 10, were similar with the highest rents found in West Los Angeles and the lowest rents in East and South Los Angeles.

Table 10: Average and Monthly Rent (2008) NSA Average Rent Median Rent North Valley $1,006 $900 South Valley $1,070 $975 West Los Angeles $1,384 $1,250 Central Los Angeles $900 $815 East Los Angeles $850 $765 South Los Angeles $834 $776 Harbor $928 $875 City of Los Angeles $951 $850 Source: City of Los Angeles RSO Study, 2008.

The survey also uncovered the following observations:

. Over a quarter of West Los Angeles renters paid $1,600 or more per month for rent and over two-thirds paid $1,000 or more. . South Los Angeles had the largest share of units renting for less than $600; 30 percent of renters paid less than $600 for rent, and a majority of renters paid less than $800 for rent. . A majority of renters in the North Valley and South Valley paid less than a $1,000 for rent. . The South Valley had the second largest share (45 percent) of renters, behind West Los Angeles, paying $1,000 or more for rent. . At a little over 75 percent, East Los Angeles had the largest share of renters paying less than $1,000 for rent. . Two-thirds of renters in the Harbor region paid less than $1,000 for rent. . Rent was evenly distributed across four categories in Central Los Angeles. Rent paid by about a quarter of renters fell into each of the following categories: less than $600, $600 to $799, $800 to $999, and $1000 or more.

Housing Affordability

Housing affordability can be estimated by comparing the cost of renting or owning a home with the maximum affordable housing costs to households at different income levels. Taken together, this information can generally indicate the size and type of housing available to each income group and can indicate which households are more susceptible to overcrowding and cost burden.

HUD conducts annual household income surveys to determine the maximum payments that are affordable for different household income groups. In evaluating affordability, the maximum affordable price refers to the maximum amount that could be afforded by households in the

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 37 Public Review Draft May 30, 2012 upper range of their respective income categories. Table 11 shows annual household income by household size. The maximum affordable housing payment is based on the standard of 30 to 35 percent of gross household income (the former for renters and latter for homeowners). General cost assumptions for utilities, taxes, and property insurance are also shown.

When comparing the maximum affordable rents and home prices presented in this table with the market conditions, some general conclusions about housing affordability can be made. The citywide median home price ($300,000) in 2011 places homeownership out of reach for Los Angeles’ lower and moderate income households. The affordability problem also persists in the rental market. Most appropriately-sized rental housing in Los Angeles is also unaffordable for the City’s lower income households. The situation is exacerbated for large households with lower and moderate incomes given the limited supply of large units, and for seniors with their fixed incomes.

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Table 11: Housing Affordability Matrix – Los Angeles County (2012) Annual Affordable Costs Utilities Taxes and Affordable Affordable Household Income Rental Ownership Renters Owners Insurance Rent Home Price Extremely Low Income (under 30% MFI) 1-Person $17,750 $444 $444 $71 $112 $89 $373 $42,717 2-Person $20,250 $506 $506 $79 $141 $101 $427 $46,409 3-Person $22,800 $570 $570 $90 $174 $114 $480 $49,573 4-Person $25,300 $633 $633 $99 $205 $127 $534 $52,913 5-Person $27,350 $684 $684 $114 $252 $137 $570 $51,858 Low Income (30 to 50% MFI) 1-Person $29,550 $739 $739 $71 $112 $148 $668 $ 84,203 2-Person $33,750 $844 $844 $79 $141 $169 $765 $ 93,872 3-Person $37,950 $949 $949 $90 $174 $190 $859 $102,837 4-Person $42,150 $1,054 $1,054 $99 $205 $211 $955 $112,154 5-Person $45,550 $1,139 $1,139 $114 $252 $228 $1,025 $115,845 Moderate Income (50 to 80% MFI) 1-Person $47,250 $1,181 $1,181 $71 $112 $236 $1,110 $146,433 2-Person $54,000 $1,350 $1,350 $79 $141 $270 $1,271 $165,067 3-Person $60,750 $1,519 $1,519 $90 $174 $304 $1,429 $182,997 4-Person $67,450 $1,686 $1,686 $99 $205 $337 $1,587 $201,104 5-Person $72,850 $1,821 $1,821 $114 $252 $364 $1,707 $211,827 Middle Income (100 to 120% MFI) 1-Person $54,450 $1,361 $1,588 $71 $112 $318 $1,290 $203,652 2-Person $62,200 $1,555 $1,814 $79 $141 $363 $1,476 $230,343 3-Person $70,000 $1,750 $2,042 $90 $174 $408 $1,660 $256,536 4-Person $77,750 $1,944 $2,268 $99 $205 $454 $1,845 $282,875 5-Person $83,950 $2,099 $2,449 $114 $252 $490 $1,985 $300,044 Assumptions: 1. California Department of Housing and Community Development (HCD) income limits, 2012. 2. Health and Safety code definitions of affordable housing costs (between 30 and 35 percent of household income depending on tenure and income level). 3. HUD utility allowances. 4. 20 percent of monthly affordable cost for taxes and insurance. 5. 10 percent down payment. 6. Five percent interest rate for a 30-year fixed-rate mortgage loan. 7. Taxes and insurance apply to owner costs only; renters do not usually pay taxes or insurance. Sources: HCD Income Limits, 2012; Veronica Tam and Associates.

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 39 Public Review Draft May 30, 2012 E. Housing Problems

A continuing priority of the City is enhancing or maintaining the quality of life for residents. A key measure of quality of life in Los Angeles is the extent of “housing problems.” The Department of Housing and Urban Development (HUD) assesses housing needs according to two criteria: (1) the number of households that are paying too much for housing; and (2) the number of households living in substandard and overcrowded units.

Combined, housing problems (cost burden, overcrowding, and inadequate housing) affected 58 percent of all households in Los Angeles (Table 12) between 2006 and 2008, according to the Comprehensive Housing Affordability Strategy (CHAS) data developed by the Census Bureau for HUD. However, housing problems affected large and renter-households more significantly than any other type of households. Specifically, 63 percent of the elderly renter-households and 90 percent of the large renter-households experienced housing problems.

Table 12: Housing Problems by Household Characteristic (2006-2008) All Households

Total Elderly Large Renters 63% 63% 90% Owners 50% 41% 70% Total 58% 28% 81% Source: Comprehensive Housing Affordability Strategy (CHAS) data, HUD, 2006-2008. Note: “Housing Problems” include housing cost burden (paying more than 30 percent of household income on housing), overcrowding (more than one person per room, not counting bathroom, kitchen, or hallway), and inadequate housing (lacking complete kitchen or bathroom)

1. Housing Cost Burden

State and federal standards specify that households experience housing cost burden if they pay more than 30 percent of their gross household income on housing. Between 2006 and 2010, 53 percent of all households experienced housing cost burden. By tenure, 56 percent of renters experienced housing cost burden, compared to 49 percent of homeowners. Among the NSAs, South Los Angeles had a significantly higher proportion of households who experienced housing cost burden (Table 13).

Table 13: Housing Cost Burden (2006-2010) North Valley South Valley West LA Central East LA South LA Harbor Total Renters 58.3% 55.2% 48.3% 54.1% 52.8% 63.5% 54.7% 55.5% Owners 51.6% 48.7% 42.2% 48.8% 45.9% 59.5% 46.0% 49.4% Total 54.2% 52.1% 45.7% 53.2% 50.2% 62.2% 50.8% 53.1% Note: Cost burden is defined as a household spending more than 30 percent of its gross household income on housing costs, including utilities, taxes, and insurance. Source: American Community Survey (ACS), 2006-2010.

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2. Overcrowding

Some households may not be able to accommodate high cost burdens for housing, but may instead accept smaller housing or reside with other individuals or families in the same home. Potential fair housing issues emerge if non-traditional households are discouraged or denied housing due to a perception of overcrowding.

General federal and state guidelines defines “overcrowding” as a housing unit being occupied by more members than habitable rooms in the unit (e.g., a three-person family may live in an apartment with one bedroom and a living room and be considered “overcrowded”). Moderate overcrowding refers to 1.0 to 1.5 persons per habitable room and severe overcrowding occurs when a home has 1.5 or more occupants per habitable room. Household overcrowding is reflective of various living situations: (1) a family lives in a home that is too small; (2) a family chooses to house extended family members; (3) the inability to afford a larger home; or (4) unrelated individuals or families are doubling up to afford housing.

Overall, 14 percent of households in the City were overcrowded, with renters experiencing more than three times the incidence of overcrowding as homeowners (Table 14). Among the seven NSAs, areas with high proportions of minority and low/moderate income populations (North Valley, Central, East Los Angeles, South Los Angeles and Harbor) had higher levels of overcrowding.

Table 14: Overcrowding and Severe Overcrowding (2006-2010) North South West LA Central East LA South LA Harbor Total Valley Valley Overcrowding Renter 23.2% 14.2% 5.3% 20.8% 23.7% 25.4% 22.4% 19.0% Owner 7.2% 3.2% 0.9% 3.2% 8.6% 13.2% 6.6% 5.8% Total 13.5% 9.1% 3.4% 17.8% 17.9% 21.4% 15.4% 13.8% Severe Overcrowding Renter 8.71% 6.04% 2.30% 13.56% 11.10% 13.17% 9.09% 9.79% Owner 1.48% 0.62% 0.24% 0.96% 2.30% 3.67% 1.42% 1.39% Total 4.30% 3.52% 1.40% 11.43% 7.76% 10.06% 5.69% 6.50% Source: American Community Survey (ACS), 2006-2010.

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3. Housing Condition

The most typical type of disputes between landlords and tenants relates to repair. Tenant/landlord disputes are not fair housing issues per se. However, if landlords are not providing maintenance and repairs in an equitable manner, and certain groups protected by fair housing laws are being disproportionately refused repairs, fair housing concerns may arise.

Housing Age

The age of housing is commonly used by state and federal housing programs as a factor to estimate the condition of housing stock. Typically, most homes begin to require major repairs or rehabilitation at 30 or 40 years of age. Approximately 80 percent of homes in the City were 30 years or older as of 2010 (Table 15). This proportion was significantly higher in areas such as East Los Angeles (84 percent) and South Los Angeles (87 percent).

Table 15: Age of Housing (2010) North South South West LA Central East LA Harbor Total Valley Valley LA % Housing Units >30 75.1% 76.8% 75.4% 79.9% 84.3% 87.2% 78.9% 79.5% Years of Age Source: Estimated by Veronica Tam and Associates based on 2000 and 2010 Census data.

Lead-Based Paint

Lead-Based Paint Hazards The age of the housing stock is the key variable for estimating the number of housing units with lead-based paint. Starting in 1978, the use of all lead-based paint on residential property was prohibited. National studies estimated that 75 percent of all residential structures built prior to 1978 contain lead-based paint (LBP) and that older structures have the highest percentage of LBP. In Los Angeles, about 80 percent of housing was built prior to 1980 and thus, household lead exposure is a major concern for the City.

Lead poisoning is a leading environmental hazard to children in America. Lead’s health effects are devastating and irreversible. Lead poisoning causes IQ reductions, reading and learning disabilities, decreased attention span, and hyperactivity and aggressive behavior. The National Institute of Environmental Health Science found that delinquent children - both White and Black - have higher blood lead levels than children from similar backgrounds without a criminal history.

Several factors contribute to higher incidences of lead poisoning:

. Low income children are at a risk eight times higher than children from wealthy families; . Black children have a risk five times higher than White children; . Hispanic children are twice as likely as White children to have lead poisoning due to the likelihood of living in older neighborhoods with deferred maintenance issues; . Children in older housing are at higher risk; and

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. Up to 50 percent of children in some distressed neighborhoods have some level of lead poisoning.

Figure 7 illustrates the high risk lead hazard areas by census tract in the City of Los Angeles based on the following three factors:

. Above City average of minority population (more than 71.3 percent minority population); . Above City average of young children under six years of age (more than 6.6 percent population); and . Above City average of older housing units (more than 79.4 percent of pre-1979 housing units).

As shown, these high risk areas are concentrated in the Central and South Los Angeles areas where there are also high numbers of lead-poisoning cases.

Both the Los Angeles Housing Department (LAHD) and the Housing Authority of the City of Los Angeles (HACLA) play a major role in evaluation and reduction of lead-based paint hazards, which is described in Chapter 6.

A HUD study conducted by David E. Jacobs, et al, found that 1.2 million housing units (five percent) nationwide with significant lead-based paint hazards were occupied by low income families with children under age six.19 There are 1.4 million housing units in the City of Los Angeles, of which about 1.1 million units were built before 1980. These units make up 80 percent of all housing units in the City. If the findings of the Jacobs study accurately reflect conditions in Los Angeles, then about 40 percent of those units, or 450,000 units, contain lead- based paint and about 25 percent or 280,000 units are likely to have significant lead-based paint hazards. Of those 280,000 units, five percent or about 14,000 units are likely to be occupied by low income families with children under age six. Table 16 below summarizes the number of defined lead poisoning cases in the City of Los Angeles from 2006 to 2010.

Table 16: Defined Lead Poisoning Cases (2006-2010) Age 2006 2007 2008 2009 2010 Total Childhood Cases 0-2 84 64 52 57 65 322 3-5 31 19 24 15 22 111 6-15 11 8 5 4 10 38 16-20 13 17 18 11 5 64 Total 139 108 99 87 102 535 Source: Los Angeles County Dept. of Health Services, 2010.

19 David E. Jacobs, Robert P. Clickner, Joey Y. Zhou, Susan M. Viet, David A. Marker, John W. Rogers, Darryl C. Zeldin, Pamela Broene, and Warren Friedman. “The Prevalence of Lead-Based Paint in U.S. Housing.” Environmental Health Perspectives, October 2002.

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Figure 7: High-Risk Lead Hazard Areas

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Given inadequate funding for lead hazard control compared to the need, the most efficient protection against lead poisoning is a building code inspection process that addresses lead- based paint hazards, and requires mitigation through paint stabilization and lead safe repair work. Since 2004, LAHD’s Systematic Code Enforcement Program (SCEP) has implemented a “lead-safe work practices program” designed by the local Healthy Homes Collaborative, comprised of 40 community-based and government agencies. Preparations were being made in 2009-2010 to get ready for the Environmental Protection Agency’s new Renovation, Repair and Painting Rule, which became effective in April 2010.

F. Income and Employment

1. Household Income

While economic factors that affect a household’s housing choice are not a fair housing issue per se, the relationships among household income, household type, race/ethnicity, and other factors often create misconceptions and biases that raise fair housing concerns.

For purposes of most housing and community development activities, HUD has established the four income categories based on the Median Family Income (MFI) for the Metropolitan Statistical Area (MSA). HUD income definitions differ from the State of California income definitions. Table 17 compares the HUD and State income categories. This AI report is a HUD- mandated study and therefore HUD income definitions are used. For other housing documents of the City, the State income definitions may be used, depending on the housing programs and funding sources in question.

Table 17: Income Categories HUD Definition State of California Definition Extremely Low Income Less than 30 percent of MFI Extremely Low Income Less than 30 percent of MFI Low Income 31-50 percent of MFI Very Low Income 31-50 percent of MFI Moderate Income 51-80 percent of MFI Low Income 51-80 percent of MFI Middle/Upper Income Greater than 80 percent of MFI Moderate Income 81-120 percent of MFI Above Moderate Income Greater than 120 percent of MFI Sources: Department of Housing and Urban Development and California Department of Housing and Community Development.

2. Income Distribution

The median household income for the City of Los Angeles between 2006 and 2010 was $49,138. Figure 8 shows the income distribution for the City, which is skewed toward the lower end of the income range. Figure 9 overlays the areas with minority population concentrations with areas considered low and moderate income areas according to HUD guidelines. The figure reflects a high correlation between low income and minority concentrations.

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Figure 8: Income Distribution (2010) 30.0%

25.0%

20.0%

15.0%

10.0%

5.0%

0.0% Less than $15,000- $25,000 - $35,000- $50,000- $100,000+ $14,999 $24,999 $34,999 $49,999 $99,000 LA City 14.7% 11.9% 10.7% 13.4% 27.2% 22.1%

Source: American Community Survey, 2006-2010.

According to the Comprehensive Housing Affordability Strategy (CHAS), 53 percent of households in Los Angeles earned less than 80 percent of the MFI between 2006 and 2008 (Table 18). About 20 percent of the City’s total households during that time were extremely low income (under 30 percent MFI), 16 percent were low income, (31-50 percent MFI), and 18 percent earned moderate income levels (51-80 percent MFI). Approximately 47 percent of the households had incomes above 80 percent of the median between 2006 and 2008.

Los Angeles saw significant changes in the income distribution of residents during the previous decade. Between 2000 and 2008, there was a 14-percent decline in the number of moderate and above moderate income households and significant increases in the proportion of extremely low income households and low income households.

Table 18: Household Income Distribution (2000 and 2006-2008) 2000 2006-2008 Change Classification Number of Percent of Households % Households % Households Households Extremely Low Income 209,341 16.4% 253,340 19.9% 43,999 21.0% Low Income 162,858 12.8% 197,690 15.5% 34,832 21.4% Moderate Income 208,778 16.4% 225,445 17.7% 16,667 8.0% Middle/Above Moderate 694,085 54.4% 599,050 47.0% -95,035 -13.7% Total 1,275,062 100% 1,275,525 100% 463 0.0% Sources: Comprehensive Housing Affordability Strategy (CHAS), 2000; Comprehensive Housing Affordability Strategy (CHAS), 2006-2008.

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Figure 9: Low and Moderate Income Areas and Minority Population Concentrations

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3. Income Distribution by Household Type

According to housing advocates, seniors and large families often face discrimination in the rental housing market. Coupled with lower incomes, these households have limited housing choices.

Income often varies by household type (elderly, small, and large families). Certain groups had a higher proportion of lower income households. Specifically, elderly households had a much higher percentage of lower income households than any other household type between 2006 and 2008. Approximately 62 percent of elderly households were lower and moderate income; about 47 percent earned less than 50 percent of the MFI (Table 19). In particular, elderly renters comprised the largest proportion of lower income households.

Another special needs group in Los Angeles is large family households. This group also had a noticeably higher percentage of lower and moderate income households between 2006 and 2008 (63 percent) when compared to the City average (53 percent). Large family renter-households had a higher proportion of lower and moderate income households compared to the citywide average. Approximately 81 percent of large renter-families were lower and moderate income, while 41 percent of large owner-households were in this income group (Table 19).

Table 19: Income by Household Type (2006-2008) Income Group (% of MFI) Extremely Middle/ Household Type Low Moderate Low Upper Total (31-50%) (51-80%) (0-30%) (81%+) Elderly (62+ years) 29.7% 17.6% 15.1% 37.7% 100.0% Small Family (2-4 persons) 16.2% 15.2% 17.2% 51.4% 100.0% Large Family (5+ persons) 18.1% 20.1% 24.4% 37.4% 100.0% Other 19.3% 12.7% 17.3% 50.7% 100.0% Total 19.9% 15.5% 17.7% 47.0% 100.0% Source: HUD CHAS Data, 2006-2008.

4. Employment

A major factor in income levels is the type of occupation that residents are employed in. Los Angeles is a major trade, manufacturing, and distribution center for the U.S., the Pacific Rim, and the world. Its leading economic sectors include shipping, manufacturing, communications, finance, and fashion. The Port of Los Angeles is among the busiest in the country and the City is a center for advanced industries, notably high technology and information-related industries. It is also the world capital of the motion picture, television, radio, and recording industries. However, Downtown Los Angeles, which still has a concentration of jobs, is being surpassed by areas such as the San Fernando Valley, the Westside along Wilshire Boulevard, the South Bay (El Segundo, Torrance and Long Beach), and the northern San Gabriel Valley, particularly Pasadena.

Northrop Grumman, with approximately 117,100 employees, is the largest employer in the City. Major employers in the City also include Gores Group, AECOM, and CBRE Group (Table 20).

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Combined, sales and office occupations comprised about one-quarter of all employees in the Los Angeles area. The lowest paid occupations (service, sales/office, farming, and production/transportation) accounted for over half of all employment in the City (Table 21).

Figure 10 shows the distribution of major employers (over 500 employees) in the City in relation to low and moderate income population and transit lines. A concentration of employers can be found in Downtown Los Angeles. Major employers can also be found in the Westside along Wilshire Boulevard and the area near LAX. South and East Los Angeles, as well as the eastern portions of San Fernando Valley have concentrations of low and moderate income residents and a lack of employers that offer large number of job opportunities. In other parts of the County, the South Bay (El Segundo, Torrance and Long Beach), Burbank, Glendale and the northern San Gabriel Valley, particularly Pasadena, are developing into important employment centers, offering residents additional job opportunities but a farther commute.

Table 20: Top 25 Employers in Los Angeles (2012) Company Name Location Employees Description Northrop Grumman Corporation Los Angeles 117,100 Shipbuilder and Repair Gores Group LLC Los Angeles 84,000 Video Production and Taping AECOM Technology Corporation Los Angeles 45,000 Engineers (Consulting) CBRE Group Inc. Los Angeles 31,000 Real Estate Management Farmers Insurance Group Los Angeles 17,000 Insurance Guess? Inc. Los Angeles 15,000 Clothing (Retail) California Pizza Kitchen Los Angeles 14,000 Restaurant Management University of Southern California Los Angeles 11,400 University American Apparel Inc. Los Angeles 11,300 Clothing (Manufacturer) Occidental Petroleum Corporation Los Angeles 11,000 Oil and Gas Producers Reliance Steel and Aluminum Co. Los Angeles 9,610 Steel Works/Blast Furnace VCA Antech Inc. Los Angeles 9,400 Animal Hospital Los Angeles Police Department Los Angeles 9,000 Police Department Lowe Enterprises Inc. Los Angeles 8,001 Real Estate Developers Capital Group Co. Inc. Los Angeles 8,000 Investment Management LAC & USC Medical Center Los Angeles 8,000 Hospitals Southern California Gas Co. Los Angeles 7,067 Gas Companies Tutor Perini Corp. Sylmar 7,733 General Contractor Health Net, Inc. Woodland Hills 7,471 Hospital and Medical Services FX Networks, LLC Los Angeles 6,000 Television Los Angeles Times Los Angeles 5,800 Marketing Programs and Services Kaiser Foundation Hospital Los Angeles 5,200 Hospitals PMC Global, Inc. Sun Valley 5,100 Plastics and Plastic Production Pro Parts Canoga Park 5,000 Automobile Parts Rad Net Inc. Los Angeles 4,581 Laboratories (Medical) Source: InfoUSA, 2012.

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Figure 10: Major Employers and Public Transportation Routes

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Table 21: Employment and Wages Employment % of All Mean Annual

Estimates Employees Wage (2011)2 Occupation Management, business, science, and arts occupations 619,969 34.5% $122,665 Service Occupations 355,983 19.8% $21,800 Sales and Office Occupations 437,989 24.4% $37,195 Natural Resources, Construction, and Maintenance 157,540 8.8% $51,160 Production, Transportation, and Material Moving 226,654 12.6% $33,128 Industry Agriculture, Forestry, Fishing and Hunting 6,865 0.4% $25,145 Construction 120,623 6.7% $51,160 Manufacturing 176,547 9.8% $31,539 Wholesale Trade 56,956 3.2% $38,837 Retail Trade 185,020 10.3% $38,837 Transportation and Warehousing, and Utilities 72,870 4.1% $33,128 Information 104,074 5.8% $122,665 Finance and Insurance 125,501 7.0% $74,138 Professional, Scientific and Management 239,249 13.3% $69,898 Educational Services, Health Care and Social Assistance 341,171 19.0% $59,608 Arts, Entertainment, and Recreation 200,965 11.2% $75,670 Other Services 125,710 7.0% $21,800 Public Administration 42,584 2.4% $51,351 Sources: 1. American Community Survey (ACS), 2006-2010. 2. CA EDD, Occupational Employment & Wage Data Los Angeles-Long Beach MSA (Los Angeles County), 2011.

5. Employment Access

Public Transportation System

The Los Angeles County Metropolitan Transportation Authority (MTA) serves as transportation planner, coordinator, designer, builder, and operator for Los Angeles County. Besides the Metro Bus fleet, the MTA also designed, built, and now operates Metro Rail service. In addition to operating its own services, the MTA funds 16 municipal bus operators many of which offer connections in to employment centers within the City such as Downtown and the Wilshire Corridor.

In addition to the MTA, the City of Los Angeles and the Southern California Regional Rail Authority (SCRRA) offer transit options for City residents: the City of Los Angeles Department of Transportation (LADOT) operates the Commuter Express lines which are express services geared to shuttling residents from suburban communities into Los Angeles business centers and the SCRRA operates the Metrolink rail system that runs commuter trains in the six southern California counties of San Bernardino, Riverside, Ventura, Orange, Los Angeles and North San Diego. The Metrolink trains travel from communities throughout Southern California to

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Downtown Los Angeles and from Los Angeles, throughout the San Fernando Valley and into Ventura County and Antelope Valley.

Transit Dependency

Many minority and low and moderate income persons are transit-dependent. According to the American Community Survey, 11 percent of the City’s residents depended on public transportation to go to work between 2006 and 2010. When job centers and housing are inadequately served by public transportation, minority households, many of whom are low and moderate income, can be impacted disproportionately.

While the Downtown area and much of East Los Angeles is well served by public transit, there is a distinct lack of transit lines serving the Westside. However, bus lines do serve this particular region of Los Angeles. Furthermore, both transit and bus services are the most frequent during peak commuting hours, which may be a disadvantage for lower income individuals who do not work traditional hours.

Low income workers, especially female heads of household with children, have unique travel patterns that may prevent them from obtaining work far from home. As discussed earlier in this chapter, women in general are disproportionately responsible for household-supporting activities. Women dependent on public transit often need to look for employment near home.20 For other low income workers, long and unreliable commutes on public transit may limit their ability to travel to and from work.21

As shown in Figure 10 many of the City’s major employers are located on or near a public transit line. The major exception appears to be major employers located on the Westside, where light rail and subway transit does not yet exist. However, the bus service to these neighborhoods does exist. Furthermore, many low and moderate income areas, particularly those in the North Valley, South Los Angeles and Harbor areas, are poorly served by public transit of any kind.

20 Blumenberg, Evelyn. “Reverse Commute Transit Programs and Single Mothers on Welfare: A Policy Mismatch?” Institute of Transportation Studies, Volume 1, Number 2: December 2002. 21 Blumenberg, Evelyn and Paul Ong. “Cars, Buses, and Jobs: Welfare Participants and Employment Access in Los Angeles.” The University of California Transportation Center: Spring 2002.

City of Los Angeles Page 52 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 Chapter 3: Lending Practices

A key aspect of fair housing choice is equal access to credit for the purchase or improvement of a home, particularly in light of the recent tightening of lending/credit markets. This chapter reviews the lending practices of financial institutions and the access to financing for all households, particularly minority households and those with lower incomes. Lending patterns in lower and moderate income neighborhoods and areas of minority concentration are also examined. However, publicly available data on lending does not contain detailed information to make conclusive statements of discrimination, but can only point out potential areas of concerns. Furthermore, except for outreach and education efforts, a local jurisdiction’s ability to influence lending practices is limited. Such practices are largely governed by national policies and regulations.

A. Background and Legislative Protection

Discriminatory practices in home mortgage lending have evolved over the last five to six decades. In the 1940s and 1950s, racial discrimination in mortgage lending was easy to spot. From government-sponsored racial covenants to the redlining practices of private mortgage lenders and financial institutions, minorities were denied access to home mortgages in ways that severely limited their ability to purchase a home. Today, discriminatory lending practices are more subtle and tend to take different forms. While mortgage loans have become more readily available in lower and moderate income minority communities, some mortgage brokers pushed borrowers into higher-cost subprime mortgages that were not well suited to their needs and have led to financial problems. Although the recent tightening of credit markets has made this type of predatory lending less common, minority consumers continue to have less-than- equal access to loans at the best price and on the best terms that their credit history, income, and other individual financial considerations merit.

1. Community Reinvestment Act and Home Mortgage Disclosure Act

In the past, financial institutions did not always employ fair lending practices. Credit market distortions and other activities such as redlining were prevalent and prevented some groups from having equal access to credit. The Community Reinvestment Act (CRA) in 1977 and the subsequent Home Mortgage Disclosure Act (HMDA) were designed to improve access to credit for all members of the community and hold the lender industry responsible for community lending.

The CRA is intended to encourage regulated financial institutions to help meet the credit needs of their entire communities, including credit needs within lower and moderate income neighborhoods. Depending on the type of institution and total assets, a lender may be examined by different supervising agencies for its CRA performance.

CRA ratings are provided by the Federal Reserve Board (FRB), Federal Financial Institutions Examination Council (FFIEC), Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC). However, the CRA rating is an overall rating for an

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 53 Public Review Draft May 30, 2012 institution and does not provide insights regarding the lending performance at specific locations by the institution.

In tandem with the CRA, the HMDA requires lending institutions to make annual public disclosures of their home mortgage lending activity. Under HMDA, lenders are required to disclose information on the disposition of home loan applications and on the race or national origin, gender, and annual income of loan applicants.

HMDA data provide some insight into the lending patterns that exist in a community. However, HMDA data are only an indicator of potential problems; the data cannot be used to conclude definite redlining or discrimination practices due to the lack of detailed information on loan terms or specific reasons for denial.

2. Conventional versus Government-Backed Financing

Conventional financing involves market-rate loans provided by private lending institutions such as banks, mortgage companies, savings and loans, and thrift institutions. To assist lower and moderate income households that may have difficulty in obtaining home mortgage financing in the private market, due to income and equity issues, several government agencies offer loan products that have below market rate interests and are insured (“backed”) by the agencies. Sources of government-backed financing include loans insured by the Federal Housing Administration (FHA), the Department of Veterans Affairs (VA), and the Rural Housing Services/Farm Service Agency (RHA/FSA). Often, government-backed loans are offered to the consumers through private lending institutions. Local programs such as first-time homebuyer and rehabilitation programs are not subject to HMDA reporting requirements.

Typically, lower income households have a much better chance of getting a government- assisted loan than a conventional loan. However, the lending market between 2000 and 2006 offered subprime loan options such as zero percent down, interest-only, and adjustable loans. As a result, government-backed loans had become a less attractive option for many households.

However, with the current difficulties in the subprime housing market, many households are facing foreclosure or have already been foreclosed upon. In response, the federal government in September 2007 created a government-insured foreclosure avoidance initiative, FHASecure, to assist tens of thousands of borrowers nationwide in refinancing their subprime home loans. As government-backed loans are again publicized and subprime loans are less of an option to borrowers, the increased use of government-backed loan applications is likely. Expanded marketing to assist potential homeowners in understanding the requirements and benefits of these loans may be necessary to promote the use of government-backed loans.

3. Financial Stability Act

The Financial Stability Act of 2009 established the Making Home Affordable Program, which assists eligible homeowners who can no longer afford their home with mortgage loan modifications and other options, including short sale or deed-in-lieu of foreclosure. The program is targeted toward homeowners facing foreclosure and homeowners who are

City of Los Angeles Page 54 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 unemployed or underwater (i.e., homeowners who owe more on their mortgage than their home is worth). The Making Home Affordable Program includes several options for homeowners in need of assistance:

. Home Affordable Modification Program (HAMP) - Reduces a homeowner’s monthly mortgage payment to 31 percent of their verified gross (pre-tax) income to make their payments more affordable. Enhancements to this program were announced in February 2012. The expanded program will allow more homeowners to qualify and provide additional aid to mortgage customers in need of assistance. The program will also be extended an additional year until December 31, 2013.

. Second Lien Modification Program (2MP) - Offers homeowners a way to lower payments on their second mortgage.

. Home Affordable Refinance Program (HARP) - Assists homeowners whose mortgages are current and held by the Federal National Mortgage Association (Fannie Mae) or the Federal Home Loan Mortgage Corporation (Freddie Mac) refinance into a more affordable mortgage. On October 24, 2011, President Obama announced an overhaul of the HARP program with the intent of reaching more underwater homeowners. The expanded HARP program—also referred to as HARP 2.0—took effect on December 1, 2011 for borrowers with a loan-to-value ratio of less than 125 percent and in the first quarter of 2012 for borrowers with a loan-to-value ratio of greater than 125 percent. HARP 2.0 was formally released by Fannie Mae and Freddie Mac on March 17, 2012.

. Unemployment Program - Provides eligible homeowners a forbearance period during which their monthly mortgage payments are reduced or suspended while they seek re- employment. The minimum forbearance period is three months, although a mortgage servicer may extend the term depending on applicable investor and regulatory guidelines.

. Principal Reduction Program - Offers homeowners who are underwater the opportunity to earn principal reductions over a three-year period by successfully making payments in accordance with their modified loan terms.

. Home Affordable Foreclosure Alternatives Program (HAFA) - For those who can no longer afford their homes, but do not want to go into foreclosure, this program offers incentives to homeowners, their mortgage servicers, and investors for completing a short sale or deed-in-lieu of foreclosure. HAFA enables homeowners to transition to more affordable housing while being released from their mortgage debt. The program also includes a “cash for keys” component whereby a homeowner receives financial assistance to help with relocation costs in return for vacating their property in good condition.

In February 2012, the federal government announced a $25 billion settlement with five of the nation's largest banks over charges of systemic and widespread mortgage fraud – Bank of America; Wells Fargo; JPMorgan Chase; Citigroup; and Ally Financial. The settlement could potentially help more than one million struggling homeowners by offering partial loan

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 55 Public Review Draft May 30, 2012 forgiveness, or principal reductions, to struggling homeowners. In addition to granting principal reductions, the deal offers homeowners relief by changing the terms of their loans. Under the terms of this deal, those who have already lost their homes would receive just a small fraction of the money—a one-time cash payment of up to $2,000.

4. Helping Families Save Their Homes Act

The Helping Families Save Their Homes Act was passed by Congress in May 2009 and expands the Making Home Affordable Program. This Act includes provisions to make mortgage assistance and foreclosure prevention services more accessible to homeowners and increases protections for renters living in foreclosed homes. It also establishes the right of a homeowner to know who owns their mortgage and provides over two billion dollars in funds to address homelessness.

The Act targets underwater borrowers by easing restrictions on refinance and requiring principal write-downs to help these homeowners increase the equity in their homes. The new law also provides federally guaranteed rural housing loans and FHA loans as part of the Making Homes Affordable Program. In addition to expanding the Making Homes Affordable Program, the Act extends the temporary increase in deposit insurance, increases the borrowing authority of the FDIC and National Credit Union Administration (NCUA), and creates a Stabilization Fund to address problems in the corporate credit union sector.

Under this new law, which sunsets this year, tenants also have the right to stay in their homes after foreclosure for 90 days or through the term of their lease. The law also provides similar protections to housing voucher holders. These protections went into effect in 2009 and are set to expire at the end of 2012. Prior to this bill, tenants were only guaranteed 60 days of notice before eviction and any current lease was considered terminated in the event of a foreclosure. This Act extends the 60-day notification period to 90 days and requires banks to honor any existing lease on a property in foreclosure.

5. Fraud Enforcement and Recovery Act

The Fraud Enforcement and Recovery Act (FERA) enhances the criminal enforcement of federal fraud laws by strengthening the capacity of federal prosecutors and regulators to hold accountable those who have committed fraud. FERA amends the definition of a financial institution to include private mortgage brokers and non-bank lenders that are not directly regulated or insured by the federal government, making them liable under federal bank fraud criminal statutes. The new law also makes it illegal to make a materially false statement or to willfully overvalue a property in order to manipulate the mortgage lending business. In addition, FERA includes provisions to protect funds expended under the Troubled Asset Relief Program (TARP) and the Recovery Act and amends the Federal securities statutes to cover fraud schemes involving commodity futures and options. Additional funds were also made available, under FERA, to a number of enforcement agencies in order to investigate and prosecute fraud.

City of Los Angeles Page 56 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 B. Overall Lending Patterns

1. Data and Methodology

The availability of financing affects a person’s ability to purchase or improve a home. Under the HMDA, lending institutions are required to disclose information on the disposition of loan applications by the income, gender, and race of the applicants. This applies to all loan applications for home purchases, improvements and refinancing, whether financed at market rate or with government assistance.

HMDA data are submitted by lending institutions to the Federal Financial Institutions Examination Council (FFIEC). Certain data is available to the public via the FFIEC site either in raw data format or as pre-set printed reports. The analyses of HMDA data presented in this AI were conducted using Lending Patterns TM. Lending Patterns is a web-based data exploration tool that analyzes lending records to produce reports on various aspects of mortgage lending. It analyzes HMDA data to assess market share, approval rates, denial rates, low/moderate income lending, and high-cost lending, among other aspects.

Table 22 summarizes the disposition of loan applications submitted to financial institutions in 2007 (the beginning of the housing crisis) and 2010 (most recent HMDA data available) for home purchase, refinance, and home improvement loans in the City of Los Angeles. The data for Los Angeles was compiled by census tract and aggregated to the area that generally approximates the boundaries of the City. Included is information on loan applications that were approved, denied, and withdrawn by the applicant, or incomplete.

Table 22: Disposition of Home Loans (2007 and 2010) Withdrawn or Total Applicants Approved Denied Loan Type Incomplete 2007 2010 2007 2010 2007 2010 2007 2010 Government-Backed Purchase 81 12,285 53.1% 67.7% 24.7% 18.3% 22.2% 14.0% Conventional Purchase 71,234 22,699 59.9% 70.4% 26.5% 15.3% 13.5% 14.4% Refinance 137,322 77,515 53.2% 62.1% 30.6% 21.3% 16.2% 16.6% Home Improvement 18,820 3,257 50.8% 50.1% 35.4% 32.7% 13.8% 17.3% Total 227,457 115,756 55.1% 64.0% 29.7% 20.1% 15.2% 15.9% Source: www.lendingpatterns.com, 2012.

2. Home Purchase Loans

Conventional Loans

In 2010, a total of 22,699 households applied for conventional home purchase loans in Los Angeles. This reflects a 68-percent decrease from the 2007 level. The substantial decrease in lending activity is reflective of lending patterns throughout the country. Housing prices, both in the region and nationwide, peaked in 2006 and 2007 marked the start of the housing market’s steep decline. Mortgage lending in 2007, while not as vigorous as in the previous year, was still

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 57 Public Review Draft May 30, 2012 active. However, in the following years lending activity slowed down dramatically to match the lack of activity in the housing market.

Table 23: Disposition of Conventional Home Purchase Loans (2007 and 2010) Withdrawn or Total Applicants Approved Denied NSA Incomplete 2007 2010 2007 2010 2007 2010 2007 2010 North Valley 13,945 4,595 57.7% 69.8% 28.8% 16.0% 13.5% 14.2% South Valley 17,803 6,218 61.8% 72.5% 25.8% 13.8% 12.5% 13.7% West LA 10,046 4,086 70.3% 71.1% 17.9% 14.1% 11.8% 14.7% Central 9,546 3,676 64.7% 71.4% 21.3% 14.5% 13.9% 14.1% East LA 5,552 1,613 58.3% 68.2% 26.5% 16.1% 15.2% 15.7% South LA 11,435 1,742 47.2% 61.8% 37.3% 22.7% 15.5% 15.5% Harbor 2,907 769 61.1% 71.0% 24.7% 14.4% 14.2% 14.6% Total 71,234 22,699 59.9% 70.4% 26.5% 15.3% 13.5% 14.4% Source: www.lendingpatterns.com, 2012.

In Los Angeles, the overall approval rate in 2010 for conventional home purchase loans was 70 percent and 15 percent of applications were denied. This reflects a significant change from 2007, when just 60 percent of conventional home loan applications were approved and 27 percent were denied. When the housing market began to show signs of collapse and foreclosures were on the rise, many financial institutions instituted stricter approval criteria for potential borrowers, which should have caused approval rates to drop somewhat. However, the applicant pool for mortgage lending in recent years has also become smaller and increasingly selective. These applicants have generally been in much better shape financially then applicants from earlier in the decade, when the housing bubble attracted a wider range of potential borrowers.

Among all NSAs in the City, South Los Angeles consistently experienced the lowest home purchase loan approval rates, either in 2007 or in 2010. This area also saw the sharpest decline in homebuying activities.

Approval rates were relatively consistent throughout all of the City’s NSAs, with the exception of South Los Angeles. South Los Angeles had a noticeably lower approval rate (62 percent) and higher denial rate (23 percent) than all other NSAs. This pattern was also visible in 2007, when only 47 percent of applications from South Los Angeles were approved and 37 were denied. Furthermore, while the number of home purchase loan applications declined substantially throughout the entire City overall, they declined the most steeply in South Los Angeles. The number of applications from South Los Angeles residents dropped 85 percent (9,693 applications) between 2007 and 2010 when applications citywide only dropped 68 percent during this time period (Table 23).

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Government-Backed Loans

In Los Angeles, the number of applications for government-backed home purchase loans was considerably higher in 2010 than 2007. Approximately 12,285 applications for government- backed loans were submitted in Los Angeles (for example, FHA, VA). Approval rates were similar to those for conventional home purchase loans (68 percent) and denial rates were also consistent at 18 percent overall. There was less variation in approval rates for government- backed loans among the City’s NSAs compared to conventional home purchase loans. However, a vast majority of the applications for government-backed loans did come from the North Valley, South Valley, East Los Angeles and South Los Angeles NSAs.

In 2007, government-backed home loans made up a considerably smaller proportion of total lending activity for the City. Los Angeles residents filed only 81 applications for government- backed home purchase loans. About 53 percent of applications for government-backed loans in 2007 were approved. During this time, conventional home purchase applications overwhelmingly outnumbered applications for government-backed loans in the City of Los Angeles. Since 2007, however, the increasingly stringent credit and downpayment requirements for conventional purchase loans have caused potential borrowers to turn more towards government-backed loans.

Government-backed loans have more lenient credit score requirements, lower downpayment requirements, and are available to those with recent bankruptcies or other credit anomalies. However, these loans may also carry higher interest rates and most require homebuyers to purchase mortgage insurance. Furthermore, government-backed loans have strict limits on the amount a homebuyer can borrow for the purchase of a home. In competitive and high-end housing markets, many of the homes available for purchase exceed the maximum allowable loan amount, making government-backed loans much less popular. However, the relatively lower cost housing available in large portions of the City, particularly in East Los Angeles and South Los Angeles, has made government-backed loans a feasible and practical option for many homebuyers in the City.

Table 24: Disposition of Government-Backed Home Purchase Loans (2007 and 2010) Withdrawn or Total Applicants Approved Denied NSA Incomplete 2007 2010 2007 2010 2007 2010 2007 2010 North Valley 26 3,456 53.9% 67.9% 23.1% 19.6% 23.1% 12.5% South Valley 14 2,501 64.3% 70.9% 21.4% 17.0% 14.3% 12.1% West LA 3 490 33.3% 71.8% 66.7% 12.5% 0.0% 15.7% Central 4 480 75.0% 61.3% 25.0% 21.3% 0.0% 17.5% East LA 6 1,012 66.7% 66.8% 16.7% 18.1% 16.7% 15.1% South LA 20 3,747 45.0% 64.8% 20.0% 19.1% 35.0% 16.1% Harbor 8 599 37.5% 73.5% 37.5% 15.6% 25.0% 12.0% Total 81 12,285 53.1% 67.7% 24.7% 18.3% 22.2% 14.0% Source: www.lendingpatterns.com, 2012.

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3. Refinance Loans

Homebuyers will often refinance existing home loans for a number of reasons. Refinancing can allow homebuyers to take advantage of better interest rates, consolidate multiple debts into one loan, reduce monthly payments, alter risk (i.e. by switching from variable rate to fixed rate loans), or free up cash and capital. A substantial proportion of loan applications submitted in Los Angeles in 2010 were for refinancing existing home loans (77,515 applications). About 62 percent of these applications were approved, while 21 percent were denied. As with home purchase loans, there was some variation in approval rates among the City’s NSAs.

South Los Angeles had the lowest approval rate for refinancing at 49 percent and the highest denial rate at 32 percent.

Refinance lending was much more active in 2007. The housing market peaked in 2006 and many households purchased homes during the peak using adjustable rates and loans with low interest rates only for a short term. With the upward trending of adjustable rates and the expiration of the short-term low-interest loans, many households sought refinancing. In Los Angeles, 137,322 applications for refinancing were filed in 2007, nearly twice the number of applications in 2010 but with lower approval rates. With the bursting of the “housing bubble” in 2006, many households were facing high housing payments and declining home value. Refinancing was far more difficult than they were led to believe when purchasing the home.

Refinancing in the current market is substantially more difficult than it had been in the past. Financial institutions have established much stricter requirements for mortgage refinancing, making it harder for homeowners to qualify for a refinance loan. Even homeowners who have excellent credit and a low debt-to-income ratio face obstacles to refinancing, such as a lack of home equity. Some homeowners have little or no equity because they bought their property with minimal down payments; alternatively, many homeowners who had equity have watched it erode in recent years because of decreasing home values. As a result, fewer households would qualify for refinancing. In response, recent federal legislation was passed to require lenders to work with homeowners to pursue loan modifications.

Table 25: Disposition of Refinance Loans (2007 and 2010) Withdrawn or Total Applicants Approved Denied NSA Incomplete 2007 2010 2007 2010 2007 2010 2007 2010 North Valley 32,256 15,167 51.9% 62.9% 32.2% 20.5% 16.0% 16.7% South Valley 29,391 21,037 55.4% 64.6% 29.3% 19.8% 15.4% 15.6% West LA 11,987 17,059 62.3% 64.9% 23.8% 19.2% 13.9% 22.6% Central 10,886 8,748 57.5% 59.9% 27.3% 22.7% 15.3% 17.5% East LA 13,195 6,549 52.6% 59.0% 30.9% 23.4% 16.6% 17.8% South LA 33,066 5,374 48.3% 49.0% 33.6% 31.7% 18.1% 19.4% Harbor 6,541 3,581 62.4% 61.7% 11.0% 21.1% 17.3% 17.2% Total 137,322 77,515 53.2% 62.1% 30.6% 21.3% 16.2% 16.6% Source: www.lendingpatterns.com, 2012.

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4. Home Improvement Loans

Historically, home improvement loan applications have a higher rate of denial when compared to home purchase loans. Part of the reason is that an applicant’s debt-to-income ratio may exceed underwriting guidelines when the first mortgage is considered with consumer credit balances. Another reason is that many lenders use the home improvement category to report both second mortgages and equity-based lines of credit, even if the applicant’s intent is to do something other than improve the home (e.g., pay for a wedding or college). Loans that will not be used to improve the home are viewed less favorably since the owner is divesting in the property by withdrawing accumulated wealth. From a lender’s point of view, the reduction in owner’s equity represents a higher risk.

In 2010, 3,257 applications for home improvement loans were received in Los Angeles. Approximately one-half of applications were approved, and about 33 percent of applications were denied. The disparity in approval rates among the City’s various NSAs was greater than for all other types of loans. West Los Angeles had the highest approval rate at 60 percent, while South Los Angeles had the lowest approval rate at 41 percent. Conversely, West Los Angeles had the lowest denial rate (25 percent) and South Los Angeles had the highest (44 percent) denial rate.

South Los Angeles had the lowest approval rates for home improvement loans.

Home improvement financing, like home purchase lending and mortgage refinancing, was much more active in 2007. About five times more applications (18,820 applications) for home improvement loans were filed by Los Angeles residents in 2007. Approval rates for this type of loan have remained consistent since 2007. Home prices were sliding in 2007 but did not hit bottom until 2010, which resulted in evaporated home equity and prevented many households to qualify for additional financing.

Table 26: Disposition of Home Improvement Loans (2007 and 2010) Total Applicants Percent Approved Percent Denied Percent Other NSA 2007 2010 2007 2010 2007 2010 2007 2010 North Valley 4,412 618 51.4% 48.5% 35.6% 32.5% 13.0% 18.9% South Valley 3,376 709 54.0% 54.4% 32.4% 29.4% 13.7% 16.1% West LA 1,334 507 61.8% 60.0% 23.6% 24.5% 14.5% 15.6% Central 1,340 353 53.2% 47.0% 32.5% 33.1% 14.3% 19.8% East LA 2,127 380 48.6% 45.8% 38.2% 33.2% 13.3% 21.1% South LA 5,236 517 45.5% 41.4% 39.8% 43.7% 14.7% 14.9% Harbor 995 173 51.4% 50.3% 35.3% 35.3% 13.4% 14.5% Total 18,820 3,257 50.8% 50.1% 35.4% 32.7% 13.8% 17.3% Source: www.lendingpatterns.com, 2012.

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 61 Public Review Draft May 30, 2012 C. Lending Patterns by Race/Ethnicity and Income Level

The federal Fair Housing Act prohibits discrimination in mortgage lending based on race, color, national origin, religion, sex, familial status or handicap (disability). It is, therefore, important to look not just at overall approval and denial rates for a jurisdiction, but also whether or not these rates vary by other factors, such as race/ethnicity. An analysis of lending patterns for different races/ethnicities of the same income levels can help reveal patterns not discernible when analyzing lending data by race or income separately.

In Los Angeles, the rate at which applications were withdrawn and incomplete was relatively consistent across all races/ethnicities and income levels in both 2007 and 2010. White and Asian applicants generally had the highest approval rates, while Blacks had the lowest approval rates across all income categories. In 2010, only 58 percent of upper income Black applicants were approved for loans versus 69 percent of upper income White applicants. Even among the highest income categories, where applicants are assumed to be the most financially capable of purchasing a home, approval rates for Blacks were 11 percentage points lower than approval rates for White applicants. This discrepancy was even greater in 2007, when 48 percent of upper income Blacks were approved for loans compared to 65 percent of upper income Whites.

Black households consistently had the lowest approval rates across all income categories. Approval rates for upper income Black households were 17 percentage points lower than upper income White households in 2007 and 11 percentage points lower than upper income White households in 2010.

While this analysis provides a more in-depth look at lending patterns, it does not conclusively explain any of the discrepancies observed. Aside from income, many other factors can contribute to the availability of financing, including credit history, the availability and amount of a downpayment, and knowledge of the home buying process. HMDA data does not provide insight into these other factors.

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Table 27: Lending Patterns by Race/Ethnicity for Los Angeles (2007 and 2010) Withdrawn/ Approved Denied Incomplete 2007 2010 2007 2010 2007 2010 Low (0-49% MFI) White 61.6% 46.1% 23.8% 40.3% 14.6% 13.6% Black 37.5% 41.6% 46.8% 39.9% 15.7% 18.6% Hispanic 26.2% 48.7% 61.9% 35.5% 11.9% 15.8% Asian 28.8% 50.1% 59.5% 32.9% 11.9% 16.2% Moderate (50-79% MFI) White 59.3% 59.5% 27.2% 25.0% 13.5% 15.5% Black 46.4% 51.5% 38.6% 30.1% 15.0% 17.6% Hispanic 44.3% 58.7% 44.0% 26.1% 11.7% 15.3% Asian 49.5% 61.3% 37.6% 23.5% 12.9% 15.2% Middle (80-119% MFI) White 63.3% 67.0% 23.9% 19.6% 12.8% 13.4% Black 49.9% 55.1% 34.3% 29.0% 15.7% 16.0% Hispanic 50.8% 63.1% 36.4% 22.6% 12.9% 14.3% Asian 56.3% 69.1% 32.3% 17.1% 11.3% 13.7% Upper (≥120% MFI) White 65.3% 69.4% 22.4% 16.4% 12.3% 14.2% Black 47.6% 58.2% 36.4% 24.7% 16.0% 17.2% Hispanic 50.5% 61.9% 34.5% 21.6% 15.0% 16.5% Asian 59.9% 69.3% 26.8% 16.4% 13.3% 14.3% Source: www.lendingpatterns.com, 2012.

D. Lending Patterns by Census Tract Characteristics

1. Income Level

To identify potential geographic differences in mortgage lending activities, an analysis of the HMDA data was conducted by census tract. Based on the Census, HMDA defines the following income levels:

. Low Income Tract – Tract Median Income ≤ 49 percent MFI . Moderate Income Tract – Tract Median Income between 50 and 79 percent MFI . Middle Income Tract – Tract Median Income between 80 and 119 percent MFI . Upper Income Tract – Tract Median Income ≥120 percent MFI

Table 28 below summarizes the loan approval and denial rates of census tracts by income level in 2010. Applications from Middle and Upper Income census tracts made up the bulk of lending applications. In general, home loan approval rates increased as the income level of the census tract increased. Higher income households are more likely to qualify for and be approved for loans so this trend is to be expected.

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Table 28: Outcomes Based on Census Tract Income (2010) Withdrawn/ Total Applicants Approved Denied Tract Income Level Incomplete # % # % # % # % Low 4,691 4.0% 2,586 55.1% 1,250 26.6% 855 18.2% Moderate 20,031 17.2% 11,878 59.3% 4,888 24.4% 3,265 16.3% Middle 30,276 26.8% 19,245 63.6% 6,160 20.3% 4,871 16.1% Upper 60,747 52.0% 40,331 66.4% 11,000 18.1% 9,416 15.5% Total 115,745 100.0% 74,040 64.0% 23,298 20.1% 18,407 15.9% Source: www.lendingpatterns.com, 2012. Note: Applications from tracts where the income level was unknown were not included.

2. Minority Population

HMDA also provides the minority population percentage within each census tract. Los Angeles is a racially and ethnically diverse city and census tracts where 60 percent to 100 percent of residents are minorities make up about 40 percent of the City. Table 29 below summarizes the home loan approval and denial rates of the City’s census tracts by percentage of minority population during 2010. Although approval rates were relatively consistent throughout all of the City’s census tracts, the table reveals a slight inverse relationship between race and approval; the approval rate was generally higher in tracts with lower minority concentrations and lower in tracts with higher minority concentrations.

Table 29: Outcomes Based on Minority Population of Census Tract (2010) Withdrawn/ Total Applicants Approved Denied Incomplete # % # % # % # % 0-19% Minority 22,291 19.3% 14,616 65.6% 4,148 18.6% 3,527 15.8% 20-39% Minority 30,108 26.0% 20,227 67.2% 5,312 17.6% 4,569 15.2% 40-59% Minority 16,933 14.6% 11,210 66.2% 3,142 18.6% 2,581 15.2% 60-79% Minority 17,819 15.4% 11,296 63.4% 3,659 20.5% 2,864 16.1% 80-100% Minority 28,605 24.7% 16,692 58.4% 7,043 24.6% 4,870 17.0% Total 115,756 100.0% 74,041 64.0% 23,304 20.1% 18,411 15.9% Source: www.lendingpatterns.com, 2012.

E. Major Lenders

In 2010, the top ten mortgage lenders in the City of Los Angeles received approximately 55 percent of all lending applications. Among these lenders, Wells Fargo and Bank of America received the most applications—about 32 percent of the market share in the City. Table 30 summarizes the top lenders for 2010 in Los Angeles as well as their underwriting outcomes.

In Los Angeles, several top lenders had significantly higher approval rates than the overall average for all lenders in the City. Flagstar Bank, PMC Bancorp, Prospect Mortgage, and

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Metlife Bank all had approval rates of 75 percent or greater in 2010, about 11 points higher than the overall approval rate for all lenders (64 percent). Flagstar also had notably high approval rates in 2007. While high approval rates do not necessarily indicate wrongdoing by a specific institution, they can be a sign of aggressive lending practices on the part of the lender. It is also worth noting that three of the lenders identified above are smaller financial institutions and two have a history of higher than average approval rates.

Table 30: Top Lenders (2007 and 2010) Overall Market Withdrawn or Approved Denied Share Incomplete 2007 2010 2007 2010 2007 2010 2007 2010 Wells Fargo 5.2% 17.2% 73.2% 63.8% 16.7% 18.4% 10.1% 17.8% Bank of America 5.8% 14.6% 72.6% 60.8% 25.2% 22.6% 22.4% 16.6% JP Morgan Chase 2.9% 7.1% 68.0% 60.2% 25.0% 34.0% 7.0% 5.8% Citimortgage 2.1% 4.3% 57.7% 54.8% 13.5% 16.5% 28.8% 28.7% PMC Bancorp 0.4% 2.6% 63.9% 77.0% 9.1% 5.6% 27.0% 17.4% Prospect Mortgage -- 2.3% -- 75.8% -- 11.9% -- 12.3% Flagstar Bank 0.6% 2.0% 72.2% 81.8% 27.3% 18.2% 0.5% 0.0% Ally Bank -- 1.7% -- 45.0% -- 18.5% -- 36.5% Metlife Bank 0.0% 1.6% 12.5% 74.8% 87.5% 17.0% 0.0% 8.2% Union Bank 0.6% 1.5% 78.7% 66.8% 15.5% 27.8% 5.8% 5.4% All Lenders 100.0% 100.0% 55.1% 64.0% 29.7% 20.1% 15.2% 15.9% Source: www.lendingpatterns.com, 2012. Note: The table identifies the top ten lenders of 2010. Some of these lenders were not top lenders in 2007 and market share data is not available.

Several top lenders in the region also had higher than average rates of withdrawn or incomplete applications. Under current banking regulations, lenders are required to hold a given interest rate for a borrower for a period of 60 days. Borrowers, however, are under no obligation to actually follow through on the loan during this time and can withdraw their application. In mortgage lending, fallout refers to a loan application that is withdrawn by the borrower before the loan is finalized. A significant disparity in fallout could suggest screening, differential processing, HMDA Action mis-classification and/or the potential of discouragement of minority applications.

Closed applications refer to applications that are closed by the lender due to incompleteness. In instances where a loan application is incomplete, lenders are required to send written notification to the applicant and request the missing information be turned over within a designated timeframe. If this notice is given and the applicant does not comply within the specified time, the lender can close the application for incompleteness. A high rate of incomplete loans can indicate a lack of financial literacy on the part of the borrower. Several studies have correlated financial literacy with a borrower’s income level. Specifically, lower income individuals were the least knowledgeable about finance.22 Insufficient lender assistance during the application process can also lead to high levels of incomplete applications. The lack

22 Collins, Michael. “Education Levels and Mortgage Application Outcomes: Evidence of Financial Literacy.” University of Wisconsin-Madison, Department of Consumer Science: 2009.

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 65 Public Review Draft May 30, 2012 of lender assistance may be discriminatory in motive or outcome; however, HMDA data cannot be used to prove motive. In Los Angeles, during 2010, two institutions had significantly higher than average rates of withdrawn and incomplete applications — Citimortgage and Ally Bank.

Top lenders for the City also varied significantly when comparing data based on the race/ethnicity of the applicant (Table 31). In Los Angeles, for example, Hispanic applicants made up about 17 percent of the applicant pool in 2010. However, Hispanic applicants made up larger proportions of the applicant pool for several lesser known banks. Specifically, Stearns Lending (31 percent) and PMC Bancorp (21 percent) had substantially higher proportions of Hispanic applicants. Ally Bank (seven percent), Stearns Lending (five percent), and Quicken Loans (five percent) had higher proportions of Black applicants than the average for all lenders (four percent). And, PMC Bancorp (24 percent) and Provident Funding Associates (11 percent) had a higher proportion of Asian applicants than the overall average for all lenders (10 percent).

The correlation between minority applicants and smaller banks raises some concerns about the equality of access to mortgage financing. Smaller community banks often have more flexibility in their selection process, and applicants with less than stellar credit and flawed financial histories may be more successful in securing mortgage financing at these smaller institutions than at larger established banks. Large banks with a strong nationwide presence, however, do have several advantages. They are closely regulated by the federal government and have a wide array of resources available to borrowers.

The propensity for certain smaller banks to attract non-White applicants may indicate that access to financing, especially at larger banks, is not equal for applicants of all races/ethnicities.

Table 31: Top Lenders by Race/Ethnicity of Applicant (2010) % of Total % of Total % of Total Lender Lender Lender Applicants Applicants Applicants Black Hispanic Asian Ally Bank 6.8% Stearns Lending 31.3% PMC Bancorp 24.3% Provident Funding JP Morgan Chase 4.8% PMC Bancorp 21.0% 11.3% Associates Stearns Lending 4.7% JP Morgan Chase 19.4% Bank of America 11.1% Quicken Loans 4.5% Flagstar Bank 16.4% Metlife Bank 10.9% Wells Fargo 4.3% Wells Fargo 16.3% Citimortgage 10.2% All Lenders 3.9% All Lenders 17.4% All Lenders 10.0% Source: www.lendingpatterns.com, 2012.

F. Subprime Lending

According to the Federal Reserve, “prime” mortgages are offered to persons with excellent credit and employment history and income adequate to support the loan amount. “Subprime” loans are loans to borrowers who have less-than-perfect credit history, poor employment history, or other factors such as limited income. By providing loans to those who do not meet the critical standards for borrowers in the prime market, subprime lending can and does serve a critical role in increasing levels of homeownership. Households that are interested in buying a

City of Los Angeles Page 66 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 home but have blemishes in their credit record, insufficient credit history, or non-traditional income sources, may be otherwise unable to purchase a home. The subprime loan market offers these borrowers opportunities to obtain loans that they would be unable to realize in the prime loan market.

Subprime lenders generally offer interest rates that are higher than those in the prime market and often lack the regulatory oversight required for prime lenders because they are not owned by regulated financial institutions. In the recent past, however, many large and well-known banks became involved in the subprime market either through acquisitions of other firms or by initiating subprime loans directly. Though the subprime market usually follows the same guiding principles as the prime market, a number of specific risk factors are associated with this market. According to a joint HUD/Department of the Treasury report, subprime lending generally has the following characteristics:23

. Higher Risk: Lenders experience higher loan defaults and losses by subprime borrowers than by prime borrowers.

. Lower Loan Amounts: On average, loans in the subprime mortgage market are smaller than loans in the prime market.

. Higher Costs to Originate: Subprime loans may be more costly to originate than prime loans since they often require additional review of credit history, a higher rate of rejected or withdrawn applications and fixed costs such as appraisals, that represent a higher percentage of a smaller loan.

. Faster Prepayments: Subprime mortgages tend to be prepaid at a much faster rate than prime mortgages.

. Higher Fees: Subprime loans tend to have significantly higher fees due to the factors listed above.

Subprime lending can both impede and extend fair housing choice. On the one hand, subprime loans extend credit to borrowers who potentially could not otherwise finance housing. The increased access to credit by previously underserved consumers and communities contributed to record high levels of homeownership among minorities and lower income groups. On the other hand, these loans left many lower income and minority borrowers exposed to default and foreclosure risk. Since foreclosures destabilize neighborhoods and subprime borrowers are often from lower income and minority areas, mounting evidence suggests that classes protected by fair housing faced the brunt of the recent subprime and mortgage lending market collapse.24

While HMDA data does not classify loans as subprime, it does track the “interest rate spread” on loans. An interest rate spread refers to the difference between two related interest rates. For HMDA data, spread specifically refers to the difference between the annual percentage rate

23 U.S. Department of Housing and Urban Development. “Unequal Burden In Los Angeles: Income and Racial Disparities in Subprime Lending.” April 2000. 24 Association of Community Organizations for Reform Now. “Foreclosure Exposure: A Study of Racial and Income Disparities in Home Mortgage Lending in 172 American Cities.” September 2007.

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(APR) for a loan and the yield on a comparable-maturity Treasury security. In 2005, the Federal Reserve Board required lenders to report rate spreads for loans whose APR was above the Treasury benchmark. Loans with a reported spread are typically referred to as higher-priced or subprime loans.

As shown in Table 32, the frequency of loans with reported spread has decreased substantially since 2007. About one in every five loans in 2007 had a reported spread, but by 2010, only a very small fraction of loans reported a spread. While the proportion of loans with a reported spread was high overall in 2007, it should be noted that the frequency of these types of loans was the highest for Blacks and Hispanics. In Los Angeles, 29 percent of loans to Blacks had a reported spread and about 24 percent of loans to Hispanics had a reported spread. By contrast, only 14 percent of loans to Asians had a reported spread and about 11 percent of Whites were given loans with a reported spread. By 2010, Blacks were still the most likely to receive a subprime loan. The proportion of Hispanics receiving subprime loans was also still notably higher than the proportion of White and Asian applicants receiving subprime loans.

Although the proportion of loans with spread (i.e. subprime loans) and the magnitude of spread have decreased since 2007, Black households consistently had the highest proportion of loans with spread in both 2007 and 2010, compared to other racial/ethnic groups.

Table 32: Reported Spread on Loans by Race/Ethnicity (2007 and 2010) Frequency of Spread Average Spread

2007 2010 2007 2010 White 11.1% 0.9% 4.08 2.35 Black 28.9% 4.6% 4.40 2.21 Hispanic 23.9% 1.6% 4.40 2.30 Asian 14.2% 0.7% 4.11 2.31 Source: www.lendingpatterns.com, 2012.

In addition to the frequency of loans with reported spread, it is also important to look at the magnitude of the reported spread. Since 2007, the magnitude of spread reported has decreased substantially. However, there were still slight disparities in the severity of the spread based on the race/ethnicity of the applicant. In 2007, the average magnitude of reported spread was the highest for Blacks and Hispanics. However, by 2010, the disparities in average reported spread narrowed among all groups.

Predatory Lending

With an active housing market, potential predatory lending practices by financial institutions may arise. Predatory lending involves abusive loan practices usually targeting minority applicants or those with less-than-perfect credit histories. The predatory practices typically include higher fees, hidden costs, and unnecessary insurance and larger repayments due in later years. One of the most common predatory lending practices is placing borrowers into higher interest rate loans than called for by their credit status. Although the borrowers may be eligible for a loan in the “prime” market, they are directed into more expensive and higher fee loans in the “subprime” market. In the other cases, fraudulent appraisal data is used to mislead

City of Los Angeles Page 68 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 homebuyers into purchasing over-valued homes, or misrepresented financial data is used to encourage homebuyers into assuming a larger loan than can be afforded. Both cases often result in foreclosure.

In recent years, predatory lending has also penetrated the home improvement financing market. Seniors and minority homeowners are typically the targets of this type of lending. In general, home improvement financing is more difficult to obtain than home purchase financing. Many homeowners have a debt-to-income ratio that is too high to qualify for home improvement loans in the prime market and become targets of predatory lending in the subprime market. Seniors have been swindled into installing unnecessary devices or making unnecessary improvements that are bundled with unreasonable financing terms.

Housing advocates attended the Focus Group consultation meetings indicated a re-emerging trend of predatory lending for home improvements. Minority and senior households are targeted for scams that promote expensive and unnecessary home improvements and high-cost financing to pay for these improvements.

Predatory lending is a growing fair housing issue. Predatory lenders who discriminate get some scrutiny under the Fair Housing Act of 1968, which requires equal treatment in terms and conditions of housing opportunities and credit regardless of race, religion, color, national origin, family status, or disability. This applies to loan originators as well as the secondary market. The Equal Credit Opportunity Act of 1972 requires equal treatment in loan terms and availability of credit for all of the above categories, as well as age, sex, and marital status. Lenders that engage in predatory lending would violate these Acts if they target minority or elderly households to buy at higher prices and unequal loan products, treat loans for protected classes differently than those of comparably credit-worthy applicants, or have policies or practices that have a disproportionate effect on the protected classes.

Data available to investigate the presence of predatory lending is extremely limited. At present, HMDA data are the most comprehensive data available for evaluating lending practices. However, as discussed before, HMDA data lack the financial details of the loan terms to conclude that any kind of predatory lending has actually occurred. There is an effort at the national level to push for increased reporting requirements in order to identify and curb predatory lending.

Predatory lending and unsound investment practices, central to the current home foreclosure crisis, are resulting in a credit crunch that has spread well beyond the housing market, now impacting the cost of credit for local government borrowing and local property tax revenues. The State of California has enacted measures designed to stem the tide of predatory lending practices. A law (Senate Bill 537) signed by Governor Gray Davis provided a funding mechanism for local district attorneys’ offices to establish special units to investigate and prosecute real estate fraud cases. The law enabled county governments to establish real estate fraud protection units. Furthermore, Governor Davis signed AB 489 in October 2001, a predatory lending reform bill. The law prevents a lender from basing the loan strictly on the borrower’s home equity as opposed to the ability to repay the loan. The law also outlaws some balloon payments and prevents refinancing unless it results in an identifiable benefit to the borrower.

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In addition to State anti-predatory lending laws, the Mortgage Forgiveness Debt Relief Act was enacted in 2007 and allows for the exclusion of income realized as a result of modification of the terms of a mortgage or foreclosure on a taxpayer’s principal residence.

While subprime lending cannot in and of itself be described as “predatory,” studies have shown a high incidence of predatory lending in the subprime market.25 Unlike in the prime lending market, overly high approval rates in the subprime market is a potential cause for concern when the target clients are considered high risk. High approval rates may indicate aggressive lending practices. Table 30 summarizes the approval rates of top lenders in Los Angeles. Of these top lenders, Flagstar Bank, PMC Bancorp, Prospect Mortgage, and Metlife Bank had notably high approval rates (75 percent or greater).

G. Purchased Loans

Secondary mortgage marketing is the term used for pricing, buying, selling, securitizing and trading residential mortgages. The secondary market is an informal process of different financial institutions buying and selling home mortgages. The secondary market exists to provide a venue for lending institutions to raise the capital required to make additional loans.

1. History

In the 1960s, as interest rates became unstable, housing construction declined and the nation faced capital shortages as many regions, including California, had more demand for mortgage credit than the lenders could fund. The need for new sources of capital promoted Congress to reorganize the Federal National Mortgage Association (FNMA) into two entities: a private corporation (today’s FNMA) and a government agency, the Government National Mortgage Association (GNMA). In 1970, Congress charted the Federal Home Loan Mortgage Corporation (FHLMC) to purchase conventional loans. Both FHLMC and FNMA have the same goals: to increase the liquidity of the mortgage market and make homeownership more widely available to the average citizen. The two organizations work to standardize the documentation, underwriting and financing of home loans nationwide. They purchased loans from originators, hold them and issue their own debt to replenish the cash. They are, essentially, very large, massive savings and loan organizations. These two organizations set the standards for the purchase of home loans by private lenders in the U.S.

2. Fair Housing Concerns

During the peak of the housing market, the practice of selling mortgage loans by the originators (lenders that initially provided the loans to the borrowers) to other lenders and investors was prevalent. Predatory lending was rampant, with lenders utilizing liberal underwriting criteria or falsified documents to push loan sales to people who could not afford the loans. The

25 California Reinvestment Committee. “Stolen Wealth, Inequities in California’s Subprime Mortgage Market.” November 2001.

City of Los Angeles Page 70 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 originating lenders were able to minimize their financial risk by immediately selling the loans to other lenders or investors on the secondary market.

Purchased loans constituted the highest proportion of loans for Hispanic households. This could be a fair housing concern if the originating lenders aggressively marketed loans to households that could afford the loans, and then minimized their risks by selling the loans to investors on the secondary market.

Table 33 shows the various loan types purchased in the City of Los Angeles, as well as the race/ethnicity of the applicants in 2010. With the exception of home improvement loans, White applicants were the least likely to have their loans purchased. By contrast, Hispanic applicants were the most likely to have their loans purchased.

Table 33: Percent of Purchased Loans by Race (2010) Loan Type White Black Asian Hispanic Government-Backed Purchase 55.4% 61.1% 57.6% 75.0% Conventional Purchase 18.7% 25.0% 27.4% 32.9% Refinance 17.4% 18.3% 22.0% 22.3% Home Improvement 16.4% 6.3% 21.4% 15.7% Source: www.lendingpatterns.com, 2012.

H. Review of Lending Patterns by Specific Lender

Because the applicant profiles of some of the top lenders in the City of Los Angeles differ so significantly, this section looks at the underwriting outcomes of some of the major lenders in both jurisdictions.

Wells Fargo

Wells Fargo was the top lender for the City in 2010, capturing 17 percent of the market share. The overall approval rate for this institution (64 percent) was on par with the average for all lenders.

Black applicants had significantly lower approval rates compared to other racial/ethnic groups.

The underwriting outcomes for this particular lender did reveal a slight disparity in approval and denial rates based on the race/ethnicity of the applicant. During 2010, among all Wells Fargo applicants, Whites and Asians had the highest approval rate at 60 percent while Blacks had the lowest approval rate at 43 percent. Fallout was high (at around 25 percent), but was consistent across all racial/ethnic categories.

Bank of America

Bank of America was the second most prolific lender in the City behind Wells Fargo. During 2010, Bank of America had 15 percent of the market share in the City of Los Angeles. The overall approval rate for this institution (61 percent) was similar to the average for all lenders.

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Whites and Asians again had the highest approval rate (62 percent and 60 percent, respectively) with this lender and Blacks and Hispanics had slightly lower approval rates (54 percent for both). Fallout was moderate (at about 18 percent), but was consistent across all races/ethnicities.

Stearns Lending, Inc.

Stearns Lending has become one of the fastest growing full-service mortgage lenders in the country. Stearns was not identified as a top lender in the City, but it did have approximately one percent of the City’s market share in 2010. Stearns was identified in Table 31 as a lender with a higher than average proportion of Hispanic applicants, compared to all other lenders in the City. Approximately 31 percent of applications to this lender were submitted by Hispanic applicants in 2010, compared to just 17 percent for all other lenders in the City.

This lender focused on lending to Hispanic households. However, approval rate was the lowest for Hispanic households, along with the highest fallout rate.

The overall approval rate for this institution (57 percent) was slightly lower than the average for all lenders. During 2010, Hispanics had the lowest approval rate for this lending institution (50 percent) as well as the highest fallout rate (33 percent). By comparison, the overall approval rate for Stearns in 2010 was 57 percent and about 29 percent of applications to this lender were classified as fallouts.

PMC Bancorp

PMC Bancorp is a full service wholesale mortgage banker established in 1998 and headquartered in the City of Industry. During 2010, PMC was not particularly active in Los Angeles with just three percent of the market share in the City.

Minority applicants, particularly Asian and Hispanic applicants, constituted a significant portion of the loan applicants for this lender. However, there was a marked difference in loan approval rates between Asian applicants (65 percent) and Hispanic (54 percent) and Black applicants (43 percent).

PMC was identified in Table 31 as a lender with a higher than average proportion of Hispanic and Asian applicants, compared to all other lenders in the City. Specifically, approximately 21 percent of applications to PMC were submitted by Hispanic applicants in 2010, compared to 17 percent for all other lenders in the City. About 24 percent of applications to PMC were by Asian applicants, compared to just 10 percent for all other lenders.

The overall approval rate for this institution (77 percent) was significantly higher than the average for all lenders. During 2010, approval rates for this specific lender were the highest for Asian applicants (65 percent) and noticeably lower for Blacks and Hispanics (43 percent and 54 percent, respectively). This lender also had very high levels of fallout (about 37 percent overall), and noticeably higher fallout rates for its Black applicants (46 percent).

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Online Lending Institutions

Ally Bank and Quicken Loans are two of the country’s largest and most prolific online mortgage lenders. During 2010, Ally was the eighth most active lender in the City of Los Angeles, with two percent of the market share. While not identified as a top lender in the City of Los Angeles, Quicken did have about one percent of the market share in the City in 2010. Quicken and Ally were both identified as top lenders for Blacks in Los Angeles in Table 31. During 2010, Blacks made up seven percent of Ally’s applicant pool and five percent of Quicken’s applicant pool. On average, Blacks made up less than four percent of the applicant pool for all other lenders.

The popularity of online institutions among the City’s Black residents should be noted. Quicken and Ally are reputable lenders without a history of subprime lending, making them good choices for vulnerable borrowers. However, the noticeably lower approval rates for Black and Hispanic applicants and high fallout rates across the board for these two lenders may be an issue.

The overall approval rate for Ally (45 percent) was significantly lower than the average for all lenders. For Quicken, the approval rate in 2010 was 72 percent. During 2010, the approval rate for Black applicants at Quicken Loans was significantly low (52 percent) compared to the approval rates for Whites and Hispanics (74 percent and 76 percent, respectively). Black applicants for this lender also had the highest denial rate (38 percent) and the highest fallout rate (11 percent). For Ally Bank, approval rates were relatively consistent across all race/income categories but were the lowest for Hispanics (38 percent). Denial rates were also the highest for Hispanic applicants, and while fallout was high overall (40 percent), it was consistent for all races/ethnicities.

Both online-only lending institutions have better than average subprime lending records. Quicken reported no loans with a spread in 2010 and Ally had only eight loans with a reported spread for that time period. The magnitude of spread for Ally’s subprime loans was also quite small. The average spread for their eight subprime loans was under two points, well under the average of 2.3 for all other lenders.

I. Foreclosures

Foreclosure occurs when households fall behind on one or more scheduled mortgage payments. The foreclosure process can be halted if the homeowner is able to bring their mortgage payments current. If payments cannot be resumed or the debt cannot be resolved, the lender can legally use the foreclosure process to repossess (take over) the home. When this happens, the homeowners must move out of the property. If the home is worth less than the total amount owed on the mortgage loan, a deficiency judgment could be pursued. If that happens, the homeowner would lose their home and also would owe the home lender an additional amount.

Statewide, the number of foreclosures in 2011 declined substantially from the previous year. During the fourth quarter of 2011, a total of 12,355 Notices of Default (NODs) were recorded in Los Angeles County, a decrease of 13 percent from the fourth quarter of 2010. Figure 11

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 73 Public Review Draft May 30, 2012 illustrates the location of all the foreclosed properties within the City of Los Angeles during the fourth quarter of 2011. Dense clusters of foreclosed homes can be seen in the North and South Valley as well as South Los Angeles.

Homes can be in various stages of foreclosure. Typically, the foreclosure process begins with the issuance of a Notice of Default (NOD). An NOD serves as an official notification to a borrower that he or she is behind in their mortgage payments, and if the payments are not paid up, the lender will seize the home. In California, lenders will not usually file an NOD until a borrower is at least 90 days behind in making payments. In January 2012, 2,596 properties in Los Angeles were in this pre-foreclosure stage.26

Once an NOD has been filed, borrowers are given a specific time period, typically three months, in which they can bring their mortgage payments current. If payments are not made current at the end of this specified time period, a Notice of Trustee Sale (NTS) will be prepared and published in a newspaper. An NTS is a formal notification of the sale of a foreclosure property. In California, the NTS is filed 90 days following an NOD when a property owner has failed to make a property loan current. Once an NTS has been filed, a property can then be sold at public auction. According to foreclosure records, 3,649 properties in Los Angeles were in the auction stage of the foreclosure process in January 2012.

Many properties, however, are unable to be sold at public auction. In the event of an unsuccessful sale at auction, a property becomes classified as Real Estate Owned (REO) and ownership of it reverts back to the mortgage company or lender. In January 2012, the City of Los Angeles had a total of 1,147 bank owned properties.

Foreclosures have a destabilizing effect on a neighborhood. Many foreclosed homes are not maintained or secured, causing theft and vandalism. Furthermore, many households facing potential foreclosures, particularly minority and senior households, fall victim to scams that claim to assist them with loan modifications by paying a fee.

26 http://www.foreclosureradar.com/

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Figure 11: Foreclosures in the City of Los Angeles (October-December 2011)

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 75 Public Review Draft May 30, 2012 Chapter 4: Public Policies

Public policies may affect the pattern of housing development, the availability of housing choices, and access to housing. This chapter reviews the various policies that may impact housing choices in Los Angeles. Policy and planning documents adopted by the City and associated agencies27 were reviewed to evaluate the following potential impediments to fair housing choice and affordable housing development, including those related to:

. Local municipal, building, occupancy, health, and safety codes; . Public policies and building approvals that add to the cost of housing; . Residential development fees; . Administrative policies affecting housing activities; . Policies that restrict housing or community development resources for areas of minority concentration, or policies that inhibit employment of minorities or individuals with disabilities; . Interdepartmental coordination between local agencies that provide housing or community development resources to areas of minority concentration or to individuals with disabilities; and . Community representation on planning and municipal boards and commissions.

A. Local Plans and Codes

Higher density housing reduces land cost on a per-unit basis and can facilitate the development of affordable housing. Restrictive municipal codes that require unusually large lot or building sizes can substantially increase housing costs and can impede housing production. The City directs the amount and type of residential development that occurs through a hierarchy of planning and regulatory documents.

1. General Plan

The Los Angeles General Plan is at the top of the hierarchy of land use plans affecting the location and development of housing. The General Plan provides a general framework for land use policies and decision-making. Land uses under the General Plan are governed by community plans. The City of Los Angeles is divided into 35 community planning areas, plus the Port of Los Angeles and Los Angeles World Airports. The community planning areas are listed in Table 34 and shown in Figure 12.

27 Associated agencies are independent legal entities created by the City of Los Angeles such as the Housing Authority of the City of Los Angeles and the joint Los Angeles City-County Homeless Services Authority.

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Table 34: Community Plan Areas List North Valley Subregion . Arleta – Pacoima . Northridge . Sunland - Tujunga - Lakeview Terrace - Shadow . Chatsworth - Porter Ranch Hills - East La Tuna Canyon . Granada Hills – Knollwood . Sun Valley - La Tuna Canyon . Mission Hills - Panorama City - North Hills . Sylmar South Valley Subregion . Canoga Park - Winnetka – Woodland Hills - West Hills . Reseda - West Van Nuys . Sherman Oaks - Studio City - Toluca Lake - . Encino – Tarzana Cahuenga Pass . North Hollywood - Valley Village . Van Nuys - North Sherman Oaks West Los Angeles Subregion . Bel Air – Beverly Crest . Venice . Brentwood - Pacific Palisades . Westchester - Playa Del Rey . Los Angeles World Airport . West Los Angeles . Palms - Mar Vista - Del Rey . Westwood Central Subregion . Central City . Westlake . Central City North . Wilshire . Hollywood East Los Angeles Subregion . Boyle Heights . Silver Lake - Echo Park – Elysian Valley . Northeast Los Angeles South Los Angeles Subregion . South Los Angeles . West Adams - Baldwin Hills - Leimert . Southeast Los Angeles Harbor Subregion . Harbor Gateway . Port of Los Angeles . San Pedro . Wilmington - Harbor City

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Figure 12: Community Planning Areas

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General Plan Land Use Element

The Los Angeles Citywide General Plan Framework Element establishes the broad overall policy and direction for the entire General Plan. The City’s 35 community plans collectively comprise the Land Use Element of the General Plan. Together, the Framework Element and community plans, set forth the City’s policies for guiding local development. These policies, and their implementation through the City’s Zoning Ordinance, establish the amount and distribution of land to be allocated for various uses throughout the City.

Table 35 lists General Plan land use categories (both residential and non-residential categories) that permit housing. Also listed are the corresponding zoning and residential density ranges. As shown, the City of Los Angeles permits a wide range of housing densities to accommodate varying housing types throughout the communities.

Table 35: General Plan Land Use Categories Residential General Plan Density (Units / Corresponding Zoning1 Land Use Category Net Acre) Minimum A1, A2, RE 40, OS 0.4 – 1 Very Low RE 20, RA, RE 15, RE 11 2 – 3 Very Low I RE 20, RA 2 Very Low II RE 14, RE 11 2 – 3 Low RE 9, RS, R1, RD 6, RD 5, RU 4 – 12 Low Medium I RD RD 3, RD 4, RZ 2.5, RZ 3, RZ 4, RU 10 – 17 Low Medium II RW 1, RD 1.5, RD 2 18 – 29 Medium R3, RAS3 30 – 55 High Medium R4, RAS4 56 – 109 High R5 110 – 218 Neighborhood District C1, C1.5, C4, C2 30 – 109 Community Center CR, C4, C2 30 – 109 Regional Center CR, C1.5, C4, C2 30 – 109 General Commercial C2 30 – 109 Boulevard-Mixed Use CR, C1, C1.5, C2, C4 30 – 109 Industrial-Light CM, MR 1, MR 2, M1, M2 30 – 109* Industrial-Transit CM, M1, M2, C2 30 – 109* *Only watchman and caretaker residences are permitted in the MR-1, MR-2, and M1 zones. No residential dwelling units are permitted in the M2 zone. Sources: City of Los Angeles, Department of City Planning website at http://cityplanning.lacity.org/cwd/framwk/chapters/03/03.htm, accessed on February 1, 2012; City of Los Angeles, Municipal Code, Chapter I, accessed on February 1, 2012.

Each community planning area has its own land use plan that specifies the acreages of permitted land uses. Residential land use categories vary from Minimum (which corresponds with zoning categories of open space, agricultural, and residential estate at one dwelling unit per acre or less) to High (which corresponds with zoning category R-5 at densities as high as 218 dwelling units per acre).

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Community plans also provide for commercial land use categories. These categories include Neighborhood, General, Community Regional, Highway, and Limited. The commercial land use categories correspond with one or more of seven commercial zones that permit residential development according to either R-3 or R-4 zoning standards. The City’s General Plan, as expressed through land use policies for each of the community plans, offers a range of housing choices and does not represent a potential impediment to providing equal housing opportunity.

General Plan Housing Element

The Housing Element of the General Plan, a state-mandated and state-reviewed document, is the City’s comprehensive statement of housing needs and strategies to address those needs. The Housing Element must include an analysis of impediments (constraints) to housing and include policies and programs that address equal housing opportunity. An important component of state review is a determination that a local jurisdiction’s policies do not unduly constrain the maintenance, improvement, and development of housing for all income levels and household types, including those with special needs (i.e., seniors, disabled, homeless, female- headed households, and large households).

Adopted in 2009, the Los Angeles Housing Element contains the following goals and objectives:

Goal 1: A City where housing production and preservation result in an adequate supply of ownership and rental housing that is safe, healthy, sanitary and affordable to people of all income levels, races, ages, and suitable for their various needs.

Objectives 1.1 Plan the capacity and develop incentives for the production of an adequate supply of rental and ownership housing for households of all income levels and needs.

1.2 Develop incentives for the preservation of quality rental and ownership housing for households of all income levels and special needs.

1.3 Forecast changing housing needs over time in relation to production and preservation needs.

1.4 Promote an equitable distribution of affordable housing opportunities throughout the City.

1.5 Reduce regulatory and procedural barriers to the production and preservation of housing at all income levels.

Goal 2: A City which housing helps to create safe, livable and sustainable neighborhoods.

Objectives 2.1 Promote safety and health within neighborhoods.

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2.2 Promote sustainable neighborhoods that have mixed-income housing, jobs, amenities, services and transit.

2.3 Promote sustainable buildings, which minimize adverse effects on the environment and minimize the use of non-renewable resources.

2.4 Promote livable neighborhoods with a mix of housing types, quality design and a scale and character that respects unique residential neighborhoods in the City.

Goal 3: A City where there are housing opportunities for all without discrimination.

Objectives 3.1 Assure that housing opportunities are accessible to all residents without discrimination on the basis of race, ancestry, sex, national origin, color, religion, sexual orientation, marital status, familial status, age, disability (including HIV/AIDS), and student status.

3.2 Promote fair housing practices and accessibility among residents, community stakeholders and those involved in the production, preservation and operation of housing.

Goal 4: A City committed to ending and preventing homelessness.

Objectives 4.1 Provide an adequate supply of short-term and permanent housing and services throughout the City that are appropriate and met the special needs of persons who are homeless or who are at high risk of homelessness.

4.2 Promote outreach and education to: homeless populations; residents; community stakeholders; health, social service and housing providers and funders; criminal justice system agencies; and, communities in which facilities and services may be located.

Compliance with State Housing Element Law The California Department of Housing and Community Development (HCD) has found the current Los Angeles Housing Element in substantial compliance with state law. This compliance status affirms that the City has evaluated its public policies as potential constraints to the maintenance, improvement, and development of housing and has adequately addressed all potential constraints through housing policies and programs.

Housing Programs Promoting Fair Housing Choice Los Angeles has adopted a number of programs in its Housing Element to promote fair housing choice. The programs either:

. Directly further the City’s fair housing goals and objectives; . Expand or preserve housing for special needs groups that often face housing discrimination;

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. Provide replacement housing for individuals or groups disproportionately affected by public and private redevelopment activities; and/or . Target neighborhoods or housing units that are disproportionately affected by unsafe or illegal housing management practices.

Every housing program contained in the Housing Element has some impact directly or indirectly on expanding housing choice for all, either by increasing the supply of housing or the types of housing being built, making housing more affordable, or improving the quality of housing. Only programs that specifically address the objectives listed above are identified here (refer to the Housing Element for detailed description of these programs).

Programs that Promote Fair Housing Goals and Objectives Provision of fair housing services directly furthers fair housing goals and objectives in the City. Fair housing research that is conducted periodically can help the City in crafting the services to respond to nature and extent of housing discrimination in Los Angeles.

Education for Property Owners: Provide continuing education to property owners and managers about housing management practices and regulations, including: training on environment, health and safety; training on sound management techniques; training on applicable laws; training on lawful tenant screening practices; training on tenants’ rights. Establish a program for landlords to ensure best practices. Establish a training and education program for police officers regarding tenant and landlord rights.

Fair Housing Awareness Training Program (Neighborhood Councils): Explore establishing a program to provide information and training to Neighborhood Councils and other community organizations on fair housing issues.

Fair Housing Research: Conduct studies to evaluate the level of housing discrimination in the City of Los Angeles. Develop action items per results of studies.

Office of the City Attorney Dispute Resolution Program (DRP): Refer persons with landlord/tenant and neighbor/neighbor housing-related conflicts, and housing disputes concerning physical access (i.e., architectural) and HIV/AIDS discrimination (i.e., rental discrimination) who utilize DODs referral services to the OCAs Dispute Resolution Program for medication, conciliation and facilitation services.

Citywide Fair Housing Program: Through a contract with the Housing Rights Center, provide resolution to illegal housing discrimination by accepting and investigating housing discrimination complaints that allege a violation of federal, state, or local fair housing law (i.e., complaints concerning advertising, lending, insurance, steering, blockbusting and hate crimes). Provide remedies for valid complaints, including conciliations, legal action and administrative referrals to state and federal fair housing agencies. Provide counseling, education, and training about fair housing laws, rights, and responsibilities to persons residing, seeking housing, or providing housing in the City of Los Angeles. Conduct proactive testing to determine patterns and practices of discrimination.

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Awareness of Special Needs Housing (Neighborhood Councils): Pursue funding for community organizations and advocates to conduct outreach and disseminate information regarding housing approaches for special needs populations.

Expand or Preserve Housing for Special Needs Groups Many barriers exist in providing affordable and suitable housing for persons with special needs (e.g. elderly, large families, and persons with disabilities). Such barriers include, but are not limited to, a lengthy development review process, limited land available for development, and regulatory constraints (e.g. building and zoning codes). Programs aimed at reducing the impacts of these constraints, such as the ones listed below, will help increase or preserve housing for persons with special needs.

Housing for Senior and Disabled Persons: Assist developers in developing housing for seniors and for disabled persons through streamlined land use entitlement procedures for a variety of housing types, including: Independent Senior Housing, Assisted Living Care Housing, Skilled Nursing Care Housing and Alzheimer’s/Dementia Care Housing.

Housing for All Household Sizes and Types: Fund the development of affordable large family housing units (families of 5 or more members) and establish affordable rent levels based upon the allowable family size occupying the large unit, as published and utilized by the City. Fund the development of housing for intergenerational households, including grandparents caring for grandchildren. Fund the development of small housing units, including efficiency units, for small households of 1 or 2 persons.

Innovative Housing Unit Design: In the review of development proposals, encourage developers to design and develop modular housing units that employ universal design in order to accommodate different life stages with minimal structural changes. Meet with developers to: (1) encourage developers to design for work-at-home needs; (2) encourage alternative multi-family residential design.

Housing Choice Vouchers for Disabled and Elderly Households: Under specialized programs, provide rental assistance to very low income persons with disabilities and to elderly persons in the form of vouchers that cover a share of the monthly rental payment of privately-owned market rate housing.

Amend the Zoning Code to Facilitate Non-Conventional Housing: Identify modifications needed in the Zoning Code to facilitate innovative housing types, such as shared housing, congregate living, modular and pre-fabricated housing, and group quarters, including consideration of parking requirements, open space requirements, and other development standards, and the need to better regulate through conditional use permits.

Childcare Facilities: Facilitate the development of childcare facilities in residential and commercial development, activity centers and near park and ride facilities.

Reasonable Accommodation: Monitor implementation and assess need for amendments to the reasonable accommodation provision in the Zoning Code which facilitates modifications to housing units occupied by persons with disabilities. Develop a staff training program

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regarding implementation of the reasonable accommodation provision. Improve application forms, outreach, advertising and informational materials to increase use of the reasonable accommodation provision by people with disabilities.

ADA Compliance Officer: Work with all City departments to coordinate the City’s compliance with ADA and the Rehabilitation Act of 1973. Monitor compliance and ensure reasonable accommodation to people who use City programs and facilities.

Housing Information Clearinghouse: Consolidate available housing unit databases across departments to provide an on-line, one-stop housing information clearinghouse for homebuyers and renters seeking for-sale and rental housing. Continue to provide referrals to Departments through the City’s 3-1-1 Hotline.

Domestic Violence Shelter Program: Provide safe and secure emergency and transitional shelter, case management and related supportive services to domestic violence survivors and their children through contracted operators.

Overnight Shelter (Winter Shelter and Year-Round Shelter): Provide temporary shelter to homeless men, women and families through a Winter Shelter program (December 1 through March 15) and Year-Round Shelter program. Provide vouchers for low-cost hotels and motels for persons not suited to large group shelters (this includes parents with minor children, elderly persons, and people with communicable diseases).

Rental Assistance for Homeless Persons with Disabilities: Provide rental assistance and supportive services for homeless persons with disabilities, specifically those with serious mental illness, chronic substance abuse problems and/or HIV/AIDS.

New Resources for Housing Serving the Mentally Ill: Coordinate with the County Department of Mental Health to access and leverage mental health funding under the MHSA.

Access New Resources and Services for the Homeless: Monitor federal, state and county legislative and budgetary initiatives that affect homeless persons, including homeless subpopulations with special needs, such as persons with disabilities.

HOPWA Emergency Shelter and Transitional Housing Program: Fund the acquisition, new construction and renovation of existing short-term residential facilities serving persons living with HIV/AIDS.

HOPWA Supportive Services for Persons Living with HIV/AIDS: Assist low income persons living with HIV/AIDS, and their families, with access to permanent housing, financial independence, stable employment, health care, nutrition, meal preparation/delivery, food banks, and assistance with legal issues.

HOPWA Rental Assistance for Persons Living with HIV/AIDS: Provide short and long term financial assistance to low income persons living with HIV/AIDS, and their families.

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HOPWA Housing Development for Persons Living with HIV/AIDS: Fund the acquisition, rehabilitation, and/or new construction of affordable rental housing for low income persons living with HIV/AIDS and their families.

Housing and Services Planning for Persons Living with HIV/AIDS: Convene monthly meetings of the Los Angeles Countywide HOPWA Advisory Committee (LACHAC). Provide advice regarding administration of the HOPWA Program and planning and policy issues.

Permanent Housing (for Persons with Disabilities): Provide long-term housing with supportive services designed to enable homeless persons with mental and physical disabilities to live as independently as possible in a permanent setting.

Citywide Rent-to-Prevent-Eviction Program: Provide one-time assistance to at-risk individuals with disabilities or families with low and very low incomes in order to prevent eviction and homelessness.

New Resources for Rental Assistance: Develop additional subsidies from existing sources and/or create new resources for short-term and long-term rent assistance to prevent eviction and to enable homeless persons to access existing housing. Pursue rental subsidies under the County’s AB2034 mental health services program and the Mental Health Services Act (MHSA) programs. Pursue expansion of supplements to County Department of Public Social Services (DPSS) rental assistance.

Zoning for Health Facilities: Facilitate siting of housing and services for all persons, including those with special needs. Eliminate Zoning Code provisions that restrict locations of public health and treatment programs, including day treatment facilities and residential based treatment programs, in order to comply with federal and state fair housing laws.

Single-Family Rehabilitation: Provide minor home repair services and installation of safety, security and accessibility features (i.e., locks, peep holes, grab bars, automatic gas shut-off valves) for low-income, elderly and disabled residents. Services are provided by City-approved contractors through the Handyworker and Home Secure Programs.

Amend the Zoning Code to Facilitate Non-Conventional Housing: Identify modifications needed in the Zoning Code to facilitate innovative housing types, such as shared housing, congregate living, modular and pre-fabricated housing, and group quarters, including consideration of parking requirements, open space requirements, and other development standards, and the need to better regulate through conditional use permits.

Modifications to Second Unit (“Granny Flat”) Process: Identify obstacles to implementing State law enabling second units on single family lots (AB 1866), and propose Code amendments to address the obstacles. Include a specific analysis and mitigation of the constraints to the second unit ordinance.

Reduced Requirements for Housing near Transit: Provide additional “trip credits” for residential development that is located in close proximity to Metro fixed rail and fixed

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guideway stations and transit stops with frequent (15 minute frequency or less between 7:00 am and 6:30 pm) bus service. Provide additional trip credits for mixed-use development and mixed income development located near transit. Reduce project required traffic mitigations.

Computerized Information Center/Information and Referrals for Persons with Disabilities: Provide assistance to callers seeking social service programs for homeless services and housing resource referrals in times of need and crisis. Assess the need/crisis via client intake, locate appropriate resource/service provider, and explain programs offered by the community-based organization and/or government agency.

HOPWA Centralized Countywide Housing Information Services Clearinghouse: Fund outside agencies to maintain a centralized, countywide HIV/AIDS-related housing information clearinghouse. Provide referral information for housing services from emergency and transitional housing to hospice and permanent housing.

Zoning and Development Standards for Shelters: Identify and adopt changes to the Zoning Code to facilitate by-right siting of a greater variety of shelter and transitional housing facilities throughout the City (such as larger facilities, different development standards, different performance standards, etc.).

Provide Replacement Housing for Individuals or Groups Disproportionately Affected by Public and Private Redevelopment Activities A disproportionate number of minority households are low and moderate incomes and living in older neighborhoods of the City. Therefore, minority households may be more likely than other households to be displaced due to redevelopment activities.

Residential Hotel and Single Room Occupancy (SRO) Hotel Preservation: Preserve residential hotels and SROs in accordance with the Residential Hotel Unit Conversion and Demolition Ordinance (RHO) and in accordance with CRA/LA Development Guidelines and Controls for residential hotels and SRO hotels in downtown that provide housing for extremely low and very low income residents.

Regulation of Conversion and Demolition of Residential Hotels: In accordance with the Residential Hotel Unit Conversion and Demolition Ordinance (RHO), review applications for the demolition or conversion of residential hotels to assure compliance with the ordinance. Require an in-lieu fee or one-for-one replacement of any units demolished or converted.

Mobile Home Park Preservation: Preserve residential use of mobile home parks that are in RMP zones and/or within residential areas. Support legislation that expands local authority over conversion of mobile home parks to ownership structures. Provide relocation benefits to mobile home park occupants. Facilitate access to purchase and mortgage assistance to tenants in the event of conversion to ownership.

Residential Rehabilitation of Obsolete Public Housing: Identify obsolete public housing sites and implement major rehabilitation, redesign, and/or demolition and replacement, including modifications to housing units, office and community spaces. Improvements

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include changes in density, unit mix, site design, amenities, traffic circulation, and parking patterns without a net loss of affordable housing at current levels of affordability. Continue rehabilitation efforts at Harbor View. Initiate rehabilitation efforts at Jordan Downs.

Target Neighborhoods or Housing Units that are Disproportionately Affected by Unsafe or Illegal Housing Management Practices A disproportionate number of minority households are low and moderate incomes and living in older neighborhoods of the City, where unsafe or illegal housing management practices are more prevalent. As discussed in Chapter 3, Community Profile, minority households are disproportionately affected by lead-based paint hazards. Slumlord practices and related habitability issues also tend to impact minority households more than the general public.

Systematic Code Enforcement Program (SCEP): Inspect all multi-family rental housing regarding maintenance, use and habitability for compliance with the Housing Code and the California Health and Safety Code at least once every four years and respond to tenant complaints. Re-inspect non-compliant properties until compliance is achieved.

Residential Rehabilitation: For properties of 1-4 units, provide loans to low income property owners or owners of properties occupied by low income tenants for rehabilitation and general improvement costs. In the case of the CRA/LA Neighborhood Home Rehabilitation Loan Program, target community revitalization and redevelopment areas with both interior (code and related upgrades) and exterior (neighborhood beautification and stabilization) improvements. Provide direct loans to property owners and interest write-downs to participating lenders for direct loans to property owners to fund property upgrades for building code compliance. Under special targeting of the Small Rental Rehabilitation Program, provide loans to property owners of buildings with 5-28 units for general habitability upgrades as well as for upgrades for building code compliance.

Utility Maintenance Program: Prevent termination of utility service and displacement of tenants in multi-family master-metered properties when owners fail to pay utility bills. Apartment buildings are referred to the program, and tenants pay rent to the City and avoid utility shut-off, until the property owner pays all delinquent utility bills.

Lead-Safe Housing: Privately-owned Housing Units: Test and abate lead-based paint in residential rehabilitation and repair projects serving lower income households with children. Disseminate information to residents and property owners regarding lead-safe repair and rehabilitation practices. Conduct outreach to tenants regarding lead hazards, how to identify such hazards, and how to report hazards.

Lead-Safe Housing (HACLA Housing Units): Under the Lead-Based Paint Evaluation and Abatement Program, conduct environmental assessments and testing for lead-based paint at public housing sites and within individual units. Abate lead-based paint hazards. Conduct an extensive public education process.

Urgent Repair Program: Order property owners to carry out immediate repairs within 48 hours of citation for life-threatening conditions in residential buildings. LAHD carries out

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repairs if not completed by the owner, and places buildings in the Rent Escrow Account Program to protect tenants.

Citywide Nuisance Abatement Program: Coordinate inter-departmental nuisance abatement strategies to target chronic problem properties with illegal activities and gang problems. Coordinate interdepartmental response to neighborhoods experiencing a high concentration of crime and nuisance plagued problem properties.

Housing Enforcement (Inter-Agency Slum Housing Task Force): Coordinate multi-agency (LAHD, LAFD, and LA County Department of Health Services) enforcement of substandard rental housing buildings through issuance of Orders to Comply and prosecutions of violations of the Zoning Code, California Housing Code, Building Code, Fire Code and Health and Safety Codes. Bring civil receivership and Unlawful Business Practice lawsuits against slumlords engaged in illegal management practices. Prosecute violations of LAMC’s Rent Stabilization Ordinance.

New Ownership of Substandard Housing: Evaluate and design an implementation strategy for the use of court-appointed receivers to assume operation of substandard housing, abate slum conditions and transfer the property to a new, permanent owner.

Rent Escrow Account Program (REAP): Administer escrow accounts for substandard residential buildings in which owners have consistently refused to comply with City Housing Code. Tenants continue to pay their rent, but funds accrue to the City- administered escrow account, rather than to the landlord. Under the Rent Reduction Program (RRP) and Habitability Enforcement Program (HEP) components of REAP, tenants may pay lower rents until the apartment building’s services and conditions are restored to a habitable level. Pursue program improvements, such as limiting the time a property remains in REAP, requiring tenants to pay rent into the escrow account, and improving the notification process. Pursue progressive reduction in number of annual cases.

2. Consolidated Plan

As a recipient of federal housing and community development grant funds, the City of Los Angeles is required to adopt a Consolidated Plan that identifies and prioritizes housing and community development needs, analyzes barriers to affordable housing, and contains a Strategic Plan to address community needs and remove affordable housing barriers. The current Consolidated Plan covers the five-year period between 2008 and 2013.

The Consolidated Plan also directs the City’s expenditure of funds under several programs operated by the federal U.S. Department of Housing and Urban Development (HUD). These programs are:

. Community Development Block Grant (CDBG) . Home Investment Partnership Act (HOME) . Housing Opportunities for Persons with AIDS (HOPWA)

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. Emergency Shelter Grant (ESG)28

Programs operated by HUD provide the largest source of funding for the City in provision of needed public services, housing, economic development, neighborhood improvements, and other critical program needs. The City files an annual Action Plan with HUD, which provides information on the activities that the City will undertake through the five federal grant programs covered in the Consolidated Plan.

The Consolidated Plan identifies three core priorities for the targeting and expenditure of HUD resources; each is described below. Because of the vast extent of need in Los Angeles, all priorities are considered of equal rank:

Priority One: Youth Development and Education: Over one-third of the population of the City of Los Angeles is under the age of 18, one of the largest percentages of young people in a major American city. The future health and vitality of Los Angeles is directly tied to the education and development of our youth. Priority will be given to those programs that foster opportunities for increased youth development, create the conditions to raise student achievement, or promote safe and violence-free informal learning environments to protect and enrich our children’s lives.

Priority Two: Job Creation and Securing Our Economic Future: New opportunities for economic success and stability for families throughout the City must be generated and sustained. Priority will be given to those programs that attract new companies to Los Angeles, assist local and emerging businesses grow, or retain and create well-paying jobs.

Priority Three: Affordable and Workforce Housing: With the continuing increase in housing costs, housing that is affordable and safe must be created and maintained. Priority will be given to those programs that assist Los Angeles’ workforce in finding affordable rental and homeownership opportunities that promote the development of housing near areas of job creation, and that maintain the City’s current affordable housing units.

3. Specific Plans

Community plan land uses, and the corresponding zoning, may be altered through the preparation of specific plans, as provided under California law. Specific plans may contain development standards that deviate from the City’s zoning code standards. Los Angeles has adopted 44 specific plans, covering both new growth areas and developed communities. Typical issues addressed by Specific Plans include land uses, density, FAR, building design, height, landscaping, and parking requirements.

28 The Homeless Emergency Assistance and Rapid Transition to Housing Act of 2009 (HEARTH Act) changed the name to “Emergency Solutions Grant.”

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Palmer v. City of Los Angeles29

Some of the City’s specific plans included requirements that developers set aside a portion of new housing units for lower and moderate income households or an in-lieu fee. An analysis of impediments to fair housing choice must be careful not to substitute or conflate housing affordability policy with policies intended to affirmatively further fair housing. Although household income is not a characteristic addressed by fair housing laws, it is appropriate to recognize that a lack of affordable housing can have a disparate impact on housing choice, on the basis of characteristics protected by fair housing laws. The “inclusionary housing” requirements to set aside a portion of new development for affordable housing were established, in part, to protect certain City neighborhoods from displacement and gentrification caused by redevelopment that is encouraged by specific plan implementation.

In 2009, a developer challenged the Central City West Specific Plan’s affordable housing requirements as a violation of the Costa-Hawkins Act, which allows residential landlords to set rent levels at the start of a tenancy. In Palmer v. City of Los Angeles, the California Court of Appeal agreed with the developer and invalidated the specific plan’s affordable housing requirements. The decision is specific to affordable housing requirements for rental housing and does not apply to ownership housing. The decision also suggests that requiring rental developments to pay an impact fee based on the community’s need for affordable housing as opposed to a fee that is tied to the amount of housing produced could be permissible. At the present time, Los Angeles does not mandate the integration of affordable units within new housing developments as a result of the California Court of Appeal decision in a case challenging the City’s inclusionary housing requirements in the Central City West Specific Plan (Palmer v. City of Los Angeles).

4. Redevelopment Project Area Plans

The Los Angeles Community Redevelopment Agency of the City of Los Angeles (CRA/LA), established in 1948, was dissolved by the State of California effective February 1, 2012. Prior to dissolution, redevelopment had been used by the City as a tool to remove blighted conditions, provide economic opportunities, create housing for lower and moderate income residents, renovate or replace deteriorated or dilapidated structures, develop vacant infill and under-used properties, and provide public infrastructure and other improvements to support private investment in deteriorated areas of Los Angeles. Implementation of the City's 32 Redevelopment Project Plans had provided a means for increasing housing choices for low and moderate income residents and those with special needs.

Dissolution of CRA significantly compromises the City’s ability in providing affordable housing, especially housing for persons with special needs, which typically requires deeper subsidies.

Since the mid-1980s, CRA/LA had committed between significant resources to providing affordable housing for low and moderate income residents, well above the minimum requirements of state law. As a result of the CRA/LA’s dissolution, the City expects to lose approximately $50 million annually for programs that benefit lower and moderate income

29 Palmer/Sixth Street Properties, L.P. v City of Los Angeles (2009), 175 Cal. App. 4th 1396

City of Los Angeles Page 90 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 residents throughout Los Angeles. Historically these funds had been used to expand housing opportunities for protected classes through production, rehabilitation, and preservation such as, but not limited to:

. Assistance for new construction serving seniors and disabled persons, and innovative housing unit design;

. Residential rehabilitation for low income property owners and property owners with low income tenants, including seniors and disabled persons; and

. Housing preservation through residential and single room occupancy hotel preservation, transfer of ownership, new ownership of substandard housing, and real estate owned acquisition.

Following the dissolution of the CRA/LA, the City’s Housing Department assumed responsibility for CRA/LA’s former housing functions by Council and Mayoral action. The City will continue to seek and advocate for alternative funding sources to continue and expand these vital programs.

5. Zoning

Capacity to Accommodate Additional Housing

Each of the land use designations set forth in the City’s General Plan corresponds to one or more of the zoning districts established in the Zoning Code. The density requirements specified in the Zoning Code adhere to the General Plan Framework Element and community plan land use plans. The City’s zoning districts allow for a variety of housing types and densities – from agricultural residential at less than one dwelling unit per acre to high density at over 200 dwelling units per acre.

Table 36 summarizes sites with additional housing capacity by subregion as reported in the City’s Housing Element, adopted in 2009. The City identified 21,522 sites with excess capacity to accommodate a minimum of 382,851 units. Of the identified sites, the City determined that over 90 percent are zoned to allow more than 30 units per acre, the minimum density necessary under California law to assume suitability for lower income housing development.

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Table 36: Dwelling Unit Capacity by Subregion Subregion Sites Acres Unit Capacity North Valley 1,294 1,416 28,202 South Valley 3,045 2,146 72,252 West 1,938 843 40,434 Central 9,280 2,484 177,665 East 1,281 505 12,188 South 4,500 1,161 47,603 Harbor 185 114 4,507 Total 21,523 8,669 382,851 Source: City of Los Angeles, 2006-2013 Housing Element, January 2009.

Alternative Housing Types that Can Expand Housing Choice

The City of Los Angeles Zoning Code defines several alternative housing types that increase housing choices for special needs groups and lower income residents of Los Angeles.

Secondary (Accessory) Living Units: Under the requirements of state law, the City is required to permit second units in single family residential zones according to a ministerial permit process. The City complies with State law, allowing for secondary units in single-family zones by right as long as the units meet standards per State law. Furthermore, the Zoning Administrator is authorized to review and approve secondary dwelling units that do not comply with State standards in the A, RA, RE, RS, R1, RMP and RW1 zones via a Conditional Use Permit process.

Factory-Built Homes and Mobilehome Parks: State law requires factory built homes and mobilehomes complying with the federal Manufactured Housing Construction and Safety Standards Act of 1974 and that are installed on a permanent foundation be permitted on any parcel on which the City allows conventional single-family homes that are built on site and under the same development standards as the “site-built” homes. The City’s Zoning Ordinance only expressly allows factory-built housing units in the RU zone. Mobilehome parks are permitted in the City’s Residential Mobilehome Park (RMP) district; this use and zoning district was established as a means to encourage the provision of affordable housing by allowing both the retention and expansion of existing, as well as the establishment of new, mobile home parks.

Shelter for the Homeless: The City permits homeless shelters by right in R4 (with performance standards), RAS 4, R5, C1.5, C2 (with performance standards), C4, C5, and CM zones. In addition, as a public benefit, homeless shelters of under 30 beds are allowed by right in R3, M1, M2 and M3 zones provided that they comply with certain performance standards. The performance standards limit homeless shelters to 30 beds designed to serve not more than 30 people and require that shelters be located at least 600 feet from another such shelter. Winter emergency shelters are allowed by right in any zone on a government owned or operated site or in R3, RAS3, R4, RAS4, R5, C2, C4, C5, CM, M1, M2 and M3 zones if operated by a charitable organization. Housing Element indicates significant development capacity in these zones to accommodate residential uses and facilities, including emergency shelters for the homeless.

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Specifically, the 2006-2014 Housing Element identified more than 10,200 sites ranging from 0.02 to 22.90 acres in size with appropriate zoning to accommodate homeless shelters.

Boarding or Rooming Houses: The City permits boarding and rooming houses in the R3 through R5 zones and in commercial zones. These provisions of the City’s Zoning Code greatly expand housing opportunities for individuals who cannot afford, or who may prefer the benefits of, a boarding or rooming home over a conventional dwelling unit.

Senior Housing: Under federal law, housing discrimination against families with children is permitted only in housing developments in which all residents are 62 years of age or older or where at least 80 percent of the occupied units have one person who is 55 years of age or older. California law, with narrow exceptions (caretakers aged 45 years or older), requires all residents to be “senior citizens” or “qualified permanent residents,” pursuant to Civil Code Section 51.3. Senior housing may be provided in a variety of housing types, ranging from single family to multi-family, and is allowed across the City’s zoning districts where residential uses are allowed. In an effort to support and facilitate the provision of unique, very specialized types of service-rich, congregate living options for elderly residents aged 62 years or older, the City’s Zoning Code incorporates definitions and identifies locations where such housing types are allowed by-right. These specialized housing types incorporate a variety of uses, and prior to these changes to the Zoning Code, these particular senior housing types, listed below here, had to pursue lengthy approval procedures, such as a conditional use permit or variance, and/or a multitude of separate approvals. In short, these provisions enhance the City’s ability to provide for and improve access to a variety of housing types:

. Eldercare Facilities: “Functionally operated facility, which provides residential housing for persons 62 years of age and older, and which combines in one facility, two or more of the following housing types: Senior Independent Housing; Assisted Living Care Housing; Skilled Nursing Care Housing; and/or Alzheimer's/Dementia Care Housing.” The City permits “Eldercare Facilities” in the R4 and R5 zones and in commercial zones. Eldercare facilities serving six or fewer persons are allowed by right in any zone.

. Senior Independent Housing: “Residential housing that consists of dwelling units for persons 62 years of age and older and may include common dining areas or other community rooms. Full time medical services shall not be provided on the premises. It may be a component of an Eldercare Facility.” These facilities are permitted in the R3 through R5 zones and commercial zones.

. Assisted Living Care Housing: “Residential housing that is licensed by the California Department of Social Services and provides assistance to people 62 years of age or older who require assistance with two or more non-medical activities of daily living as defined in the Department of Social Services licensing requirements. The residential units may consist either of dwelling units or guest rooms. Full time medical services shall not be provided on the premises. The housing may be a component of an Eldercare Facility.” These facilities are permitted in the R3 through R5 zones and commercial zones.

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. Retirement Hotels: A building with guest rooms and/or dwelling units in which 90 percent or more of the occupants are age 62 or older and for which a covenant running with the land is recorded limiting the use as such for as long as the building contains any guest rooms. These facilities are permitted in the R4 and R5 zones and in most commercial zones.

SRO, Transitional, and Supportive Housing: Single-room occupancy (SRO), transitional, and supportive housing are multi-family housing and are permitted where multi-family is permitted.

Historic Preservation

Section 12.20.3 of the Los Angeles Municipal Code establishes a historic preservation “HP” overlay zone. The purpose of the overlay zone is to preserve and enhance sites, structures, and areas with historic, architectural, cultural, or aesthetic significance. Development activities within each historic preservation overlay zone are subject to review by a five-member Historic Preservation Board (a separate board is established for each zone).

Projects subject to review by the Board include: (1) any activities affecting a designated structure or site that would alter its outward appearance; and (2) new construction within a historic preservation zone to ensure compatibility with designated structures and sites.

As of October 2010, the City had established 29 historic preservation overlay zones (HPOZ). The City’s historic preservation requirements have the potential to affect housing availability and choice to the extent that otherwise permitted residential construction or modifications may not be allowed if they adversely affect historic resources, or may be permitted only with significant changes affecting housing affordability. The City attempts to balance the need to expand housing choice with the importance of historic preservation by focusing on building design or modifications affecting the exterior and outward appearance of structures.

Parking Requirements

The number of parking spaces is determined by the number of dwelling units and the number of habitable rooms in each unit. The City requires at least two parking spaces for each single- family dwelling unit, except when the dwelling is located on a nonconforming lot 40 feet or less in width and for those created through small-lot subdivisions and in hillsides. Only one space is required on lots less than 40 feet in width and not abutting and alley. Parking for small-lot subdivisions need not be covered. Two covered on-site parking spaces are required for single- family hillside developments, plus one parking space for each 1,000 square feet above 2,500 square feet of floor area.

For other dwelling units, the City’s minimum parking requirements are:

. One parking space for each dwelling unit of less than three habitable rooms . 1½ parking spaces for each dwelling unit of three habitable rooms . Two parking spaces for each dwelling unit of more than three habitable rooms

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. One to 1¼ parking spaces per dwelling unit in the Central City area, depending on the number of dwelling units and habitable rooms on a lot

In single-family zones, the City requires that parking spaces be provided within private garages. In an R-2 Zone, at least one of the required parking spaces must be in a private garage. Parking spaces for housing in multi-family and nonresidential zones need not be enclosed.

For large residential care facilities, homeless shelters, convalescent hospitals, etc., one parking space per 500 square feet of building space or 0.2 spaces per patient bed, whichever is greater, is required. Eldercare facilities must provide either one space per unit or 0.2 spaces per guest bed, depending on facility type.

Although the Zoning Code does not contain guest parking requirements, guest parking is typically added as a standard condition to subdivisions (condominiums) at the rate of ½ space per dwelling unit in identified parking congestion areas and one-quarter space per unit in non- congested areas. In all other parts of the City, parking requirement is based on the number of habitable rooms.

The Zoning Code provides flexibility to facilitate the provision of housing for seniors and persons with disabilities. For example, a 50 percent reduction is available for Senior Independent Housing, Assisted Living Care Housing, or a housing development occupied by disabled persons. The City also offers a parking reduction of 25 percent of the Zoning Code requirement for service-enriched housing facilities occupied by disabled persons in the RD, R3, RAS3, R4, RAS4, R5, CR, C1, C1.5, C2, C4, or C5 Zones. And, parking for homeless shelters may be reduced by 25 percent, plus two spaces, if located more than 1,000 feet from a public transit stop, or by 25 percent with a minimum of two spaces for shelters located within 1,000 feet of a public transit stop.

The City’s parking requirements, along with the flexibility permitted in the Zoning Code to reduce parking or meet parking requirements through several options, do not create discriminatory outcomes based on the characteristics of a dwelling unit’s occupants . Parking standards are reasonable in light of urban parking needs and do not make the construction of housing or residential facilities for lower income or special needs groups infeasible.

Affordable Housing Initiatives

Affordable Housing Trust Fund The City established an Affordable Housing Trust Fund (AHTF) in June 2000. Recognizing that Los Angeles’ housing crisis poses significant challenges to the City’s economy, transportation infrastructure, education system, health care delivery, and basic quality of life, then Mayor Hahn pledged $100 million to the City’s Housing Trust Fund.

The AHTF is comprised of various funding sources, including but not limited to federal HOME funds, redevelopment set-aside funds, City general funds, and McKinney Act bond funds. One to three funding rounds are held each calendar year, with projects competing for Trust Funds that are used to leverage Low Income Housing Tax Credits (LIHTC) or funding from other State

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 95 Public Review Draft May 30, 2012 or Federal housing programs. However, with the dissolution of CRA/LA pursuant to State law, the AHTF faces the loss of its primary funding source.

Density Bonus Ordinance In 2008, the City adopted an ordinance to provide a density bonus and other incentives for projects that meet certain requirements established in State law as a means of increasing the production of affordable housing, consistent with City policies.

Density Increase: A project that includes 10 percent of the total units of the project for Low Income households or five percent of the total units of the project for Very Low Income households, either in rental units or for sale units, can receive a minimum Density Bonus of 20 percent. Condominium projects that set aside at least 10 percent of units for Moderate Income housing are eligible for a bonus of at least five percent. The bonuses may be increased according to the percentage of affordable housing units provided up to 35 percent. Senior housing can receive a 20 percent density bonus. The donation of land and provision of child care facilities can also make a project eligible for a density bonus. Additional density may be allowed for projects eligible under the density bonus that also meet specific performance criteria established in Section 14.00 of the Municipal Code.

Reduced Parking: Density bonus eligible projects can also apply reduced parking standards. Qualifying projects can select from one of two options:

. One space per zero or one bedroom unit, two spaces per two or three bedroom units, and 2.5 spaces per units with four or more bedrooms; or

. One space per restricted affordable unit, except 0.5 space per unit for Low or Very Low Income seniors or disabled persons and 0.25 space per restricted affordable unit in a residential hotel.

Incentives: In addition to the density bonus and parking options, qualifying projects can receive up to three additional incentives, depending on percentage set aside as affordable by income level. The menu of incentives available include, among others, yard/setback, lot coverage, lot width and open space requirement reductions; floor area ratio and height increases; inclusion of land area required for public dedication into the density calculation; and averaging of development standards across two contiguous but differently zoned parcels.

Affordable Housing Lottery Some affordable housing developers use a lottery system to select tenants for new affordable housing developments. During the 2012 AI consultation meetings, participants suggested that the City and owners of affordable housing developments conduct more outreach to underrepresented groups to advertise application periods for affordable housing lotteries. Some community groups are better at organizing their constituencies to participate in the lottery than others. For example some groups assist their constituencies in filling out applications and then bring the applications to the owner on behalf of the applicant.

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Greater Downtown Housing Incentive Area In 2007, the City adopted an ordinance to encourage private development to include affordable housing units. Developers may receive relief from zoning code provisions in return for including affordable units in the development.

The affordable housing incentives are available to developers who provide the following affordable housing units within the proposed development within the Greater Downtown Housing Incentive Area (“Downtown”):

1. Provide 5 percent of the units for very low income persons; AND 2. Provide 10 percent of the units for low income persons, or Provide 15 percent of the units for moderate income persons, or Provide 20 percent of the units for workforce housing; AND 3. Replace on a one-for-one basis within the Community Plan Area any demolished dwelling unit or guest room occupied by a very low income person.

Developers of affordable housing units, per the above list, may use any or all of the following incentives by right (i.e., a development application through DCP is not required and the developer applies to the Los Angeles Department of Building and Safety (LADBS) for building permits):

1. 35 percent increase in floor area ratio (FAR); 2. Halls, lobbies and unenclosed common areas are NOT included in the floor area calculation; 3. 50 percent reduction in the required internal building open space in exchange for providing an in-lieu fee equal to the Quimby Fee amount for all units in the development; 4. Reduction in required parking to 1 space per unit; and 5. Elimination of parking requirements for all units serving very low income persons.

For those proposed developments that seek greater incentives than those listed above in return for affordable housing units, the GDHIA ordinance established a conditional use permit process whereby such requests are considered individually through a development application to DCP.

Small Lot Subdivision (Townhome) Ordinance This ordinance permits fee-simple ownership opportunities in commercial and multi-family residential zones on parcels as small as 600 square feet. In addition to allowing homes on smaller lots, the Ordinance waives certain zoning requirements and relaxes other development standards and requirements for improvements and infrastructure otherwise required by the subdivision process, providing developers flexibility to allow more affordable home ownership.

Residential Accessory Services (RAS) Two Residential Accessory Services zones (RAS3 and RAS4) were created in 2003 to encourage mixed use development (housing and commercial) along underutilized commercial and transportation corridors. RAS zones provide increased floor area and height and reduced setbacks for 100 percent residential or mixed use projects constructed along commercial corridors. RAS3 permits 55 units per acre and RAS4 permits 109 units per acre.

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Adaptive Reuse Ordinance The City adopted the Adaptive Reuse Ordinance to facilitate the conversion of old, abandoned downtown office buildings into housing. It provides for an expedited approval process and ensures that older and historic buildings are not subjected to the same zoning and code requirements that apply to new construction. The result has been the creation of several thousand new housing units.

Live/Work The Citywide Live/Work Ordinance permits under certain conditions, joint living and work quarters in abandoned industrial buildings that can no longer support employment uses. This has encouraged the reuse of underutilized buildings for artists and others to live and work in a single space, where it is not possible to re-use buildings for modern jobs.

6. Impacts of Development Regulations and Practices on Housing for Persons with Disabilities

Several aspects of development regulations and practices may affect a person’s access to housing or limit the range of housing choices available. In 2009, the City of Los Angeles reviewed and assessed its development regulations and practices for impediments or constraints to the provision of housing for persons with disabilities as part of its Housing Element update. The analysis provided below is, in part, summarized from the City’s 2006-2013 Housing Element. The City’s existing development regulations and practices have not been found to constrain or impede the provision of housing for persons with disabilities.

Reasonable Accommodation

Both State and federal fair housing laws mandate provisions for reasonable accommodation for housing for persons with disabilities. The State Housing Element law also requires that local jurisdictions address constraints to housing for persons with disabilities, including the provision of reasonable accommodation. In 2006, the City of Los Angeles adopted an ordinance to establish a process for reasonable accommodation requests. The ordinance provides developers of housing for people with disabilities flexibility in the application of land use and zoning regulations or policies (including the modification or waiver of certain requirements) when it is necessary to eliminate barriers to housing opportunities that relate to their disability. Requests can include a modification or exception to zoning regulations, standards and practices for siting, or development and use of housing or housing related facilities that would eliminate regulatory barriers. The processes for requesting a reasonable accommodation are as follows:

(1) Applicant files a written request for reasonable accommodation from a land use or zoning regulation or policy.

(2) The Planning Director has 45 days to review the request and make a determination.

(3) If a request does not have sufficient information (e.g., the request does not specify which land use regulation or policy or provide a basis for relief), the 45-day time period for making a determination on the request stops running until the additional information is provided.

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(4) Prior to the issuance of any permits relative to an approved reasonable accommodation, the Planning Director may require the applicant to record a covenant in the County Recorder's Office if necessary to provide notice to future owners that a reasonable accommodation has been approved.

The City waives all fees to modify dwelling units for people with disabilities for reasonable accommodation and no public hearing is required. In summary, this process facilitates exceptions to zoning requirements and eases the issuance of building permits for residential structures serving individuals with disabilities.

Definition of Family

The City’s Zoning Code defines “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.” Currently, the City’s definition is not restrictive and does not have the potential to discriminate.

California court cases30 have ruled that an ordinance that defines a “family” as (a) an individual, (b) two or more persons related by blood, marriage or adoption, or (c) a group of not more than a certain number of unrelated persons as a single housekeeping unit, is invalid. These cases have explained that defining a family in a manner that distinguishes between blood-related and non-blood related individuals does not serve any legitimate or useful objective or purpose recognized under the zoning and land planning powers of the City, and therefore violates rights of privacy under the California Constitution.

Definition of Dwelling Unit

The definition of “dwelling unit” may exclude or restrict housing opportunities for individuals with disabilities by mischaracterizing residential congregate or group living arrangements as a commercial “boarding or rooming house” a “hotel” or a “residential care facility.” Both State and federal fair housing laws prohibit definitions of “dwelling unit” that either intentionally discriminate against people with disabilities or have the effect of excluding such individuals from housing. Generally, a dwelling covered by fair housing laws is understood to be a temporary or permanent dwelling place, abode or habitation to which one intends to return as distinguished from the place of temporary sojourn or transient visit.

The City’s Zoning Code defines “dwelling unit” as “a group of two or more rooms, one of which is a kitchen, designed for occupancy by one family for living and sleeping purposes.” Given the City’s current non-restrictive definition of “family”, the definition of “dwelling unit” does not intentionally discriminate or have the effect of excluding persons with disabilities from housing opportunities afforded by non-disabled persons.

30 City of Santa Barbara v. Adamson (1980) and City of Chula Vista v. Pagard (1981), among others.

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Definition of Disability or Similar Terms

Fair housing laws define “disability”, “handicap”, “physical or mental impairment”, and similar terms. Local definitions that are not at least as broad as the definitions found in applicable federal and State fair housing law may intentionally discriminate or have the effect of excluding or restricting housing opportunities for persons with disabilities. The City’s Zoning Code does not define these and similar terms. The City applies the definitions of these terms as contained in applicable State and federal law.

Group Living Facilities

Persons with special needs, such as the elderly and those with disabilities, must also have access to housing in a community. Group living facilities provide a supportive housing environment to persons with special needs in a group situation. Restrictions that may prevent this type of housing raise a fair housing concern.

Licensed residential facilities serving six or fewer persons, including persons with disabilities, are allowed by-right in all zones in accordance with State law. Licensed residential facilities for seven or more persons must pursue a variance, as the City does not currently offer any other mechanism or process for locating in any zone. Other group living arrangements, that are not licensed and do not offer care and supervision, operate as boarding houses and are permitted by right in R3 and more dense residential zones and in commercial zones.

According to the State of California Community Care Licensing Division of the State’s Department of Social Services, as of April 2012, there were 1,165 State-licensed community care residential facilities in the City of Los Angeles, totaling close to 25,000 beds (Table 37). Over 73 percent of these community residential beds are for elderly persons. Of all the City’s NSAs, the North and South Valley and Central Los Angeles have the highest concentrations of these group living facilities. The majority of these beds available in these three NSAs are for elderly persons – 79 percent of beds in North Valley; 92 percent of beds in South Valley; and 73 percent of beds in Central Los Angeles. East Los Angeles, South Los Angeles, and Harbor NSAs have higher proportions of community residential beds for adults (at 50 percent, 75 percent, and 54 percent of total beds, respectively).

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Table 37: Licensed Community Care Facilities (2012) Number of Beds by NSA LCF Type North South West LA Central East LA South LA Harbor Total Valley Valley Small Family 18 6 0 6 0 14 0 44 Homes Group Homes 428 188 52 195 187 124 16 1,190 Adult Residential 863 438 126 1,083 794 1,452 409 5,165 Facility Residential Care Facility for the 4,438 7,512 1,396 3,641 565 359 331 18,242 Elderly Community 0 0 24 0 0 0 0 24 Treatment Facility Residential Care Facility for the 6 6 0 21 50 0 0 83 Chronically Ill Social Rehabilitation 12 0 6 10 0 0 0 28 Facility Total LCF 5,765 8,150 1,604 4,956 1,596 1,949 756 24,776 Total LCF per 1,000 8.24 11.24 3.97 7.65 4.03 2.69 3.87 6.53 People Group Homes are facilities of any capacity and provide 24-hour non-medical care and supervision to children in a structured environment. Group Homes provide social, psychological, and behavioral programs for troubled youths. Small Family Homes (SFH) provide 24-hour-a-day care in the licensee's family residence for six or fewer children who are mentally disabled, developmentally disabled, or physically handicapped, and who require special care and supervision as a result of such disabilities. Small Family Homes (SFH) provide 24-hour-a-day care in the licensee's family residence for six or fewer children who are mentally disabled, developmentally disabled, or physically handicapped, and who require special care and supervision as a result of such disabilities. Adult Residential Facilities (ARF) are facilities of any capacity that provide 24-hour non-medical care for adults ages 18 through 59, who are unable to provide for their own daily needs. Adults may be physically handicapped, developmentally disabled, and/or mentally disabled. Residential Care Facilities for the Chronically Ill (RCFCI) are facilities with a maximum licensed capacity of 25. Care and supervision is provided to adults who have Acquired Immune Deficiency Syndrome (AIDS) or the Human Immunodeficiency Virus (HIV). Residential Care Facilities for the Elderly (RCFE) provide care, supervision and assistance with activities of daily living, such as bathing and grooming. They may also provide incidental medical services under special care plans. A Social Rehabilitation Facility is any facility that provides 24-hour-a-day non-medical care and supervision in a group setting to adults recovering from mental illnesses, who temporarily need assistance, guidance, or counseling. Source: State of California Department of Social Services, Community Care Licensing Division, 2012.

Location/Siting Requirements

The Los Angeles Building Code (LABC) incorporates provisions of the California Building Standards Code (CBSC). Local amendments to the CBSC tailor the LABC to local conditions but do not diminish the ability to accommodate persons with disabilities. The Zoning Code does not impose distance requirements on residential land uses for persons with disabilities.

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Accessibility Requirements for Multi-Family Housing

Both privately owned and publicly assisted housing, regardless of whether they are rental or for sale units, must meet the accessibility requirements of the Fair Housing Act when they are located in a building of four or more units, built after March 13, 1991.

The Fair Housing Act requires seven basic requirements that must be met to comply with the access requirements of the Act. Those Requirements are:

. An accessible building entrance on an accessible route; . Accessible common and public use areas; . Usable doors (usable by a person in a wheelchair); . Accessible route into and through the dwelling unit; . Light switches, electrical outlets, thermostats and other environmental controls in accessible locations. . Reinforced walls in bathrooms for later installation of grab bars; and . Usable kitchens and bathrooms.

All Federally assisted new construction housing developments with five or more units must design and construct five percent of the dwelling units, or at least one unit, whichever is greater, to be accessible for persons with mobility disabilities. These units must be constructed in accordance with the Uniform Federal Accessibility Standards (UFAS) or a standard that is equivalent or stricter. An additional two percent of the dwelling units, or at least one unit, whichever is greater, must be accessible for persons with hearing or visual disabilities.

Federal fair housing law provides that states may enact and enforce laws and regulations for accessibility that are at least as restrictive as the federal requirements. This is the case in California, laws establishing accessibility and discriminatory prohibitions are equivalent and in many areas more restrictive than the federal requirements.

New construction of the following types of multi-family dwellings in California is subject to accessibility regulations when not owned by public agencies:

. Apartment buildings with three or more dwelling units; . Condominiums with four or more dwelling units; . Lodging houses, congregate residences, and dormitories; . Dwellings with three or more SRO or efficiency units; and . Homeless shelters.

Furthermore, California law requires that 10 percent of multi-story dwelling units in apartment buildings with three or more dwelling units or condominiums with four or more dwelling units, in buildings without an elevator, be accessible. The State’s multi-family accessibility requirements are codified in the 2010 edition of the California Building Standards Code. The City adopted and enforces this code.

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In January 2012, three Los Angeles-based advocacy groups for the disabled filed a lawsuit against the City and the former Community Redevelopment Agency of the City of Los Angeles, alleging ADA violations. The suit claims that the City and CRA failed to ensure that apartment complexes built with federal and community development funds were accessible to people with disabilities. The City is currently reviewing the complaint.

ADA Compliance

The City’s Department of Building and Safety has a special Commission (the Board of Disabled Access Appeals Commissioners) dedicated to resolving ADA accessibility issues related to implementation of the Building Code issues. The Commission handles appeals alleging error or abuse of discretion regarding handicapped access and adaptability requirements. ADA compliance is monitored to ensure reasonable accommodation to people who use City programs and facilities, including City-funded housing facilities and emergency shelters. At the time of this report (April 2012), the City’ ADA Compliance Officer position within the Department on Disability was vacant. The ADA Compliance Officer position is charged with the responsibility to address conflicts and complaints regarding accessibility for individuals with disabilities.

7. Transit Oriented Development

Transit-Oriented Development (TOD) refers to the emerging trend of building compact, mixed- use projects adjacent, or very near, to public transit facilities and stations. In recent years, TODs have become the go-to strategy for combating urban sprawl and promoting sustainable communities. Despite the obvious benefits of TODs, a number of concerns have recently surfaced about the potential drawbacks and hidden costs of this type of development.

A recurring issue brought up by housing advocates at outreach meetings was the gentrifying effect TODs were having on traditionally minority and lower income neighborhoods. Many have reported seeing an increase in the number of attempted illegal evictions, especially of low income Black tenants, in the Downtown area in order to make room for tenants willing and able to pay higher rents for their units.

The City of Los Angeles is home to over 60 Metro Rail and fixed transitway stations, with 13 more currently under construction and 11 more being planned, for a future total of 84 stations. The Department of City Planning, in partnership with other City departments, is preparing Transit-Oriented District (TOD) Plans in strategic locations in the City. The new TODs will bring about livable, sustainable neighborhoods with a mix of housing types and improved access to schools, jobs, and local and regional destinations. These Plans call for quality urban design and scale that create a comfortable and safe walking and bicycling environment for residents and visitors of all ages.

The correlation between TODs and gentrification throughout the country has been examined in a number of reports, including one study conducted by the Dukakis Center for Urban and Regional Policy at Northeastern University titled Maintaining Diversity in America’s Transit-Rich Neighborhoods: Tools for Equitable Neighborhood Change. After an analysis of 42 transit stations throughout the country, this study was able to make the following observations about Transit- Rich Neighborhoods (TRNs):

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. The population within a TRN grew more quickly than the population in the surrounding metropolitan area as a whole.

. Housing production also increased more dramatically in the TRN than in the surrounding metropolitan area as a whole.

. The link between transit and an increase in the White population is less clear. About one-half of the TRNs examined in the study experienced an increase in the proportion of non-Hispanic White households, relative to the change in the TRN’s metro area. The other half, however, saw their non-Hispanic white population either decline or increase more slowly than the rate of increase in the surrounding metro area.

. There is a stronger correlation between transit and an increase in household income. Median household income increased more than in the surrounding metro area in three- fifths of the TRNs examined. Furthermore, the increase in the number of households earning over $100,000 a year was especially significant.

. The cost of housing in TRNs increased dramatically. Median gross rent increased faster than in the surrounding metro area in nearly three-quarters of the TRNs examined. The impact on home prices was even more dramatic, with nearly nine out of ten (88 percent) TRNs experiencing an increase in median housing values greater than the surrounding metro area.

. The effects of gentrification were more exaggerated with the addition of light rail, as opposed to heavy rail or commuter rail.

Within the City of Los Angeles, noticeable changes in the racial/ethnic profile of the City’s population coincided with the opening of a number of transit lines. The Los Angeles County Metropolitan Transportation Authority (Metro) operates a number of transit lines that serve the City, including the Red Line, Orange Line, Gold Line, Blue Line and Green Line. These lines, with the exception of the Orange Line, are collectively known as the Metro Rail Rapid Transport System. Figure 13 illustrates the location of the City’s transit stations. Most of these stations are located in Central Los Angeles, South Los Angeles, East Los Angeles, and the North Valley. A one-half mile buffer around each transit station is also identified in the figure. The demographic profile of the population within this buffer is compared to the population outside of the buffer and to the City as a whole (Table 38).

In 1990, prior to the opening of the Metro Rail Rapid Transport System, Non-Hispanic Whites made up approximately 23 percent of the population within one-half mile of the City’s various transit stations. The Metro Blue Line, the primary line that serves South Los Angeles, began operations in 1990. The Metro Red Line, which runs primarily through Downtown Los Angeles and Hollywood and into San Fernando Valley, opened in stages between 1993 and 2000. The Metro Purple Line, which shares the Red Line track for much of its route but diverges and ends in the Mid-City neighborhood, was completed in 1996. Metro’s Green Line, which provides service to LAX, opened officially in 1995. And, the Metro Gold Line, which serves East Los Angeles, did not enter into service until 2003. Metro’s Orange Line, while not a part of the Rail

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Rapid Transport System, is a rapid bus line that serves the North San Fernando Valley. The Orange Line did not begin operations until 2005.

Based on Census data, there is a slight trend of non-Hispanic White population moving back to areas surrounding transit stations, reversing the “White flight” from the urban cores during the 1980s and 1990s.

During the past, the term “White flight” was used to describe the departure of the White population from downtown and urban cores and migration into the suburban areas. When the 1990 Census was taken, that trend of White flight was in full action. By 2000, White population near the TOD areas decreased to 18 percent. By 2010, after all of Metro’s transit lines had opened and been in service for several years, a small reversing trend can be detected. While non-Hispanic White population outside the TOD areas and in the City as a whole declined, its proportion within the TOD areas increased slightly to 19 percent. Figure 13 illustrates the location of transit stations in relations to concentrations of minority population in 2010. The 2010 Census data does not include income information and the American Community Survey data is not available for small geographic areas such as census tract level. Therefore, an analysis of gentrification based on household income cannot be performed at this time. However, common sense dictates that new residential units created in TOD areas are likely to mirror national market trends, suggesting that these units are not affordable to lower and moderate income households.

Table 38: TOD and Population 1990 2000 2010 Distance from Distance from Distance from Transit Stations City of Transit Stations City of Transit Stations City of Within Outside LA Within Outside LA Within Outside LA 0.5 Mi 0.5 Mi 0.5 Mi 0.5 Mi 0.5 Mi 0.5 Mi Non-Hispanic 119,367 1,180,237 1,299,604 97,455 1,001,277 1,098,732 106,248 980,655 1,086,903 White Total 530,814 2,954,584 3,485,398 546,621 3,147,286 3,693,907 559,799 3,232,781 3,792,580 % Non- 22.5% 39.9% 37.3% 17.8% 31.8% 29.7% 19.0% 30.3% 28.7% Hispanic White

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Figure 13: Transit Stations and Minority Population (2010)

City of Los Angeles Page 106 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 B. Rent Stabilization

The Los Angeles City Rent Stabilization Ordinance (RSO), adopted in 1979 as Chapter XV of the Los Angeles Municipal Code, is intended to safeguard tenants from excessive and unjustified rent increases and unfair evictions. The City Council designed the law to protect tenants from excessive rent increases while allowing the landlords a reasonable return on their investment. The RSO does not address fair housing issues. LAHD refers complaints about fair housing issues to a fair housing agency.

The RSO is seen by some as a constraint to development as it discourages investors that would not experience a high rate of return in residential investment. The Ordinance regulates rent increases by limiting the frequency, amount, and reason for rent increases. The annual allowable rent increase is based on the Consumer Price Index (CPI) average for the Los Angeles - Long Beach - Anaheim areas for a twelve-month period ending September 30 of each year. Under the RSO, the percentage can be no lower than three percent and no higher than eight percent.

The ordinance controls most rental units receiving a certificate of occupancy before October 1, 1978, except single-family homes (one unit on a lot) and various other units as specified in the RSO.

1. Removal of Units from the Rental Housing Stock (Ellis)

RSO regulated units and properties stopped being added by the end of 1978 because newer housing structures are exempt. However, properties with two units were added to the RSO inventory in 1995; prior to then the RSO applied only to properties with three or more units. Current State law (the Ellis Act) allows rental property owners to permanently remove rental units from the housing market. As a result, the City of Los Angeles cannot require an owner to continue to offer a residential property for rent.

2. Just Cause Eviction

The City of Los Angeles Rent Stabilization Ordinance (RSO) includes just cause eviction provisions, and has established procedures which a property owner must follow to lawfully evict a tenant. The City’s regulations are in addition to California Civil Code regulations establishing landlord and tenant rights and responsibilities. The just cause eviction regulations cover RSO units and non-RSO foreclosed properties.

Under the City’s RSO, there are 14 permissible grounds for eviction, summarized below (L.A. Municipal Code Section 151.09):

1. Failure to pay the rent to which the landlord is entitled.

2. Violation of a lawful obligation or covenant of the tenancy and failure to cure the violation after having received written notice from the landlord, other than a violation based on:

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a. Failure to surrender possession upon proper notice; b. Exceeding a limitation on occupancy if the additional occupant is a first or second dependent child; or c. Change in the terms of the tenancy that is not the result of an express written agreement signed by both of the parties, except as permitted by Los Angeles Municipal Code Section 151.06 or as required pursuant to federal, state, or local law.

3. Commission or allowance of a nuisance that causes damage to the rental property or creates an unreasonable interference with the comfort, safety, or enjoyment of any of the other residents of the rental complex or within a 1,000 foot radius extending from the boundary line of the rental complex. 4. Use of, or permitting the use of, a rental unit, the common areas of the rental complex containing the rental unit, or an area within a 1,000 foot radius from the boundary line of the rental complex for any illegal purpose.

5. Refusal to execute a written extension or renewal of an expired rental or lease agreement, after the property owner has submitted a written request or demand, that has a similar duration and provisions to the expired agreement and is not in violation of the City’s RSO.

6. Refusing a landlord’s request for reasonable access to a rental unit for the purpose of making repairs or improvements, or for the purpose of inspection as permitted or required by the lease or by law, or for the purpose of showing the rental unit to any prospective purchaser or mortgagee.

7. Possession of a unit at the end of lease term by a subtenant who is not approved by the landlord.

8. The property owner’s recovery of a unit for use and occupancy as a primary place of residence by the landlord; the landlord’s spouse, grandchildren, children, parents or grandparents; or a resident manager.

9. Unreasonably interferes with the landlord’s ability to renovate the building or buildings housing the rental unit or units by failing to either relocate as required by the accepted Tenant Habitability Plan or honor a permanent relocation agreement with the landlord.

10. The owner’s good faith to recover possession so as to demolish the rental unit or to remove the rental unit permanently from rental housing use.

11. The owner’s good faith to recover possession of the rental unit to comply with a governmental agency’s order that necessitates the vacating of the building housing the rental unit as a result of a violation of the Los Angeles Municipal Code or any other provision of law.

12. Cases in which the Secretary of Housing and Urban Development is both the owner and plaintiff and seeks to recover possession in order to vacate the property prior to sale and

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has complied with all tenant notification requirements under federal law and administrative regulations.

13. The rental unit is in a Residential Hotel, and the landlord seeks to recover possession so as to convert or demolish the unit.

14. The landlord seeks to recover possession so as to convert the property to an affordable housing development.

3. Relocation Assistance

Under the City’s RSO, a property owner is required to pay relocation assistance to a tenant when evicting that tenant for one of the following reasons:

. The eviction is due to condominium conversion or for a change of use of the property to commercial use; . A resident owner or a family member intends to occupy the rental unit; . A resident manager will occupy the rental unit; . The rental unit will undergo major renovation (in some cases); . The rental unit will be permanently removed from the rental housing stock or will be demolished; . The rental unit must be vacated to comply with a governmental order (except an order related to hazardous conditions created by a natural disaster); or . The rental unit is part of a property to be reconveyed to HUD. . The rental unit is in a Residential Hotel and will be converted or demolished.

Any eviction requiring relocation assistance also requires the filing of a “Landlord Declaration of Intent to Evict” from with the Los Angeles Housing Department (LAHD).

The relocation assistance amount depends on the type of tenant who is being evicted. “Qualified” tenants are tenants who are 62 years of age or older, handicapped or disabled, or have one or more minor dependent children as of the date of service of notice to terminate. Qualified tenants with less than three years of occupancy are eligible to receive $15,500 (per unit). Qualified tenants with three or more years of occupancy are entitled to $18,300 (per unit). Qualified tenants whose income is 80 percent or less of the Area Median Income are entitled to $18,300 (per unit).

“Eligible” tenants are any tenants who are not “qualified” tenants. Effective through June 30, 2012, eligible tenants in a rental unit on the date of service of the written notice of termination with less than three years of occupancy are entitled to receive least $7,300 (per unit) in relocation assistance; eligible tenants with three or more years of occupancy are entitled to $9,650 (per unit). Eligible tenants whose income is 80 percent or less of the Area Median Income are entitled to $9,650 (per unit).

Once every three years, the owner of a qualifying “Mom and Pop” property can pay a reduced relocation fee for a good faith eviction for occupancy by the owner, family member or a resident manager, provided that certain requirements are met. This reduced fee applies, if the property

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 109 Public Review Draft May 30, 2012 containing the rental unit contains four or less units, the landlord owns no more than one other single-family home on a separate lot in Los Angeles, and the eligible relative moving into the rental unit does not own residential property in the City.

Effective July 1, 2011, eligible tenants in a “Mom and Pop” rental unit on the date of service of the written notice of termination are entitled to receive $7,050 (per unit) in relocation assistance. Qualified tenants are entitled to receive $14,150 (per unit) in relocation assistance.

4. Complaint Resolution

LAHD administers the enforcement of the RSO. This function is funded entirely by the annual rental unit registration fees. Effective January 1, 2012, the annual fee per unit is $24.51, which is paid by the property owner. Of this fee, $12.25 may be passed through to the tenant during the month of June each year.

The City fees that relate to the administration of relocation assistance are as follows:

. Relocation Service Administrative Fe ($57): This fee is paid by all property owners filing a Landlord Declaration for owner, family member, or resident manager.

. Relocation Service Fee for Eligible Tenants ($416)/Relocation Service Fee for Qualified Tenants ($666): This fee is paid by all property owners who file a relocation application with the City. The City uses the fee to provide relocation assistance by the City’s Relocation Assistance Service Provider to each affected tenant in connection with the conversion of a building into a condominium, community apartment or stock cooperative, or, in connection with the demolition of a building or its relocation to another site.

. Demolition Monitoring Administrative Fee ($45): This fee is paid by all property owners that seek the Housing Department’s clearance of a Planning or Building and Safety Department demolition permit.

. Income Dispute Resolution Fee ($193): This fee is paid by property owners who dispute the relocation amount based on a tenant’s self-certified income level.

. Filing Fee for Landlord Declaration for Owner, Family Member, or Resident Manager ($75): This fee is paid by property owners when the termination of tenancy is for an eviction for an Owner, Family Member or Resident Manager.

LAHD provides a process for RSO complaint investigation and resolution. RSO complaints may be filed for one or more of six reasons:

. Non-registration of a rental unit; . Notice to evict based on false and deceptive grounds; . Non-receipt of relocation assistance when due; . Illegal rent increases;

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. Illegal reduction of housing services; and . Failure to post RSO Notice.

Tenants can file a complaint by calling LAHD’s public information hotline, filling out a complaint form at LAHD’s public counter, or filing a complaint online at http://cris.lacity.org/rentweb/rentcomplaintintake.aspx. A Rent Stabilization Officer will investigate and attempt to resolve valid complaints through negotiations between the tenant and the property owner. If the complaint cannot be resolved in this manner, the complaint can be referred to the City Attorney for consideration of criminal prosecution. LAHD maintains records on complaints received from RSO tenants.

Table 39: RSO Complaints Fiscal Year May - June FY 11/12 FY 09/10 FY 10/11 2009 (thru 2/29/2012) Actual Number of Complaint Cases Received 929 5,076 4,852 3,459 Summary of Types of Complaints

Evictions 456 2,421 2,318 1,690 Relocation assistance 41 300 224 257 Illegal rent increase 403 1,679 1,567 1,097 Reduction of services 253 1,211 1,192 840 Non-registration 52 476 464 423 Failure to Post RSO Notice ------228 City Attorney Referrals 36 92 40 34

It is important to note that one complaint case can be filed on multiple types of violations. For example one tenant can file a case that encompasses an illegal rent increase complaint and a reduction of services complaint. LAHD revised its complaint tracking system in May 2009 to track numbers of individual cases as well as complaint types.

During a one-year period from July 1, 2010 to June 30, 2011, the LAHD received 4,852 complaints. The majority of the complaints were related to eviction and illegal rent increases. Of the all the complaints filed, approximately 42 percent were reconciled by investigation and enforcement. Only one percent were referred to the City Attorney for potential prosecution of violations of the RSO. Approximately 29 percent of the complaints were withdrawn or closed due to complainants not following through with the process.

LAHD investigates all RSO complaint cases filed with the agency. Priority is given to evictions, foreclosure-related cases, and illegal rent increases complaints.

The three most common RSO violations participants identified during the 2012 AI consultation meetings support RSO complaint data:

. Illegal Rent Increases: Property owners raising the rent above the allowable increase. . Relocation Assistance: Property owners failing to pay relocation fees or paying inadequate relocation fees.

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. Reduction of Services: One example provided included a property owner using the low rent his tenant paid to justify to the tenant his failure to make repairs on rental units. In another example, some property owners have driven out tenants by refusing to make repairs to the unit. Tenants then voluntarily vacate the unit rather than live in substandard conditions and therefore forego relocation assistance rights.

LAHD RSO Outreach Efforts

LAHD continues to expand its efforts to educate both renters and property owners about the RSO. The City’s RSO Publication and Form’s web page contains several resources including:

. Landlord-Tenant Handbook . Bulletins on Rent Stabilization Topics (e.g, Allowable Rent Increases, Relocation Assistance Information, Legal Reasons for Evictions, and other topics.) . The RSO Ordinance . Ellis Forms . Landlord Declarations of Intent to Evict Forms . Information about Cost Recovery and Rent Adjustment Programs . Mobilehome Parks Bulletin

The web page is available at http://lahd.lacity.org/lahdinternet/RSOPublicationsandForms/ tabid/264/language/en-US/Default.aspx.

The Department’s Public Information Hotline and six Public Counters provide information as well as intake services for RSO and Code complaints. The Hotline responded to over 122,000 telephone inquires in Calendar Year 2011. The Public Counters assisted over 64,000 customers in Calendar Year 2011. Also, over 3,300 responses to public information requests were mailed. Whenever possible, LAHD provides staff and informational materials for community events and fairs.

Since January 2011 LAHD has conducted free, monthly landlord tenant information workshops located in downtown LA, Valley, South Los Angeles. In 2012, LAHD expanded the monthly workshops to include a fourth location in West Los Angeles location and also workshops conducted in Spanish. The workshops were promoted by Channel 35, the Apartment Association of Greater Los Angeles, California Apartment Association, City Council Offices, and the LAHD web page. As a convenience to those unable to attend the workshops and as an additional reference resource, PowerPoint presentations are available on the LAHD web page at http://lahd.lacity.org/lahdinternet/RentStabilization/LandlordTenantInformationalWorkshop s/tabid/481/language/en-US/Default.aspx.

Monthly "hands on" assistance is also available, upon request, for help with the RSO and completing applications for various LAHD programs. An e-newsletter is also planned for 2012.

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Cities and counties in California are required to adopt the California Building Standards Code (Title 24 of the California Code of Regulations). The Code is actually a set of uniform health and safety codes covering building, electrical, mechanical, and plumbing, fire safety, and other issues. Uniform codes are generally considered the minimum acceptable standards for health and safety.

The Code is updated periodically by the California Building Standards Commission with additions and modifications specific to California. The periodic revisions are based on updates to the individual uniform codes that are adopted by their professional associations (such as the International Code Council).

State law allows cities and counties to add local, more restrictive, amendments to the California Building Standards Code, provided such amendments are reasonably necessary due to local climatic, geological, or topographic conditions. The City of Los Angeles has adopted several amendments that are more restrictive than the State building code. The local code amendments are intended to improve safety for building occupants and would not likely result in significant cost increases for the production of housing or create discriminatory results in the availability of housing.

D. Systematic Code Enforcement

The City established the Systematic Code Enforcement Program (SCEP) in 1998 to ensure that all rental properties with two or more units on a single parcel are safe and habitable. The program was established in response to increased complaints regarding habitability and irresponsible slumlords targeting minority and low income residents.

The SCEP is administered by LAHD, which inspects residential rental properties subject to the program periodically. While the City has a goal of inspecting the rental properties every two years, staffing and budgetary constraints have extended the inspection cycle to three to five years. Inspectors from LAHD schedule every property for a thorough inspection, and any properties that do not meet the requirements of City and State codes are cited. For most violations, property owners must abate all substandard property conditions within 30 days. The City then re-inspects the rental unit to ensure that the corrective work has been done. If repairs are not completed within the specified time period, the owner will be summoned to a hearing to explain the reason(s) for non-compliance. Additional time may be granted for completion of repairs. If further enforcement steps become necessary, the file may be forwarded to the Office of the City Attorney as a criminal complaint.

Tenants may also file habitability complaints directly with the LAHD, and inspectors will normally contact complainants within 72 hours.

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The California Environmental Quality Act (CEQA) is California's broadest environmental law. CEQA applies to all discretionary projects proposed to be conducted or approved by a public agency, including private projects that require government approval. The primary purpose of CEQA is to disclose to the public the significant environmental effects of a proposed project. CEQA also requires that public agencies disclose the decision making process utilized to approve projects and is intended to enhance public participation in the environmental review process.

In October 2011, the Governor signed into law SB 226, which allows for streamlined CEQA review for certain infill development projects, including some Transit Oriented Developments (TODs). The statute allows an exemption or limited environmental review of projects that meet certain criteria and are consistent with earlier policy documents such as General Plans, Specific Plans, or Master Plans. Subsequent environmental review of qualifying projects is limited to new or substantially greater impacts not adequately addressed in an earlier CEQA document.

The streamlined environmental process allowed by SB 226 makes it possible for the environmental impacts of a paper document like a General Plan, Specific Plan, or Master Plan area to be analyzed long before a physical development project is proposed. Because SB 226 does not include a time limit, CEQA’s environmental review and public comment requirements could be satisfied by a document prepared years prior to the proposal of a specific infill or TOD development proposal.

In late 2011, the Governor also signed into effect two bills – AB 900 and SB 292 – that would allow for an expedited review of lawsuits brought under CEQA against large infrastructure or development projects. The recently signed bills are applicable to projects valued at $100 million or more. While these bills were intended to promote sustainability and stimulate the creation of jobs, especially with the proposed development of an NFL Stadium near downtown’s LA Live, numerous concerns have been brought up regarding the effect a streamlined CEQA process will have on the public’s ability to comment on and contest a proposed development.

During public meetings, held specifically for the development of this AI, a number of attendees expressed concern that an expedited CEQA process would mean less opportunities for the public to comment on the potential impacts of a proposed project. Many have argued that the streamlined process would violate the spirit of CEQA, whose original intention was to give those most likely to be affected by a project the opportunity to learn more about the environmental impacts of that project and compel developers to consider less potentially disruptive alternatives.

City of Los Angeles Page 114 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 F. Housing Authority of the City of Los Angeles (HACLA)

The availability and location of public and assisted housing is a fair housing concern. If such housing is concentrated in one area of a community, a household seeking affordable housing is limited to choices within the area. Public/assisted housing and housing assistance must be accessible to qualified households regardless of race/ethnicity, disability, or other special characteristics. This section addresses only key housing programs administered by HACLA.

HACLA is a federally funded agency that administers housing assistance programs in the City for qualified low income families (i.e., those earning less than 50 percent of the Median Family Income [MFI]), the disabled, and seniors. The key programs discussed in this section include the tenant-based Housing Choice Voucher program and public housing.

1. Housing Choice Vouchers

Housing Choice Vouchers (formerly Section 8)

The Housing Choice Voucher program is a rent subsidy program that helps low income families and seniors pay rent to private landlords. Voucher recipients pay a minimum of 30 percent of their income for rent and HACLA pays the difference up to the payment standard established by HACLA. The program offers low income households the opportunity to obtain affordable, privately owned rental housing and to increase their housing choices. HACLA establishes payment standards based on HUD-established Fair Market Rents. The owner’s asking price must be supported by comparable rents in the area. Any amount in the excess of the payment standard is paid by the program participant.

As of January 2012, 49,314 households received vouchers from HACLA. The racial composition of the recipients was: 53 percent Black; 43 percent White; and three percent Asian. Recipients of Hispanic origin (of all races) represent approximately 21 percent of voucher households. Relative to their proportion of the City population, Hispanic residents are under-represented and Black residents are over-represented in the Housing Choice Voucher program. Half of all vouchers are used by households with an elderly or disabled member. Of the individuals in voucher-recipient households, 31 percent were children but the average household size of these households was smaller than among all City households. As shown in Figure 14, high concentrations of Housing Choice Vouchers are found in Central and South Los Angeles areas.31

31 Does not include vouchers administered by HACLA that are in use outside the incorporated City.

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Table 40: Voucher Recipient Demographics Characteristic Number/Proportion Total 49,314 Individuals on Program 105,180 Adults on Program 72,062 69% Children on Program 33,118 31% Average Household Size 2.13 By Family Type Family 44% Female-headed 71% Male-headed 29% Elderly 3% Disabled 27% Elderly and Disabled 26% By Race Black 53% White 43% Asian/Pacific Islander 3% American Indian <1% Other 0% By Ethnicity Non-Hispanic 80% Hispanic 20% By Household Size Single Person 23,578 48% Two-Person 11,020 22% Three-Person 6,461 13% Four-Person 3,939 8% Five-Person 2,579 5% Six-Person 1,010 2% Seven-Person 476 1% Eight-Person 162 <1% Nine-Person 65 <1% Ten-Person 11 <1% Eleven-Person 11 <1% Twelve-Person 2 0% Source: Housing Authority of the City of Los Angeles, 2012.

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Figure 14: Distribution of Housing Choice Voucher Recipients and Public Housing Units

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Special Section 8 Programs

HACLA offers a variety of Section 8 special programs to eligible households. Through Section 8 special initiative grants, HACLA offers services to special needs groups including the chronically homeless, the mentally ill, those with dual diagnosis including chronic substance abuse, and persons living with HIV/AIDS and their families. The purpose of these programs is to decrease and eventually end homelessness. In addition to housing assistance, through matching funds programs, HACLA coordinates supportive intervention to further promote the clients’ stability, improve quality of life issues, and move progressively towards self-sufficiency through other programs, such as Homeownership. The Family Self-Sufficiency (FSS) program is designed to help households get off welfare and other public assistance and gain economic self-sufficiency. The FSS Program offers families a financial incentive to participate in the form of an escrow account that becomes available to them upon program completion. Additionally, in 2008 HACLA, in cooperation with the Veteran Affairs Medical Centers (VAMC), was awarded vouchers under the HUD-VASH Program, expanding by 2011 to include 1,345 vouchers for homeless veterans and their families.

Challenges

Long waiting periods for assistance are common since the demand often exceeds the limited resources available. As of March 2012, HACLA’s waiting list included 7,836 families. The amount of time spent on the Housing Choice Voucher program waiting list often varies and can be as long as eight years. However, data on race/ethnicity and other household characteristics were not collected at the last registration period, therefore the data collected by HACLA represents only a small sample of the applicants and are not representative of the applicant pool.

Due to the funding shortfall in the Housing Choice Voucher program and the worsening economy and its impact on tenant rents, HUD has been proactive in working with housing authorities that are currently affected. It has already provided housing agencies $100 million set-aside funds authorized in the 2009 Appropriations Act. HACLA received $22.1 million in set-aside funds in 2009 and $10.6 million in 2010.

In 2009, the HACLA took steps to control costs. Specifically, the agency ceased voucher issuance, used Net Restricted Assets, billed incoming portability, and increased fraud termination efforts. However, according to HACLA’s projections, even with these measures, rental subsidy payments for assisted families were projected to exhaust reserves by July of 2010, so additional measures were taken. In February 2010, the HACLA revised the Occupancy Standard – bringing voucher bedroom sizes offered to assisted families down to parity with surrounded Los Angeles regional public housing agencies, and decreased the Voucher Payment Standard, which reduced the maximum rent offered per unit size. These measures have reduced overall subsidy payments, and HACLA projects that the 2012 budget will cover all families on the program.

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Impact of Denial among Members of Protected Classes

Given a limited supply of Housing Choice Vouchers and a long waiting list, denial of assistance creates a potential for disparate impact among members of protected classes. Eligibility, selection and admissions policies including de-concentration and waiting list procedures are included for the Housing Choice Voucher program in the Section 8 Administrative Plan and for the public housing program in the Admissions & Continued Occupancy Policy (ACOP). The ACOP can be found at the Public Housing Development Management Offices and Public Housing Application Center as well as the HACLA website. The Section 8 Administrative Plan is available on the HACLA website. All of the HACLA’s policies and procedures adhere to applicable federal, state, and local laws. Each eligible applicant is assigned a place on the waiting list based on the time and date of the receipt of the completed application. HACLA provides voucher assistance to eligible applicants on the waiting list based on the time and date of the receipt of the completed application and without regard to race, ancestry, sex, national origin, color, religion, sexual orientation, marital status, familial status, age, disability (including HIV/AIDS), student status, or any other arbitrary factor.

Two-thirds of current voucher holders have been in the program for more than five years. Voucher holders generally represent the demographic profile of the lower income households at least a decade ago. However, with diminishing funding in recent years, the rate of new voucher recipients entering the program has not kept in pace with the changes in the City’s demographic profile. Therefore, when the demographic characteristics of residents on the waiting list are compared with current Housing Choice Voucher recipients, some disparity is inevitable.

2. Public Housing

HACLA owns and/or manages 6,921 units and 22,055 residents. As of March 2012, approximately 48 percent of households occupying a HACLA unit were single females with children, 20 percent were elderly, and 23 percent were large families (five or more members). Persons with disabilities accounted for 11 percent of all residents and 66 percent of single- person households. The racial/ethnic composition of residents was: 78 percent Hispanic or Latino; 18 percent African American; two percent Asian or Pacific Islander; one percent Caucasian; and one percent multiple or other races. The majority of the public and assisted housing owned and operated by the HACLA is located in Boyle Heights and Watts (Figure 14).

Demolition of Assisted Housing

HACLA has transformed three large public housing sites (Pico Gardens, Aliso Apartments, and Aliso Village) into vibrant, mixed economic communities through redevelopment. Pico Gardens/Aliso Apartments has become Pico Gardens/Las Casitas and Aliso Village is now Pueblo del Sol. Additionally, a fourth Public Housing development, Dana Strand, has been redeveloped into a mixed economic community with two phases with public housing, Harbor View Garden Apartments and Wilmington Townhomes, completed so far as well as a third phase 100-unit affordable senior building.

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HACLA is currently in the planning stages for redevelopment of Jordan Downs. The intention is to replace all 700 existing public housing units and add on additional 900 to 1,100 units of affordable and market-rate housing, including workforce housing units, market rate rental units, and market rate homeownership units. In addition to the mixed-income housing, there will be mixed-use opportunities with retail services, high-tech light industrial, educational and recreational facilities, as well as enhanced community programs.

HACLA has taken extensive steps to minimize the impact of the redevelopment program on existing residents, including members of protected classes. Utilizing Replacement Housing Factor funds, HACLA purchased scattered site residential properties that can be used for temporary relocation of residents as part of the Jordan Downs redevelopment. The properties, located in close proximity to Jordan Downs, may also provide future homeownership opportunities for qualified public housing residents. The redevelopment program is also accompanied by a comprehensive Human Capital Plan to provide family support, job training and community programs to empower families towards self-sufficiency. Because each public housing unit is being replaced with a new public housing unit and redevelopment of Jordan Downs will introduce new, service-enriched, affordable and market rate housing into the area, the net impact or effect of the proposed demolition will be positive for existing and future residents of the site as well as for the community at large.

Challenges

The need for subsidized housing far exceeds the resources currently available. Inconsistent and insufficient federal funding continues to be a major challenge for public housing. Funding for operations was cut by 25 percent in 2011 and at least another seven percent cut is expected in 2012. The capital fund is expected to be cut by more than eight percent in 2012.

Impact of Denial among Members of Protected Classes

The extensive waiting list and limited supply of public housing units creates the potential for disparate impact of denial among members of protected classes. Although waitlisted residents are not denied assistance, they do not currently have access to assistance. When the demographic characteristics of waitlisted residents are compared with current residents of public housing, some disparity is apparent. Families with children (especially single-females with children) are overrepresented among public housing residents compared to those on the waiting list (48 percent versus 36 percent). Persons with disabilities are underrepresented when compared to current residents (11 percent versus 17 percent). The proportion of elderly residents in public housing is approximately the same as the proportion on the waiting list.

The racial/ethnic composition of current residents also differs from that of waitlisted residents. Hispanics/Latinos comprise 78 percent of public housing residents compared to 44 percent on the waitlist. African Americans comprise more than twice the proportion of waitlisted residents than public housing residents (41 percent versus 18 percent). Part of the disparity is due to the difference in family sizes and the units that are available for occupancy. Whites and Asian/Pacific Islanders and are also underrepresented in public housing when compared to the waiting list (one and two percent vs. seven and eight percent, respectively).

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HACLA’s application process is designed to ensure that all persons regardless of race, ancestry, sex, national origin, color, religion, sexual orientation, marital status, familial status, age, disability (including HIV/AIDS), student status, or any other arbitrary factor, have equal access to available public housing.

Anyone interested in public housing assistance can obtain and complete an application at the Conventional Application Center or request an application by telephone. Applications are also available for pick up at any HACLA Public Housing site during normal business hours and on the agency’s website. Once received, the application is date and time-stamped and the applicant information is input into the HACLA computer system.

Applicants are scheduled for interviews based on application date and current preference. Eligibility is determined by meeting established income guidelines and other HUD requirements. These guidelines and requirements include, but are not limited to, non-citizen rule requirements, criminal background checks and records of meeting financial obligations.

Eligible applicants are assigned a place on the waiting list based on the time and date of the receipt of the completed application, location preference, and the size and type of unit needed. Each applicant, regardless of protected class, is offered a suitable unit in the location with the highest number of vacancies.

3. HACLA Policies and Plans

As a recipient of federal funds, HACLA must adopt policies and plans for applicant intake and screening and property management. In administering housing programs according to its policies and plans, HACLA does not utilize criteria or methods of administration that have the effect of discriminating against persons on the basis of their race, color, sex, religion (creed), disability, familial status, national origin, ancestry, sexual orientation, marital status, source of income, or age. Also, HACLA may not take any action that defeats or impairs the availability of a HUD financed program or activity with respect to any persons on the basis of their race, color, sex, religion (creed), disability, familial status, or national origin.

Section 8 Administrative Plan

The Section 8 Administrative Plan specifies that applicants for and participants in HACLA’s assisted housing programs who encounter discrimination in the exercise of their rights under Federal, State or local laws are given assistance in addressing discrimination complaints. As a policy, HACLA does not discriminate against individuals with disabilities and provides reasonable accommodations to all housing programs and related facilities included under its jurisdiction.

Rules to Affirmatively Further Fair Housing

In 2012, HACLA published rules to affirmatively further fair housing for applicants and participants in its programs, and users of its facilities and housing. Specifically, the document provides an overview of programs and services that benefit protected classes, efforts to expand public housing choice, and actions to reasonably accommodate persons with disabilities.

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Fair Housing Complaint Procedures

HACLA program recipients or applicants who believe they have experienced discrimination in violation of the Federal Fair Housing Act or state fair housing laws are provided with HUD forms and contact information for the Housing Rights Center (HRC) of Los Angeles. The forms are available in four languages: English, Spanish, Korean, and Russian. Statistics for fair housing complaints filed with HUD are included in the Fair Housing Profile section of this AI (Chapter 6).

Analysis of Impediments to Fair Housing Choice

As a recipient of HUD funds, HACLA is also required to actively further fair housing choice: 1) by assessing potential impediments to fair housing; 2) taking actions to address impediments identified; and 3) maintaining fair housing records. HACLA updates its affirmatively furthering fair housing statement and provides it to HUD with grant applications. The HACLA participated in development of this AI for the City of Los Angeles. The required AI components for a Housing Authority (i.e., location of public housing units and vouchers; demographic profile of assisted residents; impact posed by demolition of public housing units; and, nature or extent of denial of assistance among protected classes) are incorporated above.

G. U.S. Department of Housing and Urban Development (HUD)

1. Section 8 Contracts

Another form of Section 8 rental assistance is project-based Section 8 contracts which Congress created in 1974 as part of the Housing and Community Development Act. The contracts are agreements between owners of specific properties and HUD to set aside a portion of the units for income-qualified tenants. The rental assistance is tied to the property, unlike the Housing Choice Vouchers, which are portable with the tenants. When Congress established the various housing construction programs in the 1970s, 20-year project-based Section 8 contracts were used in conjunction with mortgage financing mechanisms to encourage the construction of affordable housing. Most of the mortgage loans had a 40-year loan term with an option to prepay the mortgage after 20 years. When project owners decide to prepay the remaining mortgage after 20 years (at the same time the original Section 8 contracts are expiring), the units can convert to market rate housing. Since the 1990s, many affordable housing developments have become eligible to prepay the mortgage and opt out of Section 8 contracts.

Challenges

HUD oversees properties supported by a range of insured and direct loans provided by HUD or rental assistance provided under project-based Section 8 Housing Assistance Payments. Many properties are reaching the end of their original mortgage term or expiration of rental assistance contracts. Data reported in the City’s Housing Element indicate that Section 8 contract restrictions on 1,257 units expired between January 1998 and July 2007. None of these units were in HUD Section 202 or Section 811 projects serving elderly and/or disabled persons. Between July 2008 and June 2018, more than 13,000 units that received HUD financing,

City of Los Angeles Page 122 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 including Section 8, were or will be at-risk of losing their rental subsidies or affordability restrictions through expiration of covenants.

With the supply of Section 8 housing already well below the demand, conversion to market rate would exacerbate the problem of long waiting lists for an already vulnerable segment of the population. Recognizing the problems these expiring contracts may cause, HUD established various initiatives to attempt to stem the tide of conversions. Some initiatives include marking some below-market Section 8 properties up to market rents and permitting non-profit owners of older-assisted properties to raise rents to fund necessary capital improvements.

Recognizing the problems these expiring contracts may cause, HUD provides tenant protection voucher assistance, subject to the availability of appropriations. As of February 2012, 1,847 households received tenant protection voucher assistance due to certain housing conversion actions (mortgage prepayment, contract termination or expiration). Nevertheless, in a tight housing market, financial incentives offered by HUD are not always competitive to the market rents that owners can capture upon conversion of the units to non-low income uses.

Evidence has shown that the dynamics behind the opt-out or renewal decision are a mixed blessing for Section 8 recipients. Owners opt out of the Section 8 programs for reasons that are financially motivated or merely because of difficulties encountered in dealing with HUD oversight. But researchers have found that owners, whatever their reasons may be, have a stronger tendency to renew Section 8 contracts in more segregated and traditional low income neighborhoods and are less likely to renew in racially and economically integrated neighborhoods.32

Section 8 was designed to offer families an alternative to living in conventional public housing developments. While not always true, many public housing projects were located in the “path of least resistance”, often in poor minority areas.33 Section 8 was intended to offer residents a chance to live in higher quality neighborhoods and have access to better schools and jobs. With owners opting out in more integrated neighborhoods, Section 8 recipients will be increasingly confined to low income areas, defeating the original purpose of the program.

H. Community Participation

The ability of individuals to petition their elected officials and participate in public decisions is fundamental to American civil society. Citizens, particularly in California, have come to expect that public officials will consult them during the development of policies affecting land uses, the preparation of land use regulations, and permitting decisions on specific project proposals.

The City of Los Angeles has established a number of commissions and councils to help guide land use and zoning decisions. These appointed or elected individuals, to varying degrees, have the ability to influence the type and cost of housing being offered in the City. A diversity of points of view is important to reflect the varied interests of residents throughout the City.

32 Forbes, p. 1 33 Ibid., p. 3

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The following sections describe the commissions and councils that have direct influence on housing matters, particularly those that relate to housing for persons in the protected classes.

1. Area Planning Commissions

Under the 2000 Charter mandate, seven Area Planning Commissions (APCs) were created: North Valley, South Valley, West Los Angeles, Central Los Angeles, East Los Angeles, South Los Angeles, and Harbor (see Figure 1 for the geographic boundaries). The boundaries are drawn so that all parts of the City are served. Each APC has five members, who, like the citywide Planning Commission members, are appointed by the Mayor and must reside within the area boundaries that the commission serves.

For purposes of land use and zoning decision-making, the APCs make the initial determinations on certain applications for conditional use permits within their planning area boundaries and act as the first appellate body if a variance has been denied in a zoning administrator’s decision hearing. Specifically, the role of the APCs is to:

. Hear and determine appeals where it is alleged there is error or abuse of discretion in any order, requirement, decision, interpretation or other determination made by a Zoning Administrator; . Hear and make determinations on any matter normally under the jurisdiction of a Zoning Administrator when that matter has been transferred to the jurisdiction of an area planning commission because the Zoning Administrator has failed to act within the time limits prescribed by ordinance; . Hear and determine applications for, or appeals related to, conditional use permits and other similar quasi-judicial approvals, in accordance with procedures prescribed by ordinance; . Make recommendations with respect to zone changes or similar matters referred to it from the City Planning Commission; and . Hear and determine other matters delegated to it by ordinance.

The composition of the area planning commissions at the time of this report (April 2012) is as follows:

North Valley East Los Angeles . Oshin Harootoonian (Other) . Javier Angulo (Latino) . Richard Leyner (Caucasian) . Ana Hanson (Latina) . Veronica Padilla (Latina) . Luis Lopez (Latino) . Victor Sampson (Caucasian) . David Marquez (Latino) . Quyen Vo-Ramirez (Asian Pacific Islander) . Kei Karn Nagao (Asian Pacific Islander) . South Valley South Los Angeles . Steve Cochran (Latino) . Juan Aquino (Latino) . Matt Epstein (Caucasian) . Victoria Franklin (African American) . Noelle Guzman (Latina) . Rochelle Mills (African American) . Lydia Mather (Caucasian) . Faith Mitchell (African American) . Gordon Murley (Caucasian) . James Silcott (African American) .

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West Los Angeles Harbor . Thomas Donovan (Caucasian) . Emma Castillo (Latina) . Joyce Foster (Caucasian) . Eric Eisenberg (Caucasian) . Joseph Halper (Caucasian) . Kandee Lewis (African American) . Glenda Martinez (Latina) . Phillip Trigas (Caucasian) . Erica Teasley Linnick (African American) . Joeann Valle (Caucasian) Central Los Angeles . Franklin Acevedo (Latino) . Young Kim (Asian Pacific Islander) . Chanchanit Martorell (Asian Pacific Islander) . Kevin Norton (Caucasian) . Daniel Suh (Asian Pacific Islander)

2. Neighborhood Councils

The second significant charter reform change of 2000 affecting Los Angeles land use and zoning procedures was the creation of a citywide system of Neighborhood Councils. Neighborhood Councils are city-certified local groups made up of people who live, work, own property or have some other connection to a neighborhood. Neighborhood Council Board Members are elected or selected to their positions by the neighborhoods themselves.

Neighborhood Councils represent neighborhoods with a minimum population of 20,000 people. The average population represented by a Neighborhood Council is 38,000 people. Neighborhood Council Board size various across the City from seven to over 30 individuals depending on what the neighborhood believes will meet its needs.

Representatives from Neighborhood Councils meet with the Mayor to discuss priorities in the annual development of the City budget, prior to its submittal and approval by City Council. Councils also receive advance notice of issues and projects that are important to them and their neighborhoods so they can understand, discuss them, and voice the opinions of the neighborhood to the City before final decisions are made.

There are currently 101 Neighborhood Councils across Los Angeles. Councils must establish bylaws and go through the certification process with the Board of Neighborhood Commissioners and the Department of Neighborhood Empowerment before they can operate. Due to the large number of neighborhood councils, it is not practical to provide information on the composition and background of each council member in this document.

3. Citywide Planning Commission

The City Planning Commission consists of nine members appointed by the Mayor and confirmed by the City Council. The role of the Planning Commission is to:

. Give advice and make recommendations to the Mayor, Council, Director of Planning, municipal departments and agencies with respect to City planning and related activities and legislation; . Make recommendations concerning amendment of the General Plan and proposed zoning ordinances;

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. Make reports and recommendations to the Council and to other governmental officers or agencies as may be necessary to implement and secure compliance with the General Plan; and . Perform other functions prescribed by the Charter or ordinance.

The Planning Commission hears appeals of administrative decisions and conducts public hearings on discretionary actions such as subdivision maps, specific plans, design review, rezoning, zoning text amendments, and general plan amendments.

The composition of the Planning Commission at the time of this report (April 2012) is as follows:

. Sean Burton (Caucasian) . Diego Cardosa (Latino) . Regina Freer (African American) . George Hovaguimian (Caucasian) . Justin Kim (Asian Pacific Islander) . Robert Lessin (Caucasian) . Barabara Romero (Latina) . William Roschen (Caucasian) . Michael Woo (Asian Pacific Islander)

4. Affordable Housing Commission

The Affordable Housing Commission was established to serve as an advisory body to the Mayor, the City Council, and the General Manager of the Los Angeles Housing Department (LAHD) on housing matters, including rent stabilization. The seven-member Commission appointed by the Mayor is charged with these specific tasks:

. Advise the Mayor and the City Council with respect to the City's housing needs; . Recommend to the Mayor and the City Council a City housing policy and specific goals to meet the City's housing needs; . Coordinate the City's various housing programs; . Annually review the housing plans and budgets of City agencies and departments to ensure conformance with City housing policy; . Evaluate proposed policy and legislation for their impact on the preservation and production of housing and recommend to the Mayor and the City Council modifications that are necessary to achieve the City's housing goals; . Collaborate with City agencies and departments in the initiation of policies and programs that favorably impact housing development; and . Encourage public and private partnerships in promoting housing preservation and production.

The membership of the Affordable Housing Commission at the time of this report (April 2012) and their backgrounds are:

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. Alice Harris (African American) . Pete Navarro (Latino) . Evangeline Ordaz-Molina (Latina) . William Epps (African American) . Stephanie Klaskey-Gamer (Caucasian) . Alice Salinas (Latina)

5. Commission on Disability

The Commission on Disability is an advisory body that, with the Department on Disability, seeks to respond to the needs and concerns of disabled citizens in the City of Los Angeles. The Commission advocates for people with disabilities and serves in an advisory capacity to the Department. The Commission holds public hearings on critical issues, identifies priority issues to be addressed, and makes recommendations to the Mayor and City Council.

The membership of the Commission on Disability at the time of this report (April 2012) and their backgrounds are:

. Theresa May de Vera (Asian Pacific Islander) . Sandy Driver-Gordon (Caucasian) . Louis Herrera (Latino) . Robert Levy (Caucasian) . Luis Mata (Latino) . Gordon Overton (Caucasian) . John Rodriguez (Latino) . Betty Wilson (African American) . David Wolf (Caucasian)

6. Disabled Access Appeals Commission

The Disabled Access Appeals Commission hears appeals of actions taken by the Department of Building and Safety in the enforcement of the requirements of state law dealing with access to public accommodations and housing by physically disabled persons. The Commission may uphold, modify, or overturn decisions made by the Department.

The membership of the Commission at the time of this report (April 2012) and their backgrounds are:

. Jorge Acevedo (Latino) . Anthony Braswell (Caucasian) . Crystal Dominick (Latina) . Rod Lane (Caucasian) . Jemiss Nazar (Other)

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7. Housing Authority of the City of Los Angeles

The Housing Authority of the City of Los Angeles (HACLA) is a state-chartered public agency. With an annual budget of more than $1 billion, HACLA is one of the nation’s largest public housing authorities. Its funds come from five main sources: HUD's annual operating subsidy, HUD's annual Capital Fund, Section 8 administrative fees, rent from public housing residents plus other program and capital grants from various sources.

The Housing Authority is governed by seven-member Board of Commissioners appointed by the Mayor and confirmed by the City Council. The membership of the Housing Authority at the time of this report (April 2012) and their backgrounds are:

. Kimberly Freeman (African American) . Margarita Garr (African American) . Dennis Hernandez (Latino) . Lucelia Hooper (African American) . Mitchell Kamin (Caucasian) . Daisy Lopez (Latina) . Alicia Maldonado (Latina)

8. Los Angeles Homeless Services Authority

The Los Angeles Homeless Services Authority (LAHSA) is a joint power agency established in 1993 to administer the funding of homeless programs in the City and County of Los Angeles. LAHSA is the lead agency in the Los Angeles Continuum of Care, and coordinates and manages over $70 million dollars annually in Federal, State, County and City funds for programs providing shelter, housing and services to homeless persons in Los Angeles City and County.

Through LAHSA, funding, program design, outcomes assessment and technical assistance is provided to over 100 non-profit partner agencies who operate within the City and County assisting persons who are homeless achieve independence and stability in permanent housing. Our partner agencies provide a continuum of programs ranging from outreach, access centers, emergency shelters, safe havens, transitional and permanent housing, and prevention along with the necessary supportive services designed to provide the tools and skills required to attain a stable housing environment.

Specialized programs funded through LAHSA address a wide-range of issues related to homelessness, including but not limited to: domestic violence, mental illness, substance abuse, job training, family strengthening, health, mainstream benefits enrollment, and most importantly, supportive short and long-term housing. Additionally, LAHSA partners with both the City of Los Angeles and the County of Los Angeles to integrate services and housing opportunities to ensure wide distribution of service and housing options throughout the Los Angles Continuum of Care.

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LAHSA is governed by a politically appointed, 10-member Commission. Five members are selected by the County Board of Supervisors and five are chosen by the Mayor and City Council. The Commission has the authority to make budgetary, funding, planning and program policies.

The following are members appointed by the City of Los Angeles and their backgrounds at the time of this report (April 2012) and their backgrounds are:

. Elise Buik (Caucasian) . Antonio Manning (African American) . Kerry Morrison (Caucasian) . Cecil Murray (African American) . Ramona Ripston (Caucasian)

The five members appointed by the County Board of Supervisors are not identified in this report as the City has no influence over these appointments.

9. Commission for Community and Family Services

The City of Los Angeles Commission on Community and Family Services was established in July 2010. The fifteen-member voluntary Board serves in a policy advisory capacity to the Mayor, City Council and Community Development Department (CDD) to:

. Address the needs, interests and concerns of children, youth and families living in poverty in the city of Los Angeles; . Provide policy guidance to the City’s Community Development Department in its administration of the CDBG program under the Housing and Community Development Consolidated Plan, and its funding priorities, directed towards the goal of alleviating poverty in the City; . Engage the public on the policy priorities of the Housing and Community Development Consolidated Plan; . Coordinate with relevant City departments and non-City governmental agencies, nonprofit agencies, academia and philanthropy to create an expanded integrated and collaborative human service delivery system that will put children and their families on a pathway out of poverty and into self-sufficiency; and . Make policy recommendations on relevant legislative and regulatory initiatives at all levels of government.

The Board’s membership at the time of this report (April 2012) and their backgrounds are:

. Carolina Castillo (Latina) . Yvonne Chan (Asian Pacific Islander) . Deborah Davies (Caucasian) . Debra Duardo (Latina) . Mary Garcia (Latina) . Peggy Hill (African American) . Alfreda Iglehart (African American)

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. Alicia Lara (Latina) . Marc Little (African American) . Michael Manigault (Caucasian) . Carrie Miller (Caucasian) . Erin Pak (Asian Pacific Islander) . Angela Pinto (Other) . Benjamin Torres (Latino) . Barbara Yaroslavsky (Caucasian)

10. Rent Adjustment Commission

The Rent Adjustment Commission (RAC) of the City of Los Angeles is responsible for adopting policies, rules, and regulations regarding the proper and equitable administration of the Rent Stabilization Ordinance (RSO). The Commission also conducts studies, investigations, and hearings to gather necessary information to promulgate, administer, and enforce any regulation, rule, or order adopted in accordance with the RSO.

The Commission consists of seven members appointed by the Mayor and confirmed by the City Council. The membership of the Commission at the time of this report (April 2012) and their backgrounds are:

. Alex Cha (Asian Pacific Islander) . Jeffery Daar (Caucasian) . JC Lacey (Latino) . Paula Leftwich (African American) . Ramon Muniz (Latino) . Maria Townsend (Latina) . Belinda Vega (Latina)

11. Cultural Heritage Commission

The Cultural Heritage Commission (CHC) is a five-member, mayoral-appointed commission that considers nominations of sites as City Historic-Cultural Monuments (designated City landmarks) and reviews proposed project work affecting more than 900 existing Historic- Cultural Monuments.

The Commission also serves as the city’s primary forum for the discussion of historic preservation policy. Recommendations of the Cultural Heritage Commission are forwarded to the City Council for their final action. The Cultural Heritage Ordinance also gives the Commission the authority to temporarily delay alteration or demolition of historically significant structures until a proper review can be completed.

The membership of the Commission at the time of this report (April 2012) and their backgrounds are:

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. Richard Barron (Caucasian) . Tara Hamacher (Caucasian) . Gail Kennard (African American) . Roella Louie (Asian Pacific Islander) . Oz Scott (African American)

12. Cultural Affairs Commission

The Mayor-appointed Cultural Affairs Commission serves as an advisory body to the Department of Cultural Affairs (DCA). The DCA generates and supports high quality arts and cultural experiences for Los Angeles’ four million residents and 25 million annual visitors. DCA advances the social and economic impact of the arts and assures access to arts and cultural experiences through grant making, marketing, public art, community arts programming, arts education, and partnerships with artists and arts and cultural organizations in neighborhoods throughout the City of Los Angeles. The Commission approves the design of structures built on or over City property and accepts works of art to be acquired by the City.

The membership of the Commission at the time of this report (April 2012) and their backgrounds are:

. York Chang (Asian Pacific Islander) . Annie Chu (Asian Pacific Islander) . Richard Montoya (Latino) . Lee Ramer (Caucasian) . Josephine Ramirez (Latina) . Jonathan Weedman (Caucasian)

13. Harbor Commission

The Los Angeles Board of Harbor Commissioners oversees the management and operation of the Port of Los Angeles, the number one port by container volume and cargo value in the United States. The five-member board is appointed by the Mayor of Los Angeles and confirmed by the Los Angeles City Council. The membership of the Commission at the time of this report (April 2012) and their backgrounds are:

. David Arian (Caucasian) . Robin Kramer (Caucasian) . Doug Krause (Caucasian) . Cindy Miscikowski (Caucasian) . Won Sung Sohn (Asian Pacific Islander)

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Public Review Draft May 30, 2012 Chapter 5: Fair Housing Profile

This chapter provides an overview of the institutional structure of the housing industry with regard to fair housing practices. In addition, this chapter discusses the fair housing services available to residents in the City of Los Angeles, as well as the nature and extent of fair housing complaints received by the fair housing provider. Typically, fair housing services encompass the investigation and resolution of housing discrimination complaints, discrimination auditing/testing, and education and outreach, including the dissemination of fair housing information. Tenant/landlord counseling services are usually offered by fair housing service providers but are not considered fair housing services.

A. Fair Housing Practices in the Homeownership Market

Part of the American dream involves owning a home in the neighborhood of one's choice. Homeownership is believed to enhance one’s sense of well-being, is a primary way to accumulate wealth, and is believed to strengthen neighborhoods, because residents with a greater stake in their community will be more active in decisions affecting the future of their community. Not all Americans, however, have always enjoyed equal access to homeownership due to credit market distortions, “redlining,” steering, and predatory lending practices.

On December 5, 1996, HUD and the National Association of REALTORS® (NAR) entered into a Fair Housing Partnership. Article VII of the HUD/NAR Fair Housing Partnership Resolution provides that HUD and NAR develop a Model Affirmative Fair Housing Marketing Plan for use by members of the NAR to satisfy HUD’s Affirmative Fair Housing Marketing regulations. Yet there is still much room for discrimination in the housing market. This section analyzes potential impediments to fair housing in the home ownership sector.

1. The Homeownership Process

The following discussions describe the process of homebuying and likely situations when a person/household may encounter housing discrimination. However, much of this process occurs in the private housing market over which local jurisdictions have little control or authority to regulate. The recourse lies in the ability of the contracted fair housing service providers in monitoring these activities, identifying the perpetrators, and taking appropriate reconciliation or legal actions.

Advertising

The first thing a potential buyer is likely to do when they consider buying a home is search advertisements either in magazines, newspapers, or the Internet to get a feel for what the market offers. Advertisements cannot include discriminatory references such as the use of words describing current or potential residents, neighbors, or the neighborhood in terms that could be interpreted to discourage or exclude members of protected classes. Examples of prohibited advertisement references include:

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. Adults preferred; . Perfect for empty nesters; . Conveniently located by a Catholic Church; or . Ideal for married couples without kids.

Real Estate Advertising in the City of Los Angeles In a survey of online listings for homes available for purchase in Los Angeles in February 2012, about one-third of advertisements included potentially discriminatory language. Of a total of 1,000 listings reviewed, 368 listings (37 percent) included references to something other than just the description of the available home and amenities and services included (Table 41). A vast majority of the questionable advertisements were targeted at families, specifically at families with children. Other ads included descriptions that may be interpreted as potentially discriminatory.

A significant portion of the advertisements included potentially discriminatory language, beyond the description of the homes. A vast majority of the questionable ads were targeted at attracting families.

Table 41: Potential Discrimination in Listings of For-Sale Homes in Los Angeles (2012) Number of Discrimination Type Potentially Discriminatory Language* Listings No Discriminatory 630 n/a Language Income Related 1 . NO FHA 203-B or Conventional . Brockton Elementary. Emerson Middle and University High School close by . Close to an elementary school is an additional plus for families with children . Educational facilities such as Robert A. Millikan Middle School, Emek Hebrew Academy, and Notre Dame High School are just minutes away from the home. . Fantastic Rancho Park/Westwood location and in the excellent Westwood Household 363 Charter School District. Size/Family Related . Fully enclosed backyard for kids . Ideal new first home for a family just starting out. . Playground for kids. . This community is also within the coveted Mar Vista Elementary School district. . This is truly an ideal family home . Ideal for those who enjoy urban life style . Close to shopping, transportation and synagogues Miscellaneous 4 . For commuters, easy access to 10, 710 Fwy's and Metrolink station . Perfect home for first time homebuyers. Source: www.realtor.com, accessed February, 2012. *Examples are direct quotes from the listings (including punctuation and emphasis).

Advertising has become a sensitive area in real estate. In some instances advertisements published in non-English languages may make those who speak English uncomfortable, yet when ads are only placed in English they place non-English speaking residents at a disadvantage. While real estate advertising can be published in other languages, by law an English version of the ad must also be published, and monitoring this requirement is difficult, if not impossible.

Even if an agent does not intend to discriminate in an ad, suggesting to a reader whether or not a particular group is preferred is still considered a violation. Litigation has also set precedence

City of Los Angeles Page 134 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 for violations in advertisements that hold publishers, newspapers, Multiple Listing Services, real estate agents, and brokers accountable for discriminatory ads.

Lending

Initially, buyers must find a lender that will qualify them for a loan. This part of the process entails an application, credit check, ability to repay, amount eligible for, choosing the type and terms of the loan, etc. Applicants are requested to provide a lot of sensitive information including their gender, ethnicity, income level, age, and familial status. Most of this information is used for reporting purposes required of lenders by the Community Reinvestment Act (CRA) and the Home Mortgage Disclosure Act (HMDA).

Lending discrimination can occur during advertising/outreach, pre-application inquiries, loan approval/denial and terms/conditions, and loan administration. Further areas of potential discrimination include: differences in the level of encouragement, financial assistance, types of loans recommended, amount of down payment required, and level of customer service provided.

Based on the analysis of HMDA data conducted for this AI (see Chapter 4), minority households in the City, specifically Black and Hispanic households, have issues accessing mortgage financing.

Appraisals

Banks order appraisal reports to determine whether or not a property is worth the amount of the loan they will be giving. Generally speaking, appraisals are based on the comparable sales of properties within the neighborhood of the property being appraised. Other factors are taken into consideration, such as the age of the structure, any improvements made, location, general economic influences, etc. However, during the mortgage lending and refinancing frenzy prior to 2008, there have been reports that appraisers inflated home values in order to entice refinancing.

Real Estate Agents

Real estate professionals may act as agents of discrimination. Some unintentionally, or possibly intentionally, may steer a potential buyer to particular neighborhoods by encouraging the buyer to look into certain areas; others may choose not to show the buyer all choices available. Agents may also discriminate by whom they agree to represent, whom they turn away, and the comments they make about their clients.

The California Association of REALTORS® (CAR) has included language on many standard forms disclosing fair housing laws to those involved. Many REALTOR® Associations also host fair housing trainings/seminars to educate members on the provisions and liabilities of fair housing laws, and the Equal Opportunity Housing Symbol is also printed on all CAR forms as a reminder.

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Covenants, Conditions, and Restrictions (CC&Rs)

CC&Rs are restrictive promises that involve voluntary agreements, which run with the land they are associated with and are listed in a recorded Declaration of Restrictions. The Statute of Frauds (Civil Code Section 1624) requires them to be in writing, because they involve real property. They must also be recorded in the County where the property is located in order to bind future owners. Owners of parcels may agree amongst themselves as to the restrictions on use, but in order to be enforceable they must be reasonable.

The California Department of Real Estate (DRE) reviews CC&Rs for all subdivisions of five or more lots, or condominiums of five or more units. This review is authorized by the Subdivided Lands Act and mandated by the Business Professions Code, Section 11000. The review includes a wide range of issues, including compliance with fair housing law, and must be completed and approved before the DRE will issue a final subdivision public report. This report is required before a real estate broker or anyone can sell the units, and each prospective buyer must be issued a copy of the report. If the CC&Rs are not approved, the DRE will issue a “deficiency notice,” requiring the CC&Rs be revised. CC&Rs are void if they are unlawful, impossible to perform or are in restraint on alienation (a clause that prohibits someone from selling or transferring his/her property).

Older subdivisions and condominium/ townhome developments may contain illegal clauses which are enforced by the homeowners associations (HOAs). While homeowner’s associations have the authority to review and make necessary amendments to CC&Rs, many are not aware of their fair housing responsibilities.

Homeowners Insurance Industry

Insurance is the cornerstone of credit. Without insurance, banks and other financial institutions lend less. Fewer loans leads to fewer new homes constructed and more existing homeowners will forgo repairs leaving buildings to deteriorate faster.34 Many traditional industry underwriting practices which may have some legitimate business purpose also adversely affect lower income and minority households and neighborhoods. For example, if a company excludes older homes from coverage, lower income and minority households who can only afford to buy in older neighborhoods may be disproportionately affected. Another example includes private mortgage insurance (PMI). PMI obtained by applicants from CRA-protected neighborhoods is known to reduce lender risk. Redlining of lower income and minority neighborhoods can occur if otherwise qualified applicants are denied or encouraged to obtain PMI.35 Underwriting guidelines are not public information; however, consumers have begun to seek access to these underwriting guidelines to learn if certain companies have discriminatory policies.

The California Fair Access to Insurance Requirements (FAIR) Plan was created by the Legislature in 1968 after the brush fires and riots of the 1960s made it difficult for some people to purchase fire insurance due to hazards beyond their control. The FAIR Plan is designed to

34 National Advisory Panel on Insurance in Riot Affected Areas, 1968. 35 “Borrower and Neighborhood Racial Characteristics and Financial Institution Financial Application Screening”; Mester, Loretta J; Journal of Real Estate Finance and Economics; 9 241-243; 1994

City of Los Angeles Page 136 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 make property insurance more readily available to people who have difficulty obtaining it from private insurers because their property is considered "high risk."

The California Organized Investment Network (COIN) is a collaboration of the California Department of Insurance, the insurance industry, community economic development organizations, and community advocates. This collaboration was formed in 1996 at the request of the insurance industry as an alternative to state legislation that would have required insurance companies to invest in underserved communities, similar to the federal CRA that applies to the banking industry. COIN is a voluntary program that facilitates insurance industry investments, which provide profitable returns to investors, and economic and social benefits to underserved communities.

Credit and FICO Scores

Credit history is one of the most important factors in obtaining a home purchase loan. Credit scores determine loan approval, interest rates associated with the loan, as well as the type of loan an applicant will be given. Applicants with high credit scores are generally given conventional loans, while lower and moderate range scores revert to FHA or other government- backed loans. Applicants with lower scores also receive higher interest rates on the loans as a result of being perceived as a higher risk to the lender, and may even be required to pay points depending on the type of lending institution used.

Fair Isaac and Company (FICO), which is the company used by the Experian (formerly TRW) credit bureau to calculate credit scores, has set the standard for the scoring of credit history. Trans-Union and Equifax are two other credit bureaus that also provide credit scores, though they are typically used to a lesser degree. In short, points are awarded or deducted based on certain items such as how long one has had credit cards, whether one makes payments on time, if credit balances are near maximum, etc. Typically, the scores range from the 300s to around 850, with higher scores demonstrating lower risk. Lower credit scores require a more thorough review than higher scores and mortgage lenders will often not even consider a score below 600.

FICO scores became more heavily relied on by lenders when studies conducted show that borrowers with scores above 680 almost always make payments on time, while borrowers with scores below 600 seemed fairly certain to develop repayment problems. Some of the factors that affect a FICO score are:

. Delinquencies . New accounts (opened within the last twelve months) . Length of credit history (a longer history of established credit is better than a short history) . Balances on revolving credit accounts . Public records, such as tax liens, judgments, or bankruptcies . Credit card balances . Number of inquiries . Number and types of revolving accounts

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However, the current mortgage lending crunch resulted (in part) from lenders providing mortgage financing to borrowers who are not credit worthy or steering borrowers who can qualify for lower cost loans to the subprime market.

2. National Association of REALTORS® (NAR)

NAR has developed a Fair Housing Program to provide resources and guidance to REALTORS® in ensuring equal professional services for all people. The term REALTOR® identifies a licensed professional in real estate who is a member of the NAR; however, not all licensed real estate brokers and salespersons are members of the NAR.

Code of Ethics

Article 10 of the NAR Code of Ethics provides that “REALTORS® shall not deny equal professional services to any person for reasons of race, color, religion, sex, handicap, familial status, or national origin. REALTORS® shall not be a party to any plan or agreement to discriminate against any person or persons on the basis of race, color, religion, sex, handicap, familial status, or national origin.”

A REALTOR® pledges to conduct business in keeping with the spirit and letter of the Code of Ethics. Article 10 imposes obligations upon REALTORS® and is also a firm statement of support for equal opportunity in housing. A REALTOR® who suspects discrimination is instructed to call the local Board of REALTORS®. Local Boards of REALTORS® will accept complaints alleging violations of the Code of Ethics filed by a home seeker who alleges discriminatory treatment in the availability, purchase or rental of housing. Local Boards of REALTORS® have a responsibility to enforce the Code of Ethics through professional standards procedures and corrective action in cases where a violation of the Code of Ethics is proven to have occurred.

Additionally, Standard of Practice Article 10-1 states that “REALTORS® shall not volunteer information regarding the racial, religious or ethnic composition of any neighborhood and shall not engage in any activity which may result in panic selling. REALTORS® shall not print, display or circulate any statement or advertisement with respect to the selling or renting of a property that indicates any preference, limitations or discrimination based on race, color, religion, sex, handicap, familial status, or national origin.”

Diversity Certification

NAR has created a diversity certification, “At Home with Diversity: One America” to be granted to licensed real estate professionals who meet eligibility requirements and complete the NAR “At Home with Diversity” course. The certification will signal to customers that the real estate professional has been trained on working with diversity in today’s real estate markets. The coursework provides valuable business planning tools to assist real estate professionals in reaching out and marketing to a diverse housing market. The NAR course focuses on diversity awareness, building cross-cultural skills, and developing a business diversity plan.

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3. California Department of Real Estate (DRE)

The California DRE is the licensing authority for real estate brokers and salespersons. As noted earlier, not all licensed brokers and salespersons are members of the National or California Association of REALTORs®.

The DRE has adopted education requirements that include courses in ethics and in fair housing. To renew a real estate license, each licensee is required to complete 45 hours of continuing education, including three hours in each of the four mandated areas: Agency, Ethics, Trust Fund, and Fair Housing. The fair housing course contains information that will enable an agent to identify and avoid discriminatory practices when providing real estate services to clients. These licensees are also required to complete a minimum of 18 additional hours of courses related to consumer protection. The remaining hours required to fulfill the 45 hours of continuing education may be related to either consumer service or consumer protection, at the option of the licensee.

4. California Association of REALTORS® (CAR)

CAR is a trade association of 92,000 realtors statewide. As members of organized real estate, realtors also subscribe to a strict code of ethics as noted above. CAR has recently created the position of Equal Opportunity/Cultural Diversity Coordinator. CAR holds three meetings per year for its general membership, and the meetings typically include sessions on fair housing issues. Current outreach efforts in the Southern California area are directed to underserved communities, and state-licensed brokers and sales persons who are not members of the CAR.

REALTOR® Associations Serving the City of Los Angeles

REALTOR® Associations are generally the first line of contact for real estate agents who need continuing education courses, legal forms, career development, and other daily work necessities. The frequency and availability of courses varies amongst these associations, and local association membership is generally determined by the location of the broker for which an agent works. Complaints involving agents or brokers may be filed with these associations.

Monitoring of services by these associations is difficult as detailed statistics of the education/services the agencies provide or statistical information pertaining to the members is rarely available. Currently, the following REALTOR® Associations serve the City of Los Angeles:

. Beverly Hills/Greater Los Angeles Association of REALTORS® (BHGLAAR) . Southwest Los Angeles Association of REALTORS® (SWLAAOR) . South Bay Association of REALTORS® (SBAOR) . Southland Regional Association of REALTORS® (SRAR)

The REALTOR® Associations above use a number of listing services to serve their clients including, MLS CLAW (Combined LA/Westside MLS), CRMLS (California Regional Multiple Listing Service), and CRMLS (California Regional MLS).

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Complaints against members are handled by the associations. All complaints must be in writing. Once a complaint is received, a grievance committee reviews the complaint to decide if it warrants further investigation. If further investigation is necessary, a professional standards hearing with all parties involved takes place. If the member is found guilty of a violation, the member may be expelled from the association, and the California DRE is notified.

B. Fair Housing Practices in the Rental Market

1. Rental Process

Advertising

Los Angeles, like most parts of California, faces a shortage of rental housing. Many rental properties have low vacancy rates and do not require published advertising. Often, vacancy is announced either via word of mouth of existing tenants or a for-rent sign outside the property. Unless one happens to drive by the neighborhood or have friends or families currently residing at the property, one may not have access to information regarding vacancy. Furthermore, this practice tends to intensify segregation of neighborhoods and properties that already have a high concentration of a racial/ethnic group. When advertising is done, no checks-and-balances mechanism exists to ensure English advertising is provided.

Review of Rental Ads in Los Angeles As with ad listings for for-sale homes, rental advertisements cannot include potentially discriminatory references. Of a total of 1,000 rental listings surveyed in February 2012, 317 advertisements were found to contain potentially discriminatory language (Table 42). While advertisements would rarely state discrimination outright, often the descriptions beyond the physical characteristics of the units suggest a certain lifestyle that works to steer specific groups to or from the units. A majority of the problematic language involves disability-related and household size/family related references.

A significant portion of the rental ads reviewed as part of this AI included potentially discriminatory language. A majority of the problematic language involves references to disabilities, familial status, and household size.

Table 42: Potential Discrimination in Listings of Homes for Rent (2012) Number of Discrimination Type Potentially Discriminatory Language Listings No Discriminatory 683 N/A Language . No Pets . 100% smoke-free building. Sorry no pets (please don't ask). Disability Related 193 . Sorry, no pets and no smokers ..great for all those athletes in town run to the stairs . This is a clean and quiet, NO PETS, building. . WE DO NOT participate in section 8 program. Income Related 22 . Section 8 is not accepted . Non-smoking, good rental and employment history.

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Table 42: Potential Discrimination in Listings of Homes for Rent (2012) Number of Discrimination Type Potentially Discriminatory Language Listings . Nice neighborhood, good school, private secured yard. . Has the gym to keep you in shape, an amazing resort style pool area to have fun in the sun and a home theater to entertain family and guest. . Close to a schools right across the street - The Brand New Robert Kennedy School....Kindergarten through High School . Playground for kids . Several wonderful playground areas where your children can roam safely . Right school district (San Dimas High, Lone Hill Middle School), near freeways. Household Size/ 121 Perfect for family with teenagers or home business or someone with lots of "toys" Family Related . Wanted 1 or 2 people not exceptions, quite, non smoker, heavy drinking, drugs, no pets. . Great for student or working professional. No Pets. . No pets, drugs, smoking, loud parties, loud music, kids. . No pets, No smoking, No drugs, Ideally looking to rent to one person, but may consider two . "Responsible, positive people, please apply. Ideal situation for, e.g., a responsible couple." . CHINESE ONLY AD . SPANISH ONLY AD . Good people follow good areas as you will be surrounded by respectful doctors who have hand-picked the neighborhood. . Looking for tenants that are respectful and responsible. No drug, no drama, No smoking in the house, and has no problem making rent on time each month. . Walking distance to prayer sanctuaries . I am looking to offer a house for a young lady that is looking to live here in Miscellaneous 31 exchange for light housekeeping. No experience required. This arrangement is ideal for a student or someone new to Los Angeles. . We Invite You to See Where the Hip Los Angeles Residents Call Home! . It's perfect for anyone who drives or those who prefer walking . looking for cool clean respectful person to be my roommate . I'm looking for someone/couple who is financially responsible, mature, clean, drug- free and respectful of other people's space and who will take good care of my home during their stay. Sources: www.craigslist.com, accessed February, 2012. Note: Some ads included discriminatory language in multiple categories. The number of ads in each discrimination category may not add up to total. *Examples are direct quotes from the listings (including punctuation and emphasis).

Source of Income: Under California’s fair housing law, source of income is a protected class. It is, therefore, considered unlawful to prefer, limit, or discriminate against a specific income source for a potential renter. It is also considered unlawful to publish or print advertisements to that effect. According to the California Newspaper Publishers Association, an ad referring to a government program in which an agency makes payments directly to landlords (e.g. the federal government’s Housing Choice Voucher program, formerly known as the Section 8 voucher program) would probably not be unlawful so long as the tenant’s benefit or “income” is not paid directly to the “tenant or tenant’s representative.” Therefore, ads specifically allowing or disallowing Housing Choice Vouchers are not considered unlawful; however, when the rental housing market becomes especially tight landlords may not have an incentive to attract tenants receiving Housing Choice Voucher assistance. In these instances, an ad specifically banning Housing Choice Vouchers may be considered an impediment to fair housing because it can

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 141 Public Review Draft May 30, 2012 make housing disproportionately unavailable to a protected class, especially person with disabilities. Of all the rental listings surveyed in February 2012, only 22 ads specifically made reference to Section 8 (i.e., Housing Choice Vouchers). Furthermore, a majority of these references specifically noted that landlords were willing to accept Section 8 or Housing Choice Voucher tenants.

During outreach meetings, allegations of discrimination against Housing Choice Voucher recipients were brought up. For example, a number of residents believed their Housing Choice Voucher status led their landlords to delay in making necessary repairs to their units. There have also been allegations of some landlords asking Housing Choice Voucher tenants for additional rent.

No Pet Policies: More common in Los Angeles rental advertisements were references to pets. Persons with disabilities are one of the protected classes under fair housing laws, and rental units must allow “service animals” and “companion animals,” under certain conditions. Service animals are animals that are individually trained to perform tasks for people with disabilities such as guiding people who are blind, alerting people who are deaf, pulling wheelchairs, alerting and protecting a person who is having a seizure, or performing other special tasks. Service animals are working animals, not pets. Companion animals, also referred to as assistive or therapeutic animals, can assist individuals with disabilities in their daily living and as with service animals, help disabled persons overcome the limitations of their disabilities and the barriers in their environment.

Persons with disabilities have the right to ask their housing provider to make a reasonable accommodation in a “no pets” policy in order to allow for the use of a companion or service animal. However, in the case of rental ads that specifically state “no pets,” some disabled persons may not be aware of their right to ask for an exception to this rule. Because of this, a person with a disability may see themselves as limited in their housing options and a “no pets” policy could, therefore, be interpreted as potentially discriminatory. Of the 1,000 rental listings surveyed in February 2012, 193 ads included language to specifically ban pets.

Furthermore, at outreach meetings, housing advocates recounted various allegations of landlords refusing to grant tenants reasonable accommodations requests. Specific requests include granting hoarders additional time to vacate a unit, allowing service animals, and allowing tenants to break a lease when a unit is not accessible. Some advocates have also alleged that even though a property advertises itself as accessible, often times, only public spaces are accessible, while the actual housing unit itself is not.

Race/Ethnicity: Another concern brought up repeatedly in outreach meetings by housing advocates is the notion that certain landlords often prefer tenants of one particular race/ethnicity. While the preference is less blatant now than it has been in the past, many insist the preference still exists.

In the survey of rental listings for the City of Los Angeles, two ads were found that were published entirely in a language other than English (one in Chinese and one in Spanish). While rare, the existence of non-English ads supports the claim that some landlords may prefer

City of Los Angeles Page 142 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 tenants of a particular race or ethnicity. Furthermore, under California fair housing laws, if a rental ad is published in only one language, the language must be English.

Gender Preference: Another concern housing advocates at outreach meetings noted was the prevalence of gender discrimination in the rental process. Allegations of sexual harassment and discrimination against transgender applicants were specifically noted by advocates. In reviewing rental ads for the City of Los Angeles, at least one ad contained a discriminatory preference for a tenant of a particular gender. While gender preferences are allowed under federal fair housing laws in roommate/shared housing situations where tenants will share a common space, a stated preference for a particular gender may still be an indicator of the existence of gender discrimination.

Household Types and Size: Other potentially discriminatory ads contain references to household type and size. Numerous ads were found that contained explicit preferences for families with children and couples. Several ads also contained limits to household size, indicating preferences for a single tenant or two tenants maximum. At outreach meetings, various housing advocates reported incidences of property managers steering families with children toward specific units and establishing special rules that apply only to children.

Viewing the Unit

Viewing the unit is the most obvious place where the potential renters may encounter discrimination because landlords or managers may discriminate based on race or disability, or judge on appearance whether a potential renter is reliable or may violate any of the rules.

Credit/Income Check

Landlords may ask potential renters to provide credit references, lists of previous addresses and landlords, and employment history/salary. The criteria for tenant selection, if any, are typically not known to those seeking to rent. Many landlords often use credit history as an excuse when trying to exclude certain groups. Legislation provides for applicants to receive a copy of the report used to evaluate applications.

While landlords may ask for the above information to establish a potential tenant’s ability to pay, a rental ad explicitly stating a preference for a currently employed tenant is a fair housing violation. If a potential tenant is able to prove he/she has the financial resources to afford a particular unit, a landlord cannot deny this person housing because of his/her employment status. During a survey of rental listings for the City of Los Angeles, several ads specifically required or stated a preference for a currently employed tenant, constituting a fair housing violation.

The Lease

Most apartments are rented under either a lease agreement or a month-to-month rental agreement. A lease is favorable from a tenant's point of view for two reasons: the tenant is assured the right to live there for a specific period of time and the tenant has an established rent during that period. Most other provisions of a lease protect the landlord. Information written in

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 143 Public Review Draft May 30, 2012 a lease or rental agreement includes the rental rate, required deposit, length of occupancy, apartment rules, and termination requirements.

Typically, the lease or rental agreement is a standard form completed for all units within the same building. However, the enforcement of the rules contained in the lease or agreement may not be standard for all tenants. A landlord may choose to strictly enforce the rules for certain tenants based on arbitrary factors, such as race, presence of children, or disability. In recent years, complaints regarding tenant harassment through strict enforcement of lease agreements as a means of evicting tenants have increased significantly.

Security Deposit

A security deposit is typically required. To deter “less-than-desirable” tenants, a landlord may ask for a security deposit higher than for others. Tenants may also face discriminatory treatment when vacating the units. The landlord may choose to return a smaller portion of the security deposit to some tenants, claiming excessive wear and tear. A landlord may also require that persons with disabilities pay an additional pet rent for their service animals, a monthly surcharge for pets, or a deposit, which is also a discriminatory act.

During the Tenancy

During tenancy, the most common forms of discrimination a tenant may face are based on familial status, race, national origin, sex, or disability. Usually this type of discrimination appears in the form of varying enforcement of rules, overly strict rules for children, excessive occupancy standards, refusal to make a reasonable accommodation for handicapped access, refusal to make necessary repairs, eviction notices, illegal entry, rent increases, or harassment. These actions may be used as a way to force undesirable tenants to move on their own without the landlord having to make an eviction.

Payment of Rent

Some property owners in the City have begun requiring a specific method of payment for rent. One property management group in particular has recently required all tenants at its various properties to pay their rent online. Under current housing laws, it is only illegal for landlords to require a specific form of payment for rent when the specified method is cash. However, landlords are able to require the payment of rent in cash temporarily if a particular tenant has a history with stopped or bounced checks.

Requiring online payments may disproportionately impact the elderly and minorities. In general, a higher proportion of minority and elderly households do not have bank accounts or access to the internet to make online payments.

While requiring online payments is not currently illegal, numerous housing advocates argue that the practice is unfair. Requiring online payments means tenants must have a bank account, access to the Internet, and the technological savvy to complete the online payment process. This may unintentionally place a disproportionate burden on the elderly and minorities, who are less likely to meet all of these requirements.

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In early 2012, California State Senator Ted Lieu of Torrance addressed this issue by introducing Senate Bill (SB) 1055, which would require landlord to continue to accept rent by check or money order. SB 1055 was referred to the Senate Judiciary Committee on March 1, 2012.

2. California Apartment Association (CAA)

The CAA is the country's largest statewide trade association for rental property owners and managers. The CAA was incorporated in 1941 to serve rental property owners and managers throughout California. CAA represents rental housing owners and professionals who manage more than 1.5 million rental units. Under the umbrella agency, various apartment associations cover specific geographic areas.

The California Apartment Association has developed the California Certified Residential Manager (CCRM) program to provide a comprehensive series of courses geared towards improving the approach, attitude and professional skills of on-site property managers and other interested individuals. The CCRM program consists of 31.5 hours of training that includes fair housing and ethics along with the following nine course topics:

. Preparing the Property for Market . Professional Leasing Skills and the Application Process . The Move-in Process, Rent Collection and Notices . Resident Issues and Ending the Tenancy . Professional Skills for Supervisors . Maintenance Management: Maintaining a Property . Liability and Risk Management: Protecting the Investment . Fair Housing: It’s the Law . Ethics in Property Management

In order to be certified one must successfully score 75 percent or higher on the comprehensive CCRM final exam.

The CAA supports the intent of all local, State, and federal fair housing laws for all residents without regard to color, race, religion, sex, marital status, mental or physical disability, age, familial status, sexual orientation, or national origin. Members of the CAA agree to abide by the provisions of their Code for Equal Housing Opportunity.

3. Apartment Association of Greater Los Angeles (AAGLA)

AAGLA serves the needs of rental house providers in the Los Angeles area. AAGLA provides members with free legal assistance, low-cost tenant screening, free forms, free listings of vacancies, low-cost workers compensation programs, vendor referrals, insurance coverage, and manager training and placement. AAGLA also offers fair housing seminars for its members at a reduced cost. As members of the CAA, AAGLA abides by the Code for Equal Housing Opportunity.

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4. The National Association of Residential Property Managers (NARPM)

NARPM promotes a high standard of property management business ethics, professionalism and fair housing practices within the residential property management field. NARPM is an association of real estate professionals who are experienced in managing single-family and small residential properties. Members of the association adhere to a strict Code of Ethics to meet the needs of the community, which include the following duties:

. Protect the public from fraud, misrepresentation, and unethical practices of property managers; . Adhere to the Federal Fair Housing Stature; . Protect the fiduciary relationship of the client; . Treat all tenants professionally and ethically; . Manage the property in accordance with the safety and habitability standards of the community; and . Hold all funds received in compliance with State law with full disclosure to the Client.

In addition to promoting the standards of business ethics, professionalism and fair housing practices, the Association also certifies its members in the standards and practices of the residential property management industry and promotes continuing professional education.

NARPM offers three designations to qualified property managers and property management firms:

. Residential Management Professional, RMP ® . Master Property Manager, MPM ® . Certified Residential Management Company, CRMC ®

Various educational courses are offered as part of attaining these designations including the following courses:

. Ethics (required for all members every four years) . Habitability Standards and Maintenance . Marketing . Tenancy . ADA Fair Housing . Lead-Based Paint Law

5. Western Manufactured Housing Communities Association (WMA)

WMA is a nonprofit organization created in 1945 for the exclusive purpose of promoting and protecting the interests of owners, operators and developers of manufactured home communities in California. WMA assists its members in the operations of successful manufactured home communities in today's complex business and regulatory environment. WMA has over 1,700 member parks located in all 58 counties of California.

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WMA offers an award-winning manager accreditation program as well as numerous continuing education opportunities. The Manufactured Home Community Manager (MCM) program is a manager accreditation program that provides information on effective community operations. WMA’s industry experts give managers intensive training on laws affecting the industry, maintenance standards, California Department of Housing and Community Development (HCD) inspections, discrimination, mediation, disaster planning, and a full range of other vital subjects. In addition, WMA offers the following services:

. Toll-free Hotline for Day-to-Day Management Advice . Resident Screening Program . Group Workers’ Compensation Program . Legal Advice . Industry Referrals . Manager Referral Service; and . Educational seminars on a variety of key topics.

C. Fair Housing Services

In general, fair housing services include the investigation and resolution of housing discrimination complaints, discrimination auditing and testing, and education and outreach, including the dissemination of fair housing information such as written material, workshops, and seminars. Landlord/tenant counseling is another fair housing service that involves informing landlords and tenants of their rights and responsibilities under fair housing law and other consumer protection legislations, as well as mediating disputes between tenants and landlords. This section reviews the fair housing services available in the City of Los Angeles, the nature and extent of fair housing complaints, and results of fair housing testing/audits.

1. Housing Rights Center (HRC)

The Housing Rights Center (HRC) is under contract with the LAHD to provide fair housing services in the City. HRC in turn subcontracts with Fair Housing Foundation and Fair Housing Council of San Fernando Valley to ensure full coverage of the City. Figure 15 illustrates the geographic coverage of each service provider.

HRC is a non profit agency whose mission is to actively support and promote fair housing through education and advocacy. HRC provides the following fair housing related services to all Los Angeles residents:

. Counseling on fair housing rights and responsibilities through their toll-free fair housing hotline: 1-800-477-5977.

. Investigates allegations of housing discrimination under the fair housing laws. The Investigations Department conducts fact finding investigations and proposes potential solutions for victims of housing discrimination. Case resolution can include mediation, conciliation, a referral to State and federal administrative agencies, or referral to HRC’s Litigation Department.

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. Provides telephone and in-person counseling to both tenants and landlords regarding their respective rights and responsibilities under California law and local city ordinances.

. Hosts an Annual Housing Rights Summit, which brings interested parties together to discuss fair housing and raises public awareness of fair housing issues and services.

. Offers a monthly Fair Housing Certification Training for housing industry professionals who are interested in learning about the federal and State fair housing laws. HRC presently offers trainings in English and Spanish.

. Develops and distributes educational literature and resources that describe ways to prevent housing injustices and the applicable laws that protect against discrimination. The materials are made available free to the public in several different languages including English, Spanish, Korean, Mandarin, Armenian, Cantonese and Russian

. Presents free fair housing law workshops for landlords, tenants, nonprofit organizations and city employees. Depending on the audience, the presentations can be translated by staff into Armenian, Mandarin, Spanish, or Russian.

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Figure 15: Fair Housing Service Providers and Areas of Coverage

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Education and Outreach Efforts

Education is one of the most important components of providing fair housing services. It is also believed to be one of the most important tools in ensuring that fair housing opportunities are provided, by giving citizens the knowledge to understand their rights and responsibilities, to recognize discrimination, locate resources if they need to file a complaint or need general assistance, and much more.

During the 2012 AI consultation meetings, participants commented on the need for fair housing training targeted toward specific populations: private developers and architectural firms; small rental property owners; property managers; and police officers.

The HRC continues to present fair housing law workshops and programs to a variety of audiences such as residential property personnel (e.g., landlords, property managers, and real estate agents), tenants, prospective homebuyers, code enforcement personnel, police officers, City employees, and other non-profit organizations. Depending upon the audience, the written materials and presentations are translated by staff into Armenian, Korean, Mandarin, Spanish, or Russian. For example, the Fair Housing Certification Training for housing industry professionals is available in English, Spanish and Korean.

HRC continues operation of the “Don’t Borrow Trouble” Hotline, which provides residents with resources to combat predatory lending practices, including legal remedies. It also subcontracts with two community-based fair housing agencies (Fair Housing Foundation and Fair Housing Council of San Fernando Valley) to ensure services in each City of Los Angeles neighborhood.

LAHD and the HRC continue to participate in the ongoing Southern California Fair Housing Advertising Task Force, convened by the Los Angeles Times. Both LAHD and HRC play important roles in this collaboration. In conjunction with the Fair Housing Advertising Task Force, an educational video was produced about discrimination against persons with disabilities. HRC sponsors the Housing Rights Summit, a day-long conference held annually since 2000 which brings interested parties together and raises public awareness of fair housing issues and services. The event attracts civil rights advocates, social service providers, housing industry and community members, and government entities to address fair housing and other related issues, such as housing accessibility for persons with disabilities and how housing conditions affects resident health.

In addition, in response to advocate concerns about reasonable accommodation of service and companion animals in local homeless shelters, the City and County of Los Angeles, and the Los Angeles Homeless Services Authority (LAHSA) have worked with HRC to develop training workshops for homeless service providers on this and other fair housing topics. However, additional outreach and education is needed, including to the following groups:

. Private developers and architectural firms that do not have experience working with public funds: Private developers and architectural firms that receive public funds to develop affordable housing are not always familiar with Federal and state construction,

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affordability, and fair housing requirements, particularly those related to accessibility requirements. These firms should receive training when they are awarded public funds.

. Small rental property owners: The owners of smaller rental properties tend to be less educated about fair housing requirements than larger corporate property owners. For some of the smaller rental properties, the first time they are made aware of fair housing requirements is when they are accused of violating a law by a tenant.

. Property Managers: The high turnover rate among property managers due to the difficulty of the job and the low pay means that new property managers need to be trained on fair housing requirements.

. Police Officers: Police offers are often called to the scene of landlord-tenant or tenant- tenant disputes. The officers would benefit from fair housing training. In the past, fair housing organizations have distributed fair housing guides to officers during roll call. This outreach has ended due to a lack of funding.

2. California Department of Fair Employment and Housing (DFEH)

DFEH takes in, investigates, conciliates, mediates and prosecutes violations under the Fair Employment and Housing Act (FEHA), Disabled Persons Act, Unruh Civil Rights Act and Ralph Civil Rights Act. The DFEH investigates complaints of employment and housing discrimination based on race, sex, religious creed, color, national origin, medical condition (cured cancer only), ancestry, physical or mental disability, marital status, or age (over 40 only). The Department also investigates complaints of housing discrimination based on the above classes, as well as children/age, and sexual orientation.

DFEH established a program in May 2003 for mediating housing discrimination complaints, which is a first for the State of California, and is the largest fair housing mediation program in the nation to be developed under HUD’s Partnership Initiative with State fair housing enforcement agencies. The program provides California’s tenants, landlords, and property owners and managers with a means of resolving housing discrimination cases in a fair, confidential, and cost-effective manner.36 Key features of the program are: 1) it is free of charge to the parties; and 2) mediation takes place within the first 30 days of the filing of the complaint, often avoiding the financial and emotional costs associated with a full DFEH investigation and potential litigation.

The City’s fair housing service providers (HRC and its subcontractors) work in partnership with HUD and DFEH. After a person calls in for a complaint, an interview takes place, documentation is obtained and issues are discussed to decide on the course to proceed. Mediation/conciliation is offered as a viable alternative to litigation. If the mediation/conciliation is successful, the case is closed after a brief case follow-up. If the mediation/conciliation is unsuccessful, the case is then referred to DFEH or HUD. If during case development further investigation is deemed necessary, testing may be performed. Once the investigation is completed, the complainant is advised of the alternatives available in

36 DFEH News Brief, May 29, 2003.

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D. Fair Housing Statistics

As part of the enforcement and tracking services provided by the above mentioned fair housing service providers, intake and documentation of all complaints and inquiries result in the compilation of statistics provided to each jurisdiction in the form of quarterly and annual reports.

1. Housing Rights Center (HRC)

Clients Served

Between Fiscal Year (FY) 2004-05 and FY 2010-11, HRC provided fair housing services to a total of 65,254 Los Angeles clients. The largest proportion of clients were from the Hollywood area (43 percent), followed by residents from South Los Angeles (26 percent). The number of Los Angeles clients served has declined gradually over time, from a high in FY 2006-07 of 10,575 clients to just 8,685 clients in FY 2010-11. This decline could be an indication of an improved fair housing environment.

Table 43: Clients Served (2004-2011) 2004-05 2005-06 2006-07 2007-08 2008-09 2009-10 2010-11 Total Hollywood 4,300 4,803 4,574 2,505 4,496 4,158 3,516 28,352 West Los Angeles 1,384 1,584 1,653 822 1,287 1,234 1,057 9,021 San Fernando Valley 1,833 1,483 1,879 855 1,517 1,888 1,474 10,929 South Los Angeles 2,430 2,576 2,469 1,292 2,521 3,026 2,638 16,952 Total 9,947 10,446 10,575 5,474 9,821 10,306 8,685 65,254 Source: HRC Annual Reports, 2004-2011.

Clients Served by Race and Ethnicity Between FY 2004-05 and 2010-11, Whites represented 36 percent of clients, followed by Other (29 percent) and Blacks (22 percent). The “Other” category most likely includes those who are of Hispanic origin. Often Hispanic persons identify with their ethnicity (e.g., Mexican, Puerto Rican) but generally do not identify with their race. The demographic profile of HRC’s clients revealed one major disparity. In 2010, Blacks made up only 10 percent of the City’s population (Table 2), yet they accounted for 22 percent of HRC clients. This may indicate that Blacks in the City are more likely than persons of all other races/ethnicities to experience housing discrimination.

Approximately 62 percent of HRC clients identified themselves as non-Hispanic. While Hispanics made up nearly one-half of the City’s population (49 percent), they made up only 38 percent of HRC’s clients. The San Fernando Valley service area had the greatest proportion of

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Hispanic clients (52 percent), while the West Los Angeles service area had the smallest proportion (15 percent).

Black persons represent a significant portion of the clients served by HRC, indicating Black persons may be disproportionately impacted by fair housing issues.

Table 44: Clients Served by Race (2004-2011) West San Fernando South Hollywood Total Los Angeles Valley Los Angeles # % # % # % # % # % White 9,362 33.0% 5,052 56.0% 4,165 38.1% 4,608 27.2% 23,187 35.5% Black 3,434 12.1% 978 10.8% 1,054 9.6% 8,760 51.7% 14,226 21.8% American Indian/ Alaskan Native and 4,314 15.2% 508 5.6% 4 0.0% 15 0.1% 4,841 7.4% White Other 8,245 29.1% 1,883 20.9% 5,439 49.8% 3,353 19.8% 18,920 29.0% American Indian/Alaskan Native 276 1.0% 44 0.5% 0 0.0% 8 0.0% 328 0.5% and Black Asian 1,767 6.2% 398 4.4% 101 0.9% 118 0.7% 2,384 3.7% American 641 2.3% 86 1.0% 9 0.1% 36 0.2% 772 1.2% Indian/Alaskan Native Pacific Islander 168 0.6% 20 0.2% 15 0.1% 15 0.1% 218 0.3% Black and White 106 0.4% 39 0.4% 121 1.1% 31 0.2% 297 0.5% Asian and White 39 0.1% 13 0.1% 21 0.2% 8 0.0% 81 0.1% Total 28,352 100.0% 9,021 100.0% 10,929 100.0% 16,952 100.0% 65,254 100.0% Source: HRC Annual Reports, 2004-2011.

Table 45: Clients Served by Ethnicity (2006-2011) West San Fernando South Hollywood Total Los Angeles Valley Los Angeles # % # % # % # % # % Hispanic 10,841 38.2% 1,330 14.7% 5,726 52.4% 6,961 41.1% 24,858 38.1% Non Hispanic 17,511 61.8% 7,691 85.3% 5,203 47.6% 9,991 58.9% 40,396 61.9% Total 28,352 100.0% 9,021 100.0% 10,929 100.0% 16,952 100.0% 65,254 100.0% Source: HRC Annual Reports, 2004-2011.

Clients Served by Income As with most other jurisdictions, statistics reported for the City of Los Angeles indicate that lower income persons, regardless of race, are the most heavily impacted by fair housing issues. Between FY 2004-05 and FY 2010-11, 87 percent of those served by the HRC were lower income, with most clients falling in the low income category (46 percent). The income profile of HRC clients varied slightly by service area, with South Los Angeles having the greatest proportion of lower income clients (96 percent). By contrast, about 74 percent of clients from West Los Angeles were lower income.

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Table 46: Clients Served by Ethnicity (2004-2011) West San Fernando South Hollywood Total Los Angeles Valley Los Angeles # % # % # % # % # % Extremely Low 16,862 59.5% 4,299 47.7% 2,934 26.8% 2,492 14.7% 26,587 40.7% (30% MFI) Low 7,239 25.5% 2,328 25.8% 6,846 62.6% 13,812 81.5% 30,225 46.3% (50% MFI) Moderate 3,013 10.6% 1,615 17.9% 1,093 10.0% 545 3.2% 6,266 9.6% (80% MFI) Above Moderate 1,238 4.4% 779 8.6% 55 0.5% 104 0.6% 2,176 3.3% (80+% MFI) Total 28,352 100.0% 9,021 100.0% 10,928 100.0% 16,953 100.0% 65,254 100.0% Source: HRC Annual Reports, 2004-2011.

Clients Served by Other Characteristics Approximately 11 percent of all inquiries/complaints between FY 2004-05 and FY 2010-11 came from persons with disabilities, 12 percent from female-headed households, six percent from seniors, and 40 percent from households who received government subsidies for housing. There was some geographic variation in the distribution of special needs clients. The greatest proportion of clients living in rent stabilized housing was from the Hollywood service area (51 percent), followed by West Los Angeles (48 percent). While South Los Angeles (17 percent) and the San Fernando Valley (16 percent) service areas had the highest percentage of female headed household clients. The proportion of senior clients and disabled clients was consistent throughout all of the service areas.

Table 47: Clients Served by Other Characteristics (2004-2011) West San Fernando South Hollywood Total Los Angeles Valley Los Angeles

# % # % # % # % # % Female 2,406 8.5% 814 9.0% 1,722 15.8% 2,850 16.8% 7,792 11.9% Headed Senior 1,923 6.8% 566 6.3% 600 5.5% 809 4.8% 3,898 6.0% Disabled 3,665 12.9% 993 11.0% 989 9.0% 1,792 10.6% 7,439 11.4% Rent 14,333 50.6% 4,293 47.6% 3,284 30.0% 4,125 24.3% 26,035 39.9% Stabilized Source: HRC Annual Reports, 2004-2011.

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Housing Discrimination Complaints

Between FY 2004-05 and FY 2010-11, 6,796 complaints of housing discrimination were reported to HRC in the City of Los Angeles.

Bases for Complaints As shown in Table 48, most allegations were related to physical disability (28 percent), but a significant number of complaints involved familial status (18 percent) and race (15 percent). It should be noted that certain complaints were more prevalent in some parts of the City. According to the fair housing survey conducted as part of this AI, race, source of income, and age were identified by respondents as the leading bases for discrimination.

Complaints of racial discrimination were much more common in South Los Angeles (23 percent) than in all other service areas (about 12 to 13 percent, depending on the service area). Discrimination based on familial status, however, was much more common in the San Fernando Valley (29 percent) than in all other service areas (13 to 15 percent, depending on the service area).

Table 48: Discrimination Complaints (2004-2011) West San Fernando South Hollywood Total Los Angeles Valley Los Angeles # % # % # % # % # % Age 60 1.8% 36 3.6% 31 1.3% 54 3.8% 181 2.2% Familial Status 452 13.7% 129 12.8% 695 29.4% 209 14.8% 1,485 18.4% Gender 155 4.7% 36 3.6% 86 3.6% 123 8.7% 400 4.9% Marital Status 47 1.4% 16 1.6% 18 0.8% 21 1.5% 102 1.3% Mental Disability 333 10.1% 131 13.0% 113 4.8% 108 7.6% 685 8.5% National Origin 287 8.7% 44 4.4% 274 11.6% 58 4.1% 663 8.2% Physical Disability 1,074 32.5% 349 34.8% 481 20.3% 362 25.6% 2,266 28.0% Race 415 12.6% 115 11.5% 314 13.3% 327 23.1% 1,171 14.5% Religion 45 1.4% 19 1.9% 19 0.8% 22 1.6% 105 1.3% Sexual Orientation 123 3.7% 8 0.8% 32 1.4% 31 2.2% 194 2.4% Source of Income 35 1.1% 11 1.1% 60 2.5% 46 3.3% 152 1.9% Student Status 4 0.1% 6 0.6% 11 0.5% 1 0.1% 22 0.3% Arbitrary 41 1.2% 7 0.7% 80 3.4% 52 3.7% 180 2.2% General 233 7.1% 97 9.7% 150 6.3% 0 0.0% 480 5.9% Information Total 3,304 100.0% 1,004 100.0% 2,364 100.0% 1,414 100.0% 8,086 100.0% Source: HRC Annual Reports, 2004-2011.

Discrimination Cases It is important to note that not all allegations of discrimination evolve into actual fair housing cases. Of the 8,086 complaints of discrimination received between 2004 and 2011, 3,491 (43 percent) were deemed significant enough to turn into fair housing cases (Table 49). The San Fernando Valley (54 percent) and South Los Angeles (51 percent) had a higher proportion of discrimination complaints that turned into actual fair housing cases than the other two HRC

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service areas. Of the reported fair housing cases, the most common causes of alleged discrimination concerned familial status (28 percent), followed by physical disability (25 percent), and race (15 percent). Table 50 provides a summary of selected fair housing cases between 2004 and 2012.

Table 49: Discrimination Cases (2004-2011) West San Fernando South Hollywood Total Los Angeles Valley Los Angeles # % # % # % # % # % Age 21 1.8% 12 3.4% 13 1.0% 20 2.8% 66 1.9% Familial Status 217 19.1% 84 23.6% 536 41.9% 125 17.4% 962 27.6% Gender 40 3.5% 7 2.0% 39 3.1% 64 8.9% 150 4.3% Marital Status 15 1.3% 7 2.0% 11 0.9% 16 2.2% 49 1.4% Mental Disability 144 12.7% 68 19.1% 54 4.2% 52 7.2% 318 9.1% National Origin 104 9.1% 16 4.5% 170 13.3% 36 5.0% 326 9.3% Physical Disability 375 33.0% 105 29.5% 249 19.5% 152 21.1% 881 25.2% Race 148 13.0% 43 12.1% 151 11.8% 189 26.3% 531 15.2% Religion 10 0.9% 8 2.2% 8 0.6% 12 1.7% 38 1.1% Sexual Orientation 41 3.6% 4 1.1% 12 0.9% 21 2.9% 78 2.2% Source of Income 9 0.8% 0 0.0% 16 1.3% 22 3.1% 47 1.3% Student Status 1 0.1% 1 0.3% 5 0.4% 0 0.0% 7 0.2% Arbitrary 13 1.1% 1 0.3% 14 1.1% 10 1.4% 38 1.1% Total 1,138 100.0% 356 100.0% 1,278 100.0% 719 100.0% 3,491 100.0% Source: HRC Annual Reports, 2004-2011.

Table 50: Selected Case Summaries Case Summary Factors of Allegation, Finding, and Disposition Complainant: Married, Latino, female, Facts: The complainant, her husband, and two of her children have lived at the in-place tenant complaint address since January 1994. A company owns the 36-unit complex and a Latino man has supervised the complex since June 1, 2004. On July 1, 1999, the Allegation: Familial status Complainant and her family were transferred to a two-bedroom unit. The discrimination complainant’s three-year-old son was born in October 22, 2000. On June 1, 2004, the Complainant received a notice from the owners stating that they are the new Housing Practice: Restrictive rules and owners of the building. The Complainant also received a questionnaire asking her, harassment among other questions, how many people were currently living in her unit. The Complainant filled out the questionnaire stating that she, her husband, her eleven- year-old son, her ten-year-old daughter, and three year old son were currently living in her unit. On June 15, 2004, the owners served the Complainant with a 3-Day Notice to Perform or Quit stating, “You have one extra person living at your unit, this is not allowed you have three days to perform and let us know so we do not proceed legally, otherwise we will take action on this notice per your questionnaire send to us.” The complainant believes that the owners and the manager are discriminating against her based on her familial status.

Finding: Sustains allegation

Disposition: Successful conciliation

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Table 50: Selected Case Summaries Case Summary Factors of Allegation, Finding, and Disposition Complainant: Latino, single, female; Facts: The Complainant is a single Latino woman. The Complainant was temporarily prospective tenant disabled due to shoulder problems. The Complainant’s boyfriend is disabled and is currently under medical treatment. The Complainant was looking for a new Allegation: Mental disability apartment for her, her boyfriend, and her son. On June 30, 2005, the Complainant discrimination saw a for rent sign at the complaint address. That same day, the Complainant called the number and a Latino woman told her to go to the office for an application. On Housing Practice: Refusal to rent June 30, 2005, the Complainant went to the office and told the Latino woman that she and her boyfriend have two small dogs and she showed her a letter from her boyfriend’s physician stating he needs the dogs. The woman told the Complainant that she thought there would be no problem and provided her with an application. The woman also asked the Complainant to provide her with a photograph of the dogs. On July 4, 2005, the Complainant went to the office and turned in the completed application. The woman told the Complainant that she would call her in a couple of days. On July 5, 2005, the Complainant telephoned the woman and was informed that she could not have the apartment because she had dogs. The woman told the Complainant that she could not do anything about it because the owner would not allow the dogs. The Complainant asked the woman if she told the owner about the letter from her boyfriend’s physician indicating that he needs the dogs. The woman told the Complainant that she informed the owner, but the owner did not want to rent to her because of the dogs. The Complainant believes that the management company and the owner are discriminating against her and her boyfriend based on her boyfriend’s disability.

Finding: Sustains allegation

Disposition: Referred to DFEH (who successfully conciliated and closed the case on November 20, 2006. Complainant: African American, single, Facts: The complainant is a single, African American male. On or about July 8, male; prospective tenant 2006, the Complainant inquired about a studio rental unit that he found listed on a rental housing website. The complaint property was not disclosed in the listing, but it Allegation: Gender discrimination indicated that the property’s cross streets were located within the city of Los Angeles. The listing stated that the rental unit was a guest house in the back of the Housing Practice: Refusal to rent main home; the ad also listed a contact person. The Complainant first called to inquire about the unit on or about July 8, 2006. A man answered the telephone and informed the Complainant that the unit had been rented. The Complainant discovered the same listing posted on the rental housing website on or about July 12, 2006, so he again called the provided number to inquire about the unit. The Complainant reports that, again, a man answered, and informed the Complainant that the unit had been rented. Finally on or about July 15, 2006, the Complainant reported finding the same listing on the same rental housing website but with a new publishing date. The Complainant noticed that the statement “Women preferably” had been added to the listing. The Complainant called the provided number again, and a man answered and told the Complainant that the unit had been rented. The Complainant then asked why the same listing has continued to be posted if it had been rented, and the man then said it was because something was wrong with the woman that had first applied for the unit. The Complainant told the man that he noticed that the statement “Women preferably” was added and wanted to know why. The man hung-up the telephone.

Finding: Sustains allegation

Disposition: Referred to DFEH (who reached a conciliation agreement and closed the case on February 26, 2007.

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Table 50: Selected Case Summaries Case Summary Factors of Allegation, Finding, and Disposition Complainant: Latino, single, female; in- Facts: The Complainant is a single, Latino woman. The Complainant has lived at place tenant the complaint address since 1996. A Caucasian man has owned the building since 2005 and an African American man and an African American woman have managed Allegation: Familial status the property since March 2007. The Complainant states that the managers are not discrimination allowing children to be outdoors. The Complainant states that the managers told her that children cannot play outside their units. The Complainant states that on May 3, Housing Practice: Restrictive rules & 2007, she was served with a 30-day notice to perform covenant or quit asking her to harassment stop her children from running and playing in the common areas of the building. The Complainant states that on May 4, 2007, she was served with a three-day notice to perform covenant or quit stating that her children were hanging through windows with their feet and legs outside. The Complainant denies the accusations. The Complainant believes that the owner and the managers are discriminating against her based on her familial status.

Finding: Sustains allegation

Disposition: Successful conciliation Complainant: Caucasian, married, Facts: The complainant is a married, Caucasian, male with disabilities. The male; in-place tenant with disabilities Complainant lives in a two-bedroom unit with his wife who also has physical disabilities. The Complainant has lived at the complaint address since June 2006. Allegation: Physical disability The Complainant’s rent is due on the first of each month via mail to the management discrimination company. The Complainant’s source of income is from Social Security and disability checks. The Complainant receives electronic direct deposit of these checks into his Housing Practice: Reasonable bank account. The Complainant states that these checks are not deposited into his accommodation account until the second or third of each month. The Complainant is requesting a reasonable accommodation, to be able to pay his rent by the fifth of each month, based on his disabilities.

Finding: Sustains allegation

Disposition: Successful conciliation Complainant: Single, African-American, Facts: The Complainant is a single African American female. The Complainant lives female; in place tenant with her 16-year-old son at the complaint address. The Complainant has been living at the complaint address since February of 2009. The Complainant is a Housing Allegation: Familial status Choice Voucher recipient. In May of 2009, the Complainant’s son moved in. The discrimination Complainant stated she asked for permission from the owner to allow her son to move in but did not receive a clear response to her request. On June 17, 2009, the Housing Practice: Refusal to rent Complainant was served with a three-day notice to perform or quit asking her to remove the additional occupant from the unit (the Complainant’s son). The Complainant believes the owner is discriminating against her due to her familial status.

Finding: Sustains allegation

Disposition: Successful conciliation

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Table 50: Selected Case Summaries Case Summary Factors of Allegation, Finding, and Disposition Complainant: Single, Latino, female w/ Facts: The Complainant is a single Latino female. The Complainant has resided at disability; in-place tenant the property since May 2007. The Complainant is a person with a mental disability. The Complainant states that on February 11, 2010 she was served with a notice to Allegation: Mental disability discuss her rental assistance. The Complainant states that the manager wanted the discrimination Complainant’s mother to sign a document stating that she makes $40,000 a year. The Complainant states that her mother does not make that much money. The Housing Practice: Eviction Complainant states that on March 3, 2010 she took the notice, placed animal feces on the notice and stuck the notice on the manager’s door. The Complainant states that the manager falsely accused the Complainant of calling him and stating that the feces on the notice was her feces and she did not take her HIV medication. The Complainant states that on March 6, 2010 she was served with a 30-day notice to vacate. The Complainant states that since that incident she has regularly taken her medication for her mental disability. The Complainant states that her parents are monitoring her medication and, since she began taking her medication again, she has not had any problems at the property. The Complainant is requesting a reasonable accommodation (to have her notice to vacate rescinded) based on her disability.

Finding: Sustains allegation

Disposition: Successful conciliation Complainant: Single, African-American, Facts: The Complainant is a single, African-American female. The Complainant, her female w/ disability; in-place tenant oldest son and her youngest son have resided at the complaint address since 2001. The Complainant states that she has a disability due to bi-polar disorder with Allegation: Mental disability psychotic episodes and her youngest son has a disability due to autism and mild discrimination retardation. The Complainant states that in September 2010, there was a domestic dispute between her cousin and her cousin’s boyfriend. The Complainant states that Housing Practice: Reasonable on September 17, 2011, her oldest son allegedly went to her cousin’s house and accommodation request shot into the home. The Complainant states that her oldest son was arrested at the property and charged with shooting into a habitable property. The Complainant states that she immediately notified her Housing Choice Voucher counselor and informed her of the incident. The Complainant states that she informed her Housing Choice Voucher counselor that her oldest son would no longer be residing in her household. The Complainant states that she spoke with the Housing Authority’s assistant manager regarding the status of her Housing Choice Voucher. The Complainant states that the assistant manager informed her that she would have to submit documentation related to her and her youngest son’s disabilities. The Complainant states that she submitted all of the documentation to the assistant manager. The Complainant states that on July 23, 2011, she received a letter from the assistant manager informing her that she would be entitled to a hearing. The Complainant states that her hearing would be set in the next two weeks. The Complainant states that having to contemplate losing her Housing Choice Voucher is affecting her medical condition. The Complainant is requesting a reasonable accommodation (to be allowed to keep her Housing Choice Voucher) based on her and her youngest son’s disabilities.

Finding: Sustains allegation

Disposition: Successful conciliation

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Table 50: Selected Case Summaries Case Summary Factors of Allegation, Finding, and Disposition Complainant: Divorced, Latino, female; Facts: The Complainant is a divorced, Latino female. The Complainant, her 15-year in-place tenant old son and her 10-year old son have lived at the complaint address since December 2010. The Complainant states that since she moved into the property, her children Allegation: Familial status have been allowed to play outside with the other residents’ children. The discrimination Complainant states that there was a personal issue between her and the male resident (unit# 1) because he accused her children of creating a nuisance at the Housing Practice: Restrictive rules property. The Complainant states that in December 2011, the male resident informed her children that they would no longer be allowed to play in the common areas. The Complainant states that on January 20, 2012, there was an incident between the male resident, her children and another female resident’s children (unit #3). The Complainant states that the male resident was yelling at the children and accusing them of disrupting his family life. The Complainant states that the male resident informed the children that they would need to go back into their units. The Complainant states that she contacted the owner and informed him of the incident. The Complainant states that the owner told her that her children were never allowed to play outside. The Complainant states that the owner told her that he has witnessed her children playing outside but never mentioned anything to her. The Complainant states that the owner told her that allowing her children to play outside would create a liability. The Complainant states that the owner told her that he is afraid that he will be sued if her children are injured at the property. The Complainant states that the owner told her that since she is residing on the second floor, she has no right to the amenities located on the first floor including the common areas. The Complainant believes that the owner is discriminating against her based on her familial status.

Finding: Sustains allegation

Disposition: Successful conciliation Source: Housing Rights Center, 2011.

Disposition of Fair Housing Cases Of the fair housing cases opened, only about one-half (43 percent) had enough evidence to sustain the allegation of discrimination (Table 51). The South Los Angeles service area, however, had a higher proportion of cases where no evidence of discrimination was found (25 percent), compared to the three other services areas (less than one to five percent, depending on the service area).

About one-quarter (24 percent) of cases ended with the determination that no possible action could be taken and 18 percent resulted in successful conciliation. The rate of successful conciliation, though, varied dramatically by service area. About 30 percent of fair housing cases in the Hollywood service area and 28 percent of cases in the West Los Angeles service area ended in successful conciliation, but only nine percent of cases in the San Fernando Valley and 11 percent of cases in South Los Angeles ended in successful conciliation. South Los Angeles also had a disproportionately high number of fair housing cases where no action was deemed possible (44 percent), compared to other service areas (10 to 31 percent, depending on the service area).

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South Los Angeles had the highest proportion of fair housing complaints that could be supported by no evidence. Further, among those confirmed fair housing cases, South Los Angeles had the lowest success rate in conciliation. This may be an indication that additional education on fair housing rights and responsibilities and how to document discrimination is needed, particularly in the South Los Angeles area.

Table 51: Findings and Dispositions (2004-2011) West San Fernando South Hollywood Total Los Angeles Valley Los Angeles # % # % # % # % # % Allegations 3,304 40.9% 1004 12.4% 2,364 29.2% 1,414 17.5% 8,086 100.00% Cases 1,138 32.6% 356 10.2% 1,278 36.6% 719 20.6% 3,491 100.00% Findings Sustains Allegation 591 51.9% 181 50.8% 654 51.2% 301 41.9% 1,727 49.5% Inconclusive Evidence 324 28.5% 107 30.1% 223 17.4% 157 21.8% 811 23.2% No Evidence of 3 0.3% 2 0.6% 71 5.6% 176 24.5% 252 7.2% Discrimination Pending 220 19.3% 66 18.5% 330 25.8% 85 11.8% 701 20.1% Total 1,138 100.0% 356 100.0% 1,278 100.0% 719 100.0% 3,491 100.0% Dispositions Successful Conciliation 345 30.3% 98 27.5% 118 9.2% 82 11.4% 643 18.4% Client Withdrew 119 10.5% 28 7.9% 92 7.2% 55 7.6% 294 8.4% No Action Possible 306 26.9% 109 30.6% 121 9.5% 313 43.5% 849 24.3% Referred to Attorney 24 2.1% 16 4.5% 348 27.2% 51 7.1% 439 12.6% Referred to DFEH/HUD 31 2.7% 12 3.4% 112 8.8% 34 4.7% 189 5.4% Pending 313 27.5% 93 26.1% 487 38.1% 184 25.6% 1077 30.9% Total 1,138 100.0% 356 100.0% 1,278 100.0% 719 100.0% 3,491 100.0% Source: HRC Annual Reports, 2004-2011.

Tenant Landlord Counseling

A number of Los Angeles residents contacted the HRC for assistance with landlord/tenant issues and complaints. Concerns regarding tenant/landlord issues ranged from eviction to substandard conditions and questions on how to get repairs made. From 2004 to 2011, the most common issue the HRC encountered was clients seeking assistance with notices and eviction (25 percent). Questions concerning general information, lease terms, and rent increases were also very common (Table 52).

Certain concerns were more prevalent in various parts of the City. For example, a higher proportion of residents in the South Los Angeles service area (31 percent) sought assistance with notices and evictions compared to other services areas (20 to 24 percent, depending on the service area). South Los Angeles also had the highest percentage of inquiries about substandard conditions (13 percent) and harassment (10 percent).

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Table 52: Summary of Housing Issues (2004-2011) West San Fernando South Hollywood Total Los Angeles Valley Los Angeles # % # % # % # % # % Seeking Housing 1,031 4.2% 135 1.7% 0 0.0% 0 0.0% 1,166 2.1% Notices and Eviction 6,058 24.4% 1,687 21.3% 1,670 19.8% 4,820 31.1% 14,235 25.1% Harassment 1,901 7.7% 504 6.4% 273 3.2% 1,540 10.0% 4,218 7.4% Lease Terms 2,553 10.3% 976 12.3% 796 9.4% 1,149 7.4% 5,474 9.7% Rent Increase 2,015 8.1% 716 9.0% 628 7.4% 1,093 7.1% 4,452 7.9% Security Deposit 1,614 6.5% 742 9.3% 439 5.2% 792 5.1% 3,587 6.3% Substandard Conditions 2,565 10.3% 766 9.7% 713 8.5% 1,938 12.5% 5,982 10.6% General Information 3,397 13.7% 1,203 15.2% 1,172 13.9% 995 6.4% 6,767 11.9% Illegal Entry 328 1.3% 105 1.3% 111 1.3% 209 1.4% 753 1.3% Repairs 1,690 6.8% 645 8.1% 838 9.9% 0 0.0% 3,173 5.6% Other Issue 1,675 6.7% 458 5.8% 1,790 21.2% 2,939 19.0% 6,862 12.1% Total 24,827 100.0% 7,937 100.0% 8,430 100.0% 15,475 100.0% 56,669 100.0% Source: HRC Annual Reports, 2004-2011.

2. California Department of Fair Housing and Employment (DFEH)

The mission of the DFEH is to protect Californians from employment, housing and public accommodation discrimination, and hate violence. To achieve this mission, DFEH keeps track of and investigates complaints of housing discrimination, as well as complaints in the areas of employment, housing, public accommodations and hate violence. Since 2005, a total of 2,134 fair housing complaints in the City of Los Angeles have been filed with DFEH. Most of these complaints involved physical disability (460 instances), followed by race (380 instances) and familial/marital status (367 instances) (Table 53).

More than one-half of the City’s 1,510 fair housing cases (917 cases) were found to have no probable cause and subsequently closed. An additional 257 cases were closed after successful conciliation (Table 54).

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Table 53: Basis for Discrimination of Complaints filed with DFEH (2005-2011) Basis of Complaints # of Complaints Race 380 Age 9 Association 20 Source of Income 34 National Origin 204 Sex 259 Physical Disability 460 Mental Disability 185 Familial/Marital Status 367 Religion 57 Other 16 Retaliation 143 Total 2,134 Source: CA Department of Fair Employment & Housing, 2012.

Table 54: Closing Categories for Fair Housing Complaints Filed with DFEH (2005-2011) Closing Category # of Cases Complainant Not Available 53 No Jurisdiction 18 Complainant Failed to Cooperate 12 Respondent Unavailable 4 Determination of Another Agency Recognized 3 Accusation Withdrawn 12 Accusation Not Issued 4 Public Hearing Held; No Appeal Filed 5 Transferred to Court 27 No Probable Cause 917 Processing Waived to Another Agency 8 Successful Mediation 70 Successful Conciliation 257 Withdrawal with Resolution 65 Withdrawal without Resolution 55 Total 1,510 Source: CA Department of Fair Employment & Housing, 2011.

Investigations begin with the intake of a complaint. Complainants are first interviewed to collect facts about possible discrimination. Interviews are normally conducted by telephone. If the complaint is accepted for investigation, the DFEH drafts a formal complaint that is signed by the complainant and served. If jurisdictional under federal law, the complaint is also filed

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 163 Public Review Draft May 30, 2012 with the HUD. As a substantially equivalent agency, DFEH's findings are usually accepted by HUD. The recipient of the complaint (usually a landlord, seller, property manager, seller, or agent) is required to answer and has the opportunity to negotiate resolution with the complainant. If the case is not resolved voluntarily, the DFEH conducts a formal investigation.

If the investigative findings do not show a violation of the law, DFEH will close the case. If investigative findings show a violation of law, the DFEH schedules a formal conciliation conference. During the conciliation conference, the DFEH presents information supporting its belief that there has been a violation and explores options to resolve the complaint. If formal conciliation fails, the DFEH Housing Administrator may recommend litigation. If litigation is required, the case may be heard before the Fair Employment and Housing Commission (FEHC) or in civil court. Potential remedies for cases settled by the FEHC include out-of-pocket losses, injunctive relief, access to the housing previously denied, additional damages for emotional distress, and civil penalties up to $10,000 for the first violation. Court remedies are identical to FEHC remedies with one exception; instead of civil penalties, a court may award unlimited punitive damages.

3. U.S. Department of Housing and Urban Development (HUD)

HUD maintains a record of all housing discrimination complaints for jurisdictions, including the City of Los Angeles. These grievances can be filed on the basis of race, color, national origin, sex, disability, religion, familial status, and retaliation. From 2005 to 2011, 772 fair housing cases were recorded by HUD in Los Angeles.

In the City as a whole, disability and race related cases were the most common, comprising 500 of the 772 cases (Table 55). Cases concerning familial/marital status (165 complaints) and national origin (116 complaints) were also regularly reported. The number of cases fluctuated annually, with a high of 164 complaints recorded in 2007.

Among the 772 fair housing cases filed and closed between 2005 and 2011, a majority of these cases (423 cases) were found to have no probable cause and subsequently closed. An additional 238 cases were closed after successful conciliation or resolution (Table 56).

Table 55: Basis for Discrimination of Cases filed with HUD (2005-2010) Familial/ National Year Race Color Sex Disability Religion Marital Retaliation Total Origin Status 2005 28 2 8 5 34 1 12 9 83 2006 13 1 15 9 32 6 22 8 83 2007 45 0 29 14 57 3 47 20 164 2008 35 0 19 19 58 6 25 20 146 2009 31 0 13 11 54 2 36 9 138 2010 28 0 10 5 35 2 11 8 82 2011 22 3 22 8 28 4 12 14 76 Total 202 6 116 71 298 24 165 88 772 Source: Department of Housing and Urban Development (HUD), 2011.

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Table 56: Closing Categories for Fair Housing Cases Filed with HUD (2005-2010) Referred Compensation Closing Admin Conciliated No Cause Cause and Closed for Conciliation Total Category Closure or Resolved by DOJ* or Resolution 2005 9 29 45 0 0 $44,532 83 2006 8 27 43 5 0 $447,460 83 2007 22 44 88 9 0 $77,267 164 2008 15 36 89 6 0 $492,079 146 2009 15 52 65 6 0 $38,233 138 2010 9 27 45 1 0 $21,162 82 2011 3 23 48 0 2 $285,196 76 Total 81 238 423 27 2 $1,405,929 772 Source: Department of Housing and Urban Development (HUD), 2011. Note: Department of Justice (DOJ)

4. City of Los Angeles

City Services and Programs

The City of Los Angeles operates a number of programs and services to serve vulnerable populations and major housing issues within the City. These programs and services are discussed below.

Elderly In 2012, the Housing Authority of the City of Los Angeles (HACLA) continued work on a mixed-financed redevelopment of the former Dana Strand Village. Phase 1 (Harbor View), Phase 2 (Wilmington Townhomes) and Phase III (Dana Strand Senior Apartments) have all been completed. HACLA is also negotiating with “Meals on Wheels” for a nutritional program for seniors at Rancho San Pedro. In addition, some Rancho San Pedro residents participated in a nutritional educational program at Descanso Gardens and other venues. HACLA also works with the City of Los Angeles Department of Aging to provide senior services. There are currently 16 Multi-Purpose Centers throughout the City of Los Angeles that serve as community focal points for senior services.

Persons with Disabilities A number of City agencies/programs assist persons with disabilities. Specifically, the Department on Disability (DOD) for the City of Los Angeles is responsible for:

. Proposing, developing and implementing policies, programs, services, and activities that will improve the quality of life for persons with disabilities;

. Developing and implementing of the City's federally mandated ADA Transition Plan, which is designed to guide the City into full ADA Compliance; and

. Providing ADA Compliance training for City departments and private entities.

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HACLA assists eligible persons with disabilities and their families afford decent and safe housing and receive necessary supportive services to remain successfully housed through a variety of programs, including the Non-Elderly Disabled, Shelter Plus Care, Project-Based Voucher, Homeless, Tenant-Based Supportive Housing, HOPWA, Moderate Rehabilitation and HUD-VASH programs.

Persons Living with HIV/AIDS The Housing Opportunities for Persons with AIDS (HOPWA) program provides support for housing assistance and services to low income persons with HIV/AIDS and their families. In Los Angeles, the Los Angeles Housing Department is the coordinating agency administering HOPWA funds for the entire County. The HOPWA funding provides one or two years of rental assistance administered by HACLA, after which the clients are funded by the standard Housing Choice Voucher program in order to open up the HOPWA assistance for a new household living with HIV/AIDS. The HACLA Section 8 HOPWA Fast Track Program, also provides housing assistance to persons living with HIV/AIDS and uses funding from the HOPWA Permanent Supportive Housing (PSH) program previously called the HOPWA Connections grant. The LAHD first applied for the funding in 2003 and the grant has been renewed two times.

Homeless The City of Los Angeles has committed 2,109 project-based vouchers, amounting to over $401 million in operating subsidy to the City’s Permanent Supportive Housing Program. Currently almost ten percent of HACLA’s Housing Choice Voucher allocation, which amounts to over 4,000 vouchers, is set aside to house homeless individuals and families who are receiving case management and supportive services. The Tenant-Based Supportive Housing Program will serve an additional 500 individuals and families who are chronically homeless and high utilizers of Los Angeles County and private supportive services.

The Homelessness Prevention and Rapid Re-housing Program (HPRP) brought $29.5 million into the City of Los Angeles and $12.2 million into the County from September 2009 to September 2012. This critical funding enabled eligible shelter clients to move to permanent housing, while simultaneously creating shelter vacancies to be filled by other homeless persons living on the streets. Without this unprecedented funding, it is likely that homelessness would have increased even more in Los Angeles. Additionally, the County’s $100 million Homeless Prevention Initiative, the City’s Housing That Works Plan, and the expanded Housing Choice Voucher programs that specifically target homeless individuals and families have created 961 new permanent supportive housing units since 2009. Additionally, the City has also dedicated a significant portion of its Community Development Block Grant (CDBG) funding to homeless programs and services. Between 2008 and 2011, 1,650 Veterans Affairs Supportive Housing (VASH) vouchers were awarded to Housing Authorities in the LA CoC. During this time period, over 1,039 veterans moved into apartments using the VASH subsidy, and the City’s Homelessness Prevention and Rapid Rehousing Program (HPRP) funded by the American Recovery and Reinvestment Act (ARRA) provided the security deposits and other assistance to facilitate their move to housing.

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Lead-Based Paint Hazards Since 1992, when Title X of the Housing and Community Development Act was enacted, the City of Los Angeles has addressed lead-based paint hazards in housing units rehabilitated with federal funds. The housing rehabilitation programs of LAHD conduct inspections for lead- based paint in every housing unit that is rehabilitated with federal funds and mitigate all lead- based paint hazards. LAHD also administers a HUD-funded Lead-Based Paint Hazard Reduction Grant program that funds inspections and lead-based paint abatement in units that meet grant criteria. Lead Grant Program funds are used citywide as follows:

. Property owners and/or tenants are low income (80 percent of MFI); . The site contains lead-based paint; . The property being remediated was built prior to 1978, and . The units are or will be occupied by families with at least one child less than six years of age either residing or frequenting the location.

LAHD targets projects in high-risk lead hazard areas (Figure 7 on page 44). High-risk communities contain:

. A concentration of pre-1940 housing; . Households with young children (less than 6 years old); . Low income residents; . A high percentage of rental units; . Minority neighborhoods; and . A significant number of cases reported with elevated blood lead levels.

In addition, HACLA conducted extensive bulk sampling and XRF Surveys of the lead-based paint in the 1990s. Risk assessments were also conducted of all the conventional developments per HUD Guidelines (Guidelines for the Removal and Control of Lead-Based Paint Hazards in Housing). HACLA identified 8,226 conventional public housing units with various levels of lead-based paint and lead containing paint. In conjunction with renovation projects, HACLA has abated or stabilized lead painted surfaces in which loose and flaky deteriorating paint is removed from friction surfaces such as window and door components, and entire exteriors.

HACLA also has contracted with eight environmental consulting firms to provide lead-based paint identification, testing, hazard identification/screening, risk assessment, hazard control, and remediation design. HACLA’s consultant’s suggestions are incorporated into the planning/design for all public housing construction, modernization and rehabilitation projects.

HACLA has built new lead-free units at the 27 unit West 87th Street Apartments. Under HACLA’s Comprehensive Modernization plan, units undergo abatement in which lead-based paint and lead containing paint are removed, stabilized, encapsulated or enclosed.

In addition, with American Recovery and Reinvestment Act (ARRA) of 2009 formula grant funds available in 2010, HACLA performed asbestos abatement at the following public housing development sites:

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. William Mead . Ramona Gardens . Pueblo Del Rio . Avalon Gardens . Gonzaque Village . Mar Vista Gardens . Estrada Courts . Imperial Courts . Nickerson Gardens . Jordan Downs . Rancho San Pedro

Fair Housing Lawsuits against the City

The City has been involved in several fair housing related lawsuits related to its policies concerning persons with disabilities. In June 2009, a lawsuit was filed against the City of Los Angeles for its discriminatory policies concerning homeless persons with service animals. Prior to this lawsuit, agencies serving the homeless under contract with the Los Angeles Homeless Services Authority (LAHSA) denied access to emergency shelter beds and services to homeless persons with service animals. A vast majority of emergency shelters in Los Angeles County receive Federal, State, County and City funds coordinated, distributed and managed by LAHSA. As a result of this lawsuit, the City, along with the County of Los Angeles, PATH Partners, and LAHSA, entered into a settlement agreement that required the establishment of policies and procedures specifically for persons with service animals at shelters. Under these new policies, homeless persons accompanied by a service animal are welcome at all LAHSA- funded agencies.

In January 2012, three Los Angeles-based advocacy groups for the disabled filed a lawsuit against the City and the former Community Redevelopment Agency of Los Angeles (CRA/LA), alleging violations of Section 504 of the Rehabilitation Act. The suit claims that the City and CRA failed to ensure that apartment complexes built with federal funds were accessible to people with disabilities. The City is currently reviewing the complaint.

Housing advocates attended the AI focus group meetings and expressed concerns that many housing units advertised as accessible do not actually meet accessibility requirements.

5. Other Fair Housing Advocates

In addition to the agencies identified above, a number of other organizations in the City are dedicated to advocating for and ensuring the fair housing rights of Los Angeles residents:

. Bet Tzedek is a non-profit, public interest law firm providing free legal services for the poor, elderly, and disabled residents of Los Angeles County.

. Asian Pacific American Legal Center (APALC), a member of the Asian American Center for Advancing Justice, is the nation’s largest legal and civil rights organization

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for Asian Americans, Native Hawaiians, and Pacific Islanders (NHPI). APALC is based in downtown Los Angeles, with satellite offices in Orange County and Sacramento.

. Inner City Law Center (ICLC), as the only full-time provider of legal services on Skid Row in downtown Los Angeles, combats slum housing while developing strategies to end homelessness. ICLC provides a wide variety of legal services focused mainly on housing and homelessness to low income individuals and families.

. Los Angeles Housing Law Project (LAHLP) is a non-profit organization founded in May 1997, by former legal aid housing advocates to address the unmet needs of low income and undocumented tenants seeking quality and comprehensive legal services in housing related matters.

. Neighborhood Legal Services of Los Angeles County (NLSLA) is a private, non-profit law firm advocating for low income residents by providing effective legal representation and a variety of legal services and community education. With a proven track record of leadership and success, NLSLA finds creative solutions to complex problems for nearly 100,000 Angelinos every year.

. Legal Aid Foundation of Los Angeles (LAFLA) has six neighborhood offices, three Domestic Violence Clinics, and four Self Help Legal Access Centers in Los Angeles. LAFLA serves communities as diverse as East Los Angeles, the Westside, South Los Angeles, Pico-Union, Koreatown and Long Beach. Nearly 12,000 individuals and families are provided with legal services annually and an additional 35, 000 litigants are helped through LAFLA’s four Self Help Legal Access Centers.

Selected Case Summaries

LAFLA has recently handled several fair housing-related cases. One is currently ongoing and involves both the owner and operators of a residential apartment complex in the midtown/east Hollywood area. The tenants are all women who allege that they were sexually harassed by the owner and/or the operators of the hotel and denied services for refusing to acquiesce to requests for sexual favors. In addition to fair housing act violations, the complaint also alleges retaliatory eviction and violations of other landlord tenant laws. The complaint is in Federal Court.

The second case, also filed in federal court, involved discrimination on the basis of disability against a tenant at a residential four-plex. The allegations include the owner and operator failing to provide accommodations to persons with physical impairments. The case involved failure to move a tenant to an available unit that would allow the wheelchair-bound tenant to live in a safer setting without the added risk of harm caused by living in an upper floor. The tenant had previously been forced to climb stairs by crawling on the staircase to reach her apartment. The case settled.

Finally, LAFLA is currently litigating a case in State Court in which it is alleged, in part, that the owners of the downtown residential hotel is refusing to rent to persons with disabilities, actively seeking or actively sought to remove persons who are elderly and persons with

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E. NIMBYism

Many people agree that a variety of housing should be available for people with special needs, such as homeless shelters, affordable housing, and group homes for people with disabilities. However, whether or not these types of housing should be located within their own community is another matter. The following discussion on NIMBYism is not specific to the City of Los Angeles and is included below simply to provide context for the analysis of SB 1721 and SB 2 that concludes this chapter.

The Not-in-My-Back-Yard sentiment (NIMBYism) can serve as the most significant constraint to the development of affordable or even market-rate multi-family housing. NIMBYism describes opposition by residents and public officials alike to additional or different kinds of housing units in their neighborhoods and communities. The NIMBY syndrome often is widespread, deeply ingrained, easily translatable into political actions, and intentionally exclusionary and growth inhibiting. NIMBY sentiment can reflect concerns about property values, service levels, community ambience, the environment, or public health and safety. It can also reflect racial or ethnic prejudice masquerading under the guise of a legitimate concern. NIMBYism can manifest itself as opposition to specific types of housing, as general opposition to changes in the community, or as opposition to any and all development.

Community opposition to high-density housing, affordable housing, and housing for persons with special needs is directly linked to the lack of such housing options for residents in need. In particular, community opposition is typically strongest against high-density affordable housing and group homes for persons with mental disabilities.

Community residents who are especially concerned about the influx of members of racial and ethnic minority groups sometimes justify their objections on the basis of supposedly objective impacts like lowered property values and increased service costs. Racial and ethnic prejudice often is one root of NIMBYism, although NIMBY concerns still exist where racial or ethnic differences are not involved. The California legislature has passed various Anti-NIMBYism housing bills to prevent communities from rejecting affordable housing projects, including:

SB 1721 - The bill stipulates that a local agency shall not disapprove an affordable housing development project, including agricultural worker housing, or condition approval, including through the use of design review standards, in a manner that renders the project infeasible for development for the use of lower- or middle-income households.

SB 2 - Expands the Housing Accountability Act, to prohibit localities from denying a proposal to build an emergency shelter, transitional housing or supportive housing if it is needed and otherwise consistent with the locality’s zoning and development standards.

City of Los Angeles Page 170 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 Chapter 6: Progress since Previous AIs

This chapter summarizes and compares key findings of the previous AI documents in order to evaluate the progress toward addressing impediments to fair housing choice. These include:

. 1996 City of Los Angeles AI . 2005 City of Los Angeles AI

The City of Los Angeles has prepared only two official Analysis of Impediments (AI) to Fair Housing Choice reports pursuant to HUD requirements. These were the 1996 AI and 2005 AI reports.

The 2002 Fair Housing Impediment Study: How Land Use and Zoning Regulations and Practices Impact Housing for Individuals with Disabilities, by Kim Savage, Mental Health Advocacy Services, Inc., in November 2002 was not an AI. The 2002 impediment study is the City’s proactive fair housing efforts in direct response to one of the conclusions of the 1996 AI (Impediment #6 of that report), stating that the City’s mechanisms for identifying discrimination wee predominantly reactive rather than proactive.

A. 1996 City of Los Angeles AI

Overarching Comment

The 1996 AI was the first Analysis of Impediments produced for the City of Los Angeles. It was a controversial document that local fair housing experts and the City did not entirely agree with. Therefore, not all of the impediments and recommendations identified in the 1996 AI were considered to be of equal importance.

Impediment #1: Comprehensive Fair Housing Planning

The City lacks a comprehensive fair housing plan.

Efforts/Response

The development of the AI was required by HUD to address the lack of comprehensive fair housing planning by many entitlement jurisdictions in the nation. Therefore, it is understandable that this finding was made by the authors of the first Los Angeles AI. This initial AI did eventually lead the City to develop a more comprehensive approach toward fair housing in the City.

This impediment, along with the others identified in the 1996 AI, were seriously considered by the City of Los Angeles and led to several changes in the design and operations of the citywide fair housing program.

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Selecting a Fair Housing Service Provider and Scope of Work The AI recommended that City support for fair housing should be awarded via a competitive process, not through a sole-source contract to the same agency every year. A request for proposal (RFP) process was initiated by the City in 1998 and has been held every three years since that time.

Through the RFP process, as well as significant changes to the contractual scope of work and annual deliverables, the City ensured that the citywide fair housing program was made more comprehensive, with an increased focus on coordinated litigation and in-house attorneys, rather than relying primarily on pro-bono and contract resources.

Currently the Los Angeles Housing Department (LAHD) contracts with the Southern California Housing Rights Center (HRC) to provide a citywide fair housing program to residents. HRC also has subcontracts with two community-based fair housing agencies, the Fair Housing Council of San Fernando Valley (FHCSFV) and the Fair Housing Foundation (FHC), to ensure services exist in different parts of the City of Los Angeles.

HRC and its subcontractors provide the following services to Los Angeles residents:

. Investigations of housing discrimination complaints concerning housing for rent or sale, advertising, lending, insurance, steering, blockbusting and hate crimes; . Remedies for valid complaints, including conciliations, legal action and administrative referrals to state and federal fair housing agencies; . Multilingual counseling on fair housing and predatory lending issues; . Multilingual property owner, manager and realtor training sessions; and . Educational seminars, workshops and presentations on fair housing.

HRC also sponsors the Housing Rights Summit, a day-long conference held annually since 2000, which invites interested parties to attend and raises public awareness of fair housing issues and services. The event usually attracts civil rights advocates, social service providers, housing industry and community members, and government entities to address fair housing and other related issues, including housing accessibility for persons with disabilities and the effect of housing conditions on resident health. The Housing Rights Summit for 2012 occurred on Wednesday, April 25, 2012.

Responding to Concerns of Fair Housing Advocates Furthermore, in response to advocate concerns and a lawsuit regarding the reasonable accommodation of service and companion animals in local homeless shelters, the City and County of Los Angeles, and the Los Angeles Homeless Services Authority (LAHSA) worked with HRC to develop and present six training workshops for homeless service providers on reasonable accommodations and other fair housing topics. The sessions took place in October and November of 2010 at LAHD’s Garland office and approximately 600 people attended. Representatives from all LAHSA and HOPWA contract agencies, as well as LAHSA’s staff, City Attorney and County Counsel staff, and LAHD staff were in attendance at the three-hour training sessions that were conducted by attorneys from HRC. The LAHD also arranged for the City’s Cable Channel 35 to videotape the last two training sessions; master DVDs were made and copies provided to the City Attorney and County Counsel’s office.

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Affirmatively Furthering Fair Housing In addition to LAHD’s involvement in furthering fair housing, LAHD is a member of the Southern California Fair Housing Advertising Task Force, along with other participants, which include: the Apartment Association of Greater Los Angeles; the California Department of Fair Employment and Housing; the City of Lakewood; the Fair Housing Council of Orange County; FHF; HRC, the Los Angeles Times; the San Diego Fair Housing Council; FHCSFV; and the U.S. Department of Housing and Urban Development (HUD). The Task Force meets quarterly and meetings are convened by the Los Angeles Times.

The purpose of the Fair Housing Advertising Task Force is to inform and educate all housing related industries, media groups and the general public about Federal and State Fair Housing Laws and Guidelines to prevent and discourage housing discrimination. At the last Task Force meeting (March 2012), the group discussed the posting of fair housing questions and answers, which will include a referral to HRC and the Fair Housing Council of Orange County. These questions and answers will appear in weekend editions of the LA Times near rental ads. A HUD participant also presented sample housing discrimination posters to the group. The posters will be posted at different locations (and in Spanish [e.g., Hoy newspaper]) to recognize Fair Housing Laws and to commemorate April as Fair Housing Month.

In addition, the LAHD actively markets low and moderate income housing opportunities citywide. The City requires owners and developers of multi-family housing who receive financial assistance from the City to develop an affirmative marketing plan consistent with the Department’s requirements. The marketing plan, subject to approval by LAHD, must contain specific procedures to inform and solicit applications from persons in a specific housing market area who are not likely to apply without special outreach. Overall, the goal of the plan is to promote equal housing choices for prospective purchasers or tenants.

LAHD also uses the following affirmative marketing procedures to advertise programs, funding availability, and to solicit bids and requests for proposals. These affirmative marketing procedures include: advertisements in Los Angeles newspapers with citywide circulation; newspapers with a target audience (i.e., newspapers that reach Spanish or Korean speakers); community meetings; newsletters; special workshops; notices on the City’s and LAHD’s websites; and special meetings.

Impediment #2: Monitoring and Oversight

There is insufficient monitoring and oversight of fair housing activities.

Efforts/Response

This impediment led to an effort at LAHD to increase the Department’s focus on fair housing work in Los Angeles. As mentioned above, the request for proposal (RFP) process initiated by the City in 1998 led to significant changes in the contractual scope of work and annual deliverables. The LAHD also provided additional staff resources on monitoring and program development, which was supported by the Mayor and City Council.

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One result of the increased monitoring was that, over time, the non-profit Fair Housing Congress, which had functioned for many years as an umbrella agency and conduit for grants to the smaller local fair housing councils, became unable to sustain itself and went out of business.

LAHD’s Current Contract Agreements LAHD’s current contract agreements (i.e., ESG, CDBG, HPRP, and General Fund contracts) with LAHSA all include language regarding a fair housing requirement:

. Section 415 (Compliance with State and Federal Statutes and Regulations) . Subsection A (Statutes and Regulations Applicable to All Grant Contracts) . Subsection 9 (Civil Rights) requires LAHD’s homeless contractor, LAHSA, to, among other things, comply with the applicable federal regulations ensuring non- discrimination in the sale, rental or financing of housing. More specifically, Sec. 415.A.14. . Subsection 5 requires LAHSA to comply with the provisions of the Federal Fair Housing Act. LAHSA is also required to incorporate these requirements into its homeless subcontractor agreements and monitor compliance with these requirements at the subcontractor level.

LAHD, in turn, monitors LAHSA's compliance with the various civil rights requirements, including fair housing. LAHD also oversees LAHSA's efforts to monitor its (city-funded) homeless service providers to ensure that they comply with these requirements.

Impediment #3: Enforcement

There is inadequate enforcement of fair housing laws through litigation.

Efforts/Response

As part of the fair housing program changes referred to above, such as introducing a competitive process for City funds and a bigger focus on litigation, the City also increased annual funding for citywide fair housing enforcement and services by over 50 percent in 2000 (from $500,000 to $770,000). These funds (which include CDBG and local dollars) leveraged funds from the County of Los Angeles and other local jurisdictions, and allowed the contractor, HRC, to offer a comprehensive countywide fair housing program with several attorneys on staff.

LAHD began funding a fair housing attorney as part of its fair housing contract approximately 15 years ago. Since that time, HRC has been able to leverage other funds, such as settlement funds and contributions from major law firms, to fund additional positions. Up until several months ago, HRC was able to fund three full-time staff attorneys and a Director of Litigation. At the present time, HRC has three attorneys who litigate its fair housing cases full-time and it hopes to have funding for four full-time attorneys again in the near future to assist with the recent increase in its litigation efforts. HRC has also recently co-counseled cases, including one involving the Legal Aid Foundation of Los Angeles. Subcontractors to HRC must also have attorneys on staff or contract to support litigation efforts.

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Impediment #4: Discrimination

Latinos, African-Americans and families with children are more likely to be discriminated against.

Efforts/Response

The City has had a $770,000 annual contract with HRC for citywide fair housing enforcement and services for several years. Much of HRC’s work, both outreach and clients, is focused on providing services to members of these protected classes.

City funds (which include CDBG and local dollars) leverage other funds and allow HRC to offer a comprehensive countywide fair housing program which can track discrimination across many jurisdictions to identify patterns and practices of discrimination by particular rental property owners or management companies.

HRC Events In addition to providing fair housing services, HRC organizes a number of events and outreach activities to publicize its services and fair housing issues in general. Since 1996, HRC has made significant progress in raising public awareness of discrimination against Latinos, African- Americans, and families with children. In recent years, HRC has focused its efforts on raising awareness of discrimination against people with disabilities due to an increased volume of calls received from disabled individuals who felt they were victims of discrimination. Since 1996, HRC has hosted 29 citywide educational conferences for the purpose of bringing together fair housing groups, social service providers, community members, and government entities to address fair housing and other related issues, such as immigration, community development, the underreporting of housing discrimination and affordable housing. The diversity of HRC’s conferences brings a fresh perspective to addressing fair housing impediments and promoting a new understanding of connections between fair housing issues and other issues.

To date, more than 3,000 community members have attended HRC’s annual conferences. Topical seminars, such as the Immigrant Rights Seminar in 2004, the Race Relations Seminar in 2005, and the Disability Rights Forum in 2011, also featured on-site health and resource fairs which provided attendees with direct client services.

The following summarizes the outreach activities performed by HRC, FHF, and FHCSFV:

Booths . Los Angeles Latino Book and Family Festival (2007, 2010) . Echo Park Housing Resource Fair (2003) . Sol Festival at MacArthur Park (2003)

Annually: . Agency Contacts – 240 . Agency and Community Meetings – 48 . Booths – 28

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. Literature Distribution – 12, 000 . Management Trainings – 16 . Spanish Trainings – 4 . Newsletters – 9 . Press Release – 12 . PSAs – 18 . Presentations to other nonprofits – 16 . Presentations to clients of other nonprofits – 16 . Tester Trainings – 35 . Tenant Workshops – 11 . Landlord Workshops – 3

Impediment #5: Non-English Speaking Communities

There is insufficient fair housing outreach to non-English speaking communities.

Efforts/Response

In 2001, the LAHD paid for the translation and printing of a variety of English language fair housing brochures in several languages including Spanish, Korean, Russian, Farsi, Mandarin, and Armenian. These brochures have been an important resource for outreach to non-English speaking communities in the City of Los Angeles for over 10 years and have been updated as needed by HRC.

Furthermore, HRC has specifically focused on immigrant and non-English speaking communities that fair housing groups have had difficulty reaching. This is an important component of a comprehensive fair housing program because immigrant populations are increasingly redefining neighborhoods throughout Los Angeles. Moreover, these immigrant populations often face formidable barriers because of discriminatory housing practices. Fair housing efforts are therefore directed towards educating immigrant populations about their fair housing rights and responsibilities and ensuring that enforcement mechanisms address the specific types of discrimination they encounter. HRC understands that the best way to achieve this goal is through extensive outreach.

HRC’s immigrant and non English speaking community outreach component is organized into four parts: 1) Identify target areas that fair housing agencies have had difficulty reaching; 2) Create/increase greater public awareness of our presence, services we offer, and housing rights under the law; 3) Create a more active and extensive network with community and culturally based organizations that serve these communities; and 4) Recruit volunteers from target areas.

Identifying Target Areas In identifying target areas, HRC takes into account a variety of factors ranging from demographic to cultural. Recent immigrants in Los Angeles are often localized in specific neighborhoods. This is often the result of personal contact networks that direct new arrivals to the locations of friends and relatives. Unusually high proportions of recent immigrants in certain neighborhoods suggest that these areas may house pockets of persons with very low English-language proficiency.

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Identifying these neighborhoods is more difficult because the role of traditional ethnic staging grounds has changed since the 1960s. For example, recent Latino immigrants have settled less in Boyle Heights and other old neighborhoods, opting instead for inexpensive houses and apartments in Westlake and Koreatown. Upon examining where contemporary networks of immigration are leading people, the target areas for HRC’s outreach plan are: 1) Koreatown; 2) Pico Union; 3) Van Nuys; and 4) Watts.

Create/Increase Greater Public Awareness Creating public awareness is a very important part of outreach. The number of people who actually know about fair housing issues directly relates to HRC’s success as a fair housing agency. HRC uses all of the tools available (i.e. posters, flyers, and doorknob hangers) to increase awareness. Additionally, new methods must be tried. Ethnic newspapers that serve HRC’s target Areas (Armenian Observer, Chinese American Daily News, China Weekly, City Terrace Comet, L.A. Asian Journal, Hoy, LA Opinion, etc.) have been contacted for advertisements. Smaller free magazines have also been contacted. Other media outlets such as radio (KTNG-AM 1020, KREA-FM 93.5, KXED-AM 1540, etc.) and television (Telemundo, KCET-TV Channel 28, KVEA-TV Channel 52, etc.) have been looked into as well. These media resources are a powerful vehicle for increasing public awareness.

In addition to promoting HRC’s program through media and educational venues, the agency goes to events and places where immigrants, people of color, and low-income people congregate. For example, HRC travels to community festivals, health fairs, and other social events to post flyers on available community boards.

Building an Extensive Network In all of the target areas, there already exist organizations that work with the vulnerable populations identified. HRC has created a database that contains resources (community groups and services) that have been contacted. These resources range from social services, schools, churches, libraries, and media contacts. Through phone calls, mailing, or personal visits, HRC contacted these groups to let them know of the services HRC provides and inform them where services are available to the populations that they serve. HRC also make flyers available at their public centers. Many of these groups are already well established within immigrant communities in the identified target areas and by working with them, HRC will learn more about the target areas and the most effective ways to reach these residents.

Recruiting Volunteers Recruiting volunteers has also proven to be successful in aiding outreach efforts. Volunteers improve HRC’s language capacity, conduct presentations, make neighborhood visits, staff booths, and network with other community groups. Volunteers are recruited from identified target areas and are able to assist with language and cultural issues in these neighborhoods, as well as develop innovative methods of outreach specific to that target area.

Outreach Materials HRC, FHCSFV and FHF staff have developed and distributed materials in the City that describe how housing injustices arise, the applicable laws that protect against housing discrimination and ways to prevent housing inequity. Their materials and programs are offered to a variety of

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 177 Public Review Draft May 30, 2012 audiences such as housing professionals (e.g., landlords, property managers, and realtors), tenants, prospective homebuyers, city employees, and other non-profit organizations. Depending on the audience, the written materials are translated by HRC staff into Armenian, Chinese, Korean, Russian or Spanish. Because the City is so large, materials have been distributed during neighborhood visits and through mailings to ensure that all residents have access to fair housing information and services.

Outreach and Education Services HRC, FHCSFV and FHF provide outreach and education services including programs and workshops at sites throughout the City and in collaboration with local programs and services. Depending on the audience, the presentations have been translated by staff and volunteers into Spanish, Mandarin, Cantonese, Korean, Armenian, or Russian. If other languages are needed, HRC works with volunteers and other non-profits to utilize their language skills. All presentations and workshops are free and open to the public.

HRC, FHCSFV and FHF also hold frequent property management seminars. These seminars are tailored to provide landlords with detailed analysis of fair housing law and interpretation, with specific information on discrimination against families with children, disability provisions, sexual harassment, hate crimes, and advertising. HRC’s management training sessions are conducted by the agency’s staff attorneys. The Certification Training Manual was also recently rewritten by HRC’s staff and has already been translated into Spanish and Korean. Staff has provided training in English, Mandarin, Cantonese, Russian, Armenian, Spanish, and Korean as needed.

Impediment #6: Identifying Discrimination

Current mechanisms for identifying discrimination are predominantly reactive rather than proactive.

Efforts/Response

One excellent example of a proactive AI follow-up study was the 2002 report How Land Use and Zoning Regulations and Practices Impact Housing for Individuals with Disabilities by Kim Savage of Mental Health Advocacy Services. The LAHD allocated additional CDBG administrative funds for this study, which resulted in a number of positive changes in the City’s zoning code.

In the past, HRC has undertaken “proactive” fair housing audits on an annual basis. These audits are typically a patterns and practice audit based on actual or anecdotal discrimination. For example, HRC has conducted proactive tests that included an audit that addresses For Rent signs that are not in English. HRC has also conducted several proactive, non-complaint driven audits in an effort to determine discrimination based on race, national origin, familial status and disability (including design and construction tests and disability surveys). However, funding cutbacks have forced the LAHD to remove that requirement so that the basic services can remain fully funded.

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Impediment #7: Landlord/Tenant Counseling

Landlord/tenant counseling dilutes fair housing enforcement efforts.

Efforts/Response

The City added $250,000 of local funds (Rent Stabilization Trust Fund) for fair housing work in 2000, which was later increased to $270,000. This allocation was made to increase the overall budget for fair housing, which had not changed for many years. The source of funds was meant to compensate HRC and subcontractors for the time they spend on inquiries that ultimately are determined to be landlord-tenant issues, not fair housing discrimination. In order to provide quality customer service, HRC staff and LAHD’s Rent Stabilization Ordinance staff engaged in cross trainings so that the hotline staff at both agencies would be better able to handle inquiries and give callers the information they needed, instead of just referrals to other agencies.

Impediment #8: Neighborhood Diversity

There is a lack of small scale initiatives that could slow neighborhood re-segregation and encourage neighborhood diversity. This endangers the generally high level of diversity in Los Angeles neighborhoods.

Efforts/Response

This item is an example of an identified ‘impediment’ that was not well-defined, not understood nor agreed to by other fair housing advocates. It was not clear what type of ‘small scale initiatives’ were needed to address it, nor what appropriate actions should be taken. Therefore, there were no efforts to address this impediment, compared to the substantial efforts made to address other items.

As discussed earlier, more minority groups are moving to different ethnic areas in search of affordable housing opportunities. Specifically, recent Hispanic immigrants tend to move into: 1) Koreatown; 2) Pico Union; 3) Van Nuys; and 4) Watts. Therefore, policies that promote the dispersal of affordable housing would help mitigate racial segregation.

Impediment #9: Public Housing Authority

The local public Housing Authority engages in little fair housing activity.

Efforts/Response

The Housing Authority of the City of Los Angeles (HACLA) is not a City agency. It has independent status according to state law; the Mayor of Los Angeles does appoint the HACLA Commissioners but the Mayor and City Council do not have authority to review or approve its budget or operations. The City and HACLA partner on many worthwhile projects but the City’s legal power to influence its activities is minimal.

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This impediment was not agreed upon in general by all local fair housing advocates. The primary concern was that HACLA did not enforce the State’s fair housing laws and focused only on federally protected classes and laws. Local fair housing advocates and LAHD staff met several times with HACLA about this topic in the early 2000s. There have been leadership changes since that time and HACLA currently promotes and enforces both federal and state fair housing laws.

HACLA actively works to affirmatively further fair housing for applicants and participants in its programs, and users of its facilities and housing. This is done by carrying out the following programs and activities:

Persons with Disabilities A “504 hotline” is provided for persons with disabilities to report difficulty in accessing staff or program benefits due to disability. HACLA also has a “504 Coordinator” e-mail address and provides six TTYs for communication with hearing and speech-impaired persons. HACLA also has a Reasonable Accommodations Policy in place and conducts training every other year on topics for both the Section 8 and Housing Services Departments. Major components of the City’s Reasonable Accommodations Policy include:

. When a resident with a disability requests one or more modifications to his or her public housing unit, once the request form is submitted and the disability is verified, the Housing Authority provides any reasonable modification related to that individual’s disability. . HACLA has a streamlined procedure for persons with visible and/or obvious disabilities to self-certify a need for requested accommodation, provided that one-time cost of the accommodation is under $1,000. For disabilities that are not obvious or visible or the cost is over $1,000, third party verification of the disability by a healthcare provider or a social work professional licensed by the state or working for a government or non-profit entity is required. . HACLA has a Transition Plan for its public housing program that includes modifying additional units for accessibility to disabled persons. Public housing residents may contact the Section 504 Coordinator through the Section 504 “hotline” for resolution of problems, or may file a grievance if they choose.

Language Services Unit The Language Services Unit, located within the Housing Services Department, provides services for both the Section 8 and the Housing Services Departments. Language Services not only coordinates translation and oral interpretation services for persons with Limited English Proficiency (LEP) but also coordinates securing sign language interpreters for person with hearing impairments. HACLA also contracts with Language Line service to access telephone interpretation in 150 languages in addition to hiring competent bilingual staff in threshold languages.

The majority of “vital” documents have been translated into Spanish for use in both departments and HACLA is in the process of having such documents translated into other

City of Los Angeles Page 180 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 threshold languages. HACLA’s LEP policy was also updated in the fall of 2010 and the Housing Authority currently conducts training for all public contact positions.

Section 8 Department Activities

Special Programs to Eligible Households The programs currently being administered by the Section 8 Department target various low- income households, which include protected groups such as the elderly, and persons with AIDS and other disabilities. Programs such as the Family Self-Sufficiency (FSS) are designed to encourage participants to become economically self-sufficient and become less dependent on all forms of public assistance. The programs that the Section 8 Department administers that expand housing choice for persons of protected classes include:

. Family Self-Sufficiency Program (FSS) . Homeless Program . Housing Opportunities for Persons with AIDS (HOPWA) . Homeownership Program . Moderate Rehabilitation (Mod Rehab) Program . Moderate Rehabilitation Single Room Occupancy (MRS) . Project-Based Assistance Program (PBA) . Shelter Plus Care Program . Mainstream – Housing Opportunities for Persons with Disabilities (due to limited funding, this is currently not accepting new participants at this time).

Resident Services The Resident Services Division of the Housing Department coordinates the delivery of an array of programs and services primarily designed to assist public housing residents and grant- funded program participants, including those in protected classes, become better educated, enter employment, and participate in community building activities. Services are provided by partner organizations that are qualified and experienced in education, employment training, credit counseling, financial education, and leadership development. Resident Services is also home to the Language Services unit that provides interpretation and translation services for the entire Housing Authority.

Resident Services provides the following programs and activities:

. Resident Leadership Training . Educational activities . Employment and training activities . Housing-Based Day Supervision Program . Employment Technology Centers

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Impediment #10: Public Housing Sites

Large public housing sites are often racially segregated.

Efforts/Response As noted above, HACLA is not a City agency and the City has limited power to influence its operations. HACLA was the subject of one or more lawsuits on this topic in the 1990s.

The Housing Services department oversees public housing developments. HACLA’s original mission was slum clearance. This is reflected in the concentration of its large public housing developments. HACLA has taken several steps to expand housing choice for public housing residents through various deconcentration methods.

HACLA has redeveloped two large public housing sites, Pico Gardens and Aliso Village, folding public housing units into vibrant, mixed economic communities. Pico Gardens has become Pico Gardens/Las Casitas and Aliso Village is now Pueblo del Sol. Additionally, a third public housing development, Dana Strand has been redeveloped into a mixed economic community with two phases, Harbor View Garden Apartments and Wilmington Townhomes, completed so far.

HACLA has utilized Replacement Housing Factor funds in purchasing scattered site residential properties in the Watts area of Los Angeles, in close proximity to the Jordan Downs public housing site that can be used for temporary relocation of residents as part of the Jordan Downs redevelopment. Replacement Housing Factor funds are also being utilized to develop 30 newly constructed public housing units under a mixed finance development on the west side of Los Angeles. These units will be available to senior and disabled residents in an area which has historically been underserved by public housing or low and moderate income housing.

Class Action Lawsuit against HACLA In the early 1990s, much tension existed between Latino and African-American residents in Watts. Newly arrived Latino residents were being harassed and even physically attacked by African-Americans who were resentful of the changing demographics of the Watts neighborhood.

Several cases of reckless violence against Latinos were reported to the authorities with little results. As time proceeded, Latino residents realized the lack of police response and felt the need to address this issue. As a result, in 1994, the Watts/Century Latino Organization (WCLO) in conjunction with the Watts Health Foundation (WHF), obtained legal counsel and filed a Class Action Lawsuit against HACLA. In 1996, a settlement agreement was reached and as a result, violence in general and particular against Latinos noticeably decreased.

Later, the WCLO, a non-profit organization, began a series of outreach programs meant to bridge some cultural gaps between the two minority groups. Both a Watts Community Bridges and a Conflict Resolution and Mediation Committee were formed. Soon after, WCLO also organized various tours and festivals to assist the ethnic groups in getting to know one another in the hopes of finding some common ground. For example, Latinos were taken to visit African-American museums and African-Americans were invited to attend Latino landmarks

City of Los Angeles Page 182 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 like Plazita Olvera. After several years of working together, both communities breached their differences and the incidence of violence has lowered noticeably although it was never completely eradicated.

Impediment #11: Rental Subsidy Programs

Rental subsidy programs tend to intensify segregation and constrict residential choices.

Efforts/Response

HACLA HACLA conducts regular outreach to add rental property owners as new participants in its rental subsidy program (formerly called Section 8, now known as Housing Choice Vouchers). However, this national program, by its design, is dependent on local real estate economies for its ability to support housing choice in more neighborhoods of the City. In good economic times when rental vacancies are low, there is less financial incentive for rental property owners, and particularly those in affluent, less segregated neighborhoods, to participate in the program. This is a problem nationwide.

LAHD LAHD finances affordable housing development through the City’s Affordable Housing Trust Fund (AHTF) Program. The AHTF creates affordable rental housing for low and very low income households by making long-term loans for new construction or for the rehabilitation of existing residential structures through a competitive Notice of Funding Availability (NOFA) process.

The AHTF was established by the Mayor and City Council through the City’s budget process in June 2000 in response to the critical shortage of affordable housing in Los Angeles. Seed funding of $5 million was provided, which was immediately committed by LAHD to fund proposed housing developments that were on the waiting list from the NOFA for that year. In the following fiscal year, $10.5 million was budgeted for the AHTF Fund (Fiscal Year 2001- 2002).

In January 2002, the Mayor announced his $100 million proposal for the AHTF, and a multi- year funding plan based on the Mayor’s proposed plan was approved.

Status Currently, the AHTF is comprised of various funding sources, including but not limited to federal HOME funds, the City’s general funds, and McKinney Act bond funds.

One to three funding rounds are held each calendar year, with projects competing for AHTF that are used to leverage Low Income Housing Tax Credits (LIHTC) or funding from other State or Federal housing programs. Since 1990, LAHD has provided financing options to developers, which has not intensified segregation and constricted residential choices, but in fact, allowed for affordable housing to be developed throughout the City of Los Angeles.

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Impediment #12: Insufficient Funding

There is insufficient funding for specific fair housing activities, including multi-lingual professional fair housing staff, attorneys, and broad-based outreach and media programs.

Efforts/Response

This identified impediment supported the LAHD as it prepared a detailed analysis in 1999 of the funding levels for fair housing over time. That analysis led to a proposal for a 50 percent increase (from $500,000 to $750,000) in annual funding for the citywide fair housing program, which was approved by the Mayor and City Council in 2000. These additional resources allowed the new citywide contractor, HRC, to leverage the contract support received from other local jurisdictions to hire attorneys, develop an effective litigation department and conduct better quality and more comprehensive outreach.

B. 2002 City of Los Angeles Fair Housing Impediment Study

Overarching Comment

The 2002 Fair Housing Impediments Study: How Land Use and Zoning Regulations and Practices Impact Housing for Individuals with Disabilities was not a formal comprehensive Analysis of Impediments developed for the City of Los Angeles. Therefore, no responses are given below because the document was not an AI.

This report was a pro-active AI follow-up study initiated by LAHD, with additional CDBG administrative funds, which resulted in a number of positive changes. The study was one response by the City to Impediment No. 6 above, Identifying Discrimination: Current mechanisms for identifying discrimination are predominantly reactive rather than proactive. The study resulted in several positive changes, including adoption of the City’s Reasonable Accommodation Ordinance to address the provision of housing for persons with disabilities.

C. 2005 City of Los Angeles AI

Impediment #13: Housing and Household Characteristics

The City has a number of fair housing impediments related to housing and household characteristics, including:

. Large Households: Large households, particularly those with children, often face discrimination in the housing market.

. Homeless Persons: Homeless and formerly persons have a very difficult time finding housing – either accessing emergency shelters or transitional housing facilities, or finding moving from a transitional housing or other assistance program to permanent housing.

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. Seniors: In a tight housing market, seniors, particularly those with disabilities, often face increased difficulty in finding housing accommodations or face targeted evictions.

. Single Parents: Some landlords and managers are reluctant to rent to single parents, particularly single mothers, due to concerns about their ability to pay rents and to manage their children.

. Disability: Fair housing choice for persons with disabilities can be compromised based on the nature of their disability. Persons with physical disabilities may face discrimination in the housing market because of the use of wheelchairs, need for home modifications to improve accessibility, or other forms of assistance.

. Persons with HIV/AIDS: For persons living with HIV/AIDS, access to safe, affordable housing is equally important to their general health and well-being as access to quality health care.

. Renters with Housing Problems: As with the majority of Southern California communities, renter-households in general are disproportionately affected by the problems of housing cost burden and overcrowding.

Efforts/Response

The programs designed to carry out the mission of LAHD address many of the key impediments listed above. The following discussion is provided to show the applicable programs and activities to address the various aspects of this impediment.

Large Households City efforts to address the housing needs and problems of large households include, but are not limited to:

. Rent Stabilization Ordinance (RSO), established in 1980, provides for reasonable rent increases and prevent arbitrary evictions. . Systematic Code Enforcement Program (SCEP), established in 1998, and housing code complaint program inspects all rental housing in the city except single-family homes and enforces State Health and Safety Codes, and lead-safe work practices. . Affordable Housing Trust Fund (AHTF) supports the development of new affordable housing, including large family rental housing. The AHTF was established in 2000, but LAHD has financed large family housing since its inception in 1990. . Fund a robust Citywide Fair Housing Program.

Homeless Persons The City of Los Angeles has implemented and planned various programs/initiatives to address the City’s homeless crisis. LAHD plays a vital role in these efforts. LAHD uses several different approaches to respond to the housing needs of persons with disabilities and individuals and families who suffer from homelessness. In addition to financing the development of affordable

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 185 Public Review Draft May 30, 2012 housing for a variety of persons with special needs, both physical and mental disabilities, LAHD also promotes policy change via local legislation and the Zoning Code, through its Citywide Fair Housing Program. Furthermore, the countywide HOPWA program is administered by LAHD, which serves persons with disabilities. The following programs provide additional support for the City’s homeless:

The Permanent Supportive Housing Program (PSHP) In 2006 the Permanent Supportive Housing Program (PSHP), a part of the AHTF, was established by LAHD as a partnership with HACLA, the City’s Department of Water and Power, and the Community Redevelopment Agency of the City of Los Angeles, with an acquisition fund developed by the Corporation for Supportive Housing and many investors. It funds over 100 new permanent supportive housing units each year (depending on available funding). Since its inception, LAHD has provided over $111.9 million of the City’s AHTF dollars to PSHP.

Additionally, PSHP is working with LAHSA and County agencies to provide the support services, which are crucial to ending the cycle of homelessness. This combination of permanent housing with supportive services for those with special needs (i.e., mental illness, substance use issues, HIV/AIDS, etc.) has been proven to be one of the most effective solutions to homelessness. Alliances formed between the housing and service agencies help homeless people secure and keep the housing and services necessary to avoid falling into homelessness once again. Supportive Housing is the cornerstone of the current national movement to end homelessness.

The City and County of Los Angeles and LAHSA were served with a lawsuit in July 2009 regarding lack of reasonable accommodation for homeless persons with service/companion animals in local homeless shelters. LAHD worked with the City Attorney and LAHSA to negotiate a settlement, arrange for the training of homeless shelter providers and others, and develop a curriculum for the training. These activities took place in 2009-2010 and training, held at LAHD, occurred in December 2010.

The Los Angeles Homeless Services Authority (LAHSA) LAHSA is the agency designated by Los Angeles County and all participating cities within the County except Pasadena, Glendale, and Long Beach, to annually apply for Stewart B. McKinney funds through the SuperNOFA process. As the lead agency in the Los Angeles Continuum of Care, (Los Angeles CoC), LAHSA coordinates and manages over $80 million dollars annually in Federal, State, County and City funds for programs providing shelter, housing and services to homeless persons in Los Angeles City and County. LAHD is responsible for the proper administration of CDBG, ESG and other Federal funds. LAHD annually issues approximately $23 million of the City’s allocation of Federal dollars (e.g., CDBG, ESG) to LAHSA. LAHD provides oversight and monitoring of LAHSA’s programs for compliance.

LAHSA provides funding, program design, outcomes assessment and technical assistance to nearly 300 homeless services programs through over 100 non-profit/local government partner agencies which operate within the City and County of Los Angeles. These partner agencies assist persons who are homeless in achieving independence and stability in permanent housing. LAHSA’s partner agencies provide a continuum of programs ranging from outreach, access

City of Los Angeles Page 186 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 centers, emergency shelters, safe havens, transitional and permanent housing, and prevention along with the necessary supportive services designed to provide the tools and skills required to attain a stable housing environment.

Specialized programs funded through LAHSA address a wide-range of issues related to homelessness, including but not limited to: domestic violence, mental illness, substance abuse, job training, family strengthening, health, mainstream benefits enrolment, and most importantly, supportive short and long-term housing. Additionally, LAHSA partners with both the City and County of Los Angeles to integrate services and housing opportunities to ensure a wide distribution of options throughout the Los Angles CoC.

LAHSA uses Supportive Housing Program (SHP), ESG, CDBG, Independent Living Program (ILP), Temporary Assistance for Needy Families (TANF), and City and County General Funds to support a system of housing and services programs for homeless families and individuals in the Los Angeles CoC.

Projects funded by LAHSA using ESG and CDBG funds from the City of Los Angeles’ Consolidated Plan support a variety of critical programs, such as emergency shelters, transitional housing, permanent housing, job training, access centers, and supportive services. In addition, new funds from HUD became available in the 35th Program Year via the American Recovery and Reinvestment Act of 2009 (see below for HPRP).

Recently, LAHSA was awarded $13.6 million from HUD to fund new permanent supportive housing projects for the region’s homeless. In 2012, the Los Angeles CoC received more funding for new projects under this competition than any other Continuum in the nation with seven percent of the total allocation. It also received 36 percent of all new project awards for California—the largest share in the state. Since permanent supportive housing has proven to be the most effective solution in helping to end homelessness for chronically homeless individuals, families and veterans, the Los Angeles CoC projects from this year’s funding source will primarily focus on these groups. Specifically:

. The initiatives will supply approximately 194 new housing units and comprise programs providing long-term rental aid and supportive services like linkages to public benefits, medical and mental health care, and employment assistance. . The Housing Authorities of the City and County of Los Angeles will administer the projects while service agencies will operate the programs.

Homeless Prevention and Rapid Re-Housing Program (HPRP) On August 26, 2009, the City of Los Angeles was awarded $29 million to administer HPRP for a three-year grant period. HPRP was created by the American Recovery and Reinvestment Act (ARRA) of 2009 (H.R. 1). The program is designed to deliver services through two methods: 1) Prevent homelessness; and 2) Rapidly re-house homeless Los Angeles residents. The program requires 60 percent of the funds to be expended by August 26, 2011 and 100 percent of the funds to be expended by August 26, 2012.

Under the homelessness prevention assistance component, very low income renters, who meet program requirements, are facing eviction, and have received a three-day notice to quit or

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page 187 Public Review Draft May 30, 2012 complaint for unlawful detainer from their landlord, are eligible for legal services, supportive services, and financial assistance to help them stay in their homes.

For the rapid re-housing assistance component, homeless individuals and families are eligible for housing location, supportive services, and financial assistance to help them secure and move in to a rental home. Also, very low income homeowners in the City, who are in foreclosure and meet program requirements, are eligible for housing location, supportive services and financial assistance to help them move into a rental home.

LAHD serves as the program fund administrator for HPRP. The citywide partnership for the HPRP Program consists of the following agencies: LAHSA; the Legal Aid Foundation of Los Angeles (LAFLA); LAHSA/Home at Last; Los Angeles Family Housing (LAFH); People Assisting the Homeless (PATH); Special Service for Groups (SSG); HACLA; and four other non- profits with small subcontracts.

As of 2011, a total of $26,426,561 of program funding has been expended. The HPRP program officially ends on August 26, 2012, but it is anticipated that all funds will be expended by June 2012 or earlier. All financial assistance funds have been encumbered and the program stopped enrolling new clients as of September 30, 2011. Continuing clients enrolled before that date are still receiving assistance. LAHSA is preparing a phase-out plan for LAHD’s review, including client termination, assistance and referrals for clients after termination, budget projections and so forth.

The homelessness prevention work supported by the HPRP grant has brought in new partners, primarily legal service providers, and expanded the reach of such activities throughout the City.

Housing Authority of the City of Los Angeles (HACLA) HACLA provides housing assistance to over 3,000 households. HACLA’s overall strategy is to address the needs of the homeless and those at risk of becoming homeless. They complement many of the City’s efforts to address the housing and supportive service needs of the homeless. HACLA has administered various programs for several years, including the Moderate Rehabilitation Single Room Occupancy (MRS) Program, the Shelter Plus Care (S+C) Program and the Section 8 (tenant-based rental assistance and project-based rental assistance) Program.

. Section 8 Moderate Rehabilitation SRO: The goal of this program is to increase the local stock of single room occupancy (SRO) units available for homeless individuals. HUD’s strategy is to provide funding for upgrades to existing distressed housing, such as dilapidated SRO hotels, in order to preserve the supply of affordable and decent units. The Moderate Rehabilitation SRO program targets homeless individuals coming directly from the streets, emergency shelters, or transitional housing. Since 1990, HACLA has secured over $76,548,942 in Section 8 Moderate Rehabilitation funding, totaling more than 1,370 subsidized units.

. Shelter + Care: The Shelter Plus Care (S+C) Program is designed to provide permanent housing combined with supportive services for homeless persons and their families. S+C targets the chronically homeless suffering from mental illness, substance abuse, HIV/AIDS, or some combination of these disabilities, coming directly from the streets,

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emergency shelters, or transitional housing. HUD requires contracted non-profit agencies, termed “sponsors,” to provide supportive services equal to or greater than the aggregate amount of rental assistance awarded. HACLA has participated in the Shelter Plus Care program since 1992, receiving cumulative funding totaling more than $198,203,142 for over 2,501 subsidized units.

. Project-Based Rental Assistance Voucher Program: HACLA also administers the Project-Based Voucher Program in collaboration with other city partners through the Permanent Supportive Housing Program. This program targets homeless individuals and families requiring supportive services. More than1,055 units have been committed to the program.

Neighborhood Stabilization Program (NSP) LAHD initiated the Neighborhood Stabilization Program (NSP) in 2009 with grant funds from HUD to acquire and rehabilitate foreclosed or abandoned residential properties in order to stabilize neighborhoods and stem the decline of house values of neighboring homes. To date, the City has been awarded three NSP grants from HUD:

. NSP 1 for $32.8 million . NSP 2 for $100 million . NSP 3 for $9.8 million

LAHD, through its subrecipient, Restore Neighborhoods LA (RNLA), adopted sustainable building practices and is incorporating responsible “green” building materials in the rehabilitation and restoration of single-family and multi-family NSP properties.

In one of its many efforts to address homelessness, LAHD has partnered with the Los Angeles County Department of Health Services (DHS) to create a pilot project, which links housing units with on-site or mobile delivery of support services in NSP properties. The pilot project, called Direct Access to Housing, will target chronically homeless adults (and in some cases, including their families) and high-users of hospital inpatient and emergency services in permanent supportive housing. The purpose of this project is to improve the health and well being of vulnerable populations living with chronic homelessness, high rates of disability, multiple un- treated health conditions, and early mortality.

Direct Access to Housing is a collaborative effort that not only includes LAHD, RNLA, and DHS, but also supportive services offered by HACLA, the Los Angeles County Department of Mental Health (DMH) and the Los Angeles County Department of Public Health (DPH).

Site Details: . 15 Sites selected in South Los Angeles . Range from 13 unit apartment building to a single-family house, this includes 56 units that can accommodate approximately 60 individuals. . Two of the 15 projects have been completed, with all of the planned projects to be completed and occupied by Fall 2012.

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By using NSP dollars, LAHD is also planning to serve veterans through permanent supportive housing in NSP properties in the near future. New Directions, Inc., a non-profit agency that has been serving veterans through case management, substance abuse treatment, housing and other services for 20 years has been working with LAHD and RNLA. For almost two years, all agencies have been working to acquire 2-4 foreclosed single-family homes in the Pacoima area that will be utilized as rental housing for veterans who have successfully graduated from New Directions’ programs and are ready to move on to independent living.

The permanent supportive housing for veterans will serve disabled veterans, both men and women, with histories of homelessness and chronic homelessness. These individuals may have disabilities, which include war-related physical disabilities like traumatic brain injury, mental health disorders such as PTSD, bipolar disorder and schizophrenia, HIV/AIDS, and chronic substance abuse. The purpose of the program is for New Directions’ Mobile Treatment Team to provide case management, assist veterans in maintaining employment, advancing job skills, and creating a network of support to ensure housing stability.

Site Details: . Single-family homes selected in San Fernando Valley . Program will house 9 clients . Rehabilitation has been completed on one of the projects, and rehab has not yet begun on the other property

Home for Good Plan Launched in November 2010, Home for Good was created by the Business Leaders Task Force, a group of 22 business leaders brought together by United Way of Greater Los Angeles and L.A. Area Chamber of Commerce. The Home for Good Plan is a blueprint to end chronic and veteran homelessness in Los Angeles County by 2016, the intention is to build the most efficient and effective system in the County’s history. Over 100 public sector, non-profit, faith, and philanthropic leaders have signed on to Home for Good. The Los Angeles Housing Department was one of the City agencies that signed on to the Plan in November 2010.

The goals of the Plan are to house the 12,000 chronically homeless individuals and 6,000 newly homeless veterans in the Los Angeles County region. The goals are based on the following principles:

. Everyone deserves a home. . Our homeless neighbors are important members of our communities. . No one should be on the streets or in shelter for a prolonged period of time. . Housing stability is a critical first step on the road to wellness for those who are struggling with substance abuse, mental illness, and chronic health problems.

The key strategies to achieve the Home for Good goals include the following:

1. Align Goals to Integrate our System 2. Collect and Share Data to Assess Need and Track Progress 3. Target and Reallocate Existing Resources to Maximize Impact 4. Coordinate Resources to Streamline Funding

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LAHD has committed to helping fund 250 new and rehab units (of the total 500 new and rehab units committed by the L.A. County) per year (2011-2015) through the Permanent Supportive Housing Program. The LAHD has also committed to setting aside at least 20 percent of all affordable housing funds, including HOME, redevelopment tax increment low-moderate income housing set-aside funds and Neighborhood Stabilization Program funds, for this purpose during the term of the Plan.

Since Round 1 of the 2011 Permanent Supportive Housing Program (PSHP) NOFA, the LAHD has committed $17.8 Million from the Los Angeles Affordable Housing Trust Fund (AHTF) to the PSHP Program. In Round 1, three PSHP projects were new construction, totaling 295 units; in Round 2, two projects (one new construction and one rehab) received a commitment from the AHTF, totaling 64 units. In Round 3, one PSHP project received a commitment for rehab, totaling 34 units. For 2011, LAHD has committed AHTF dollars for the rehabilitation and new construction of 393 PSHP units. The Department has surpassed its 2011 goal by 143 units.

The Year 1, 2011 goal for the Home for Good Plan was to house 840 homeless veterans and 1,700 chronically homeless individuals. To date, 864 homeless veterans and 2,273 chronically homeless individuals have been housed with the support of various service providers, affordable housing developers and finance agencies/departments. The goals set by the Home for Good Plan to house the target population have been surpassed. Due to the powerful partnerships formed throughout L.A. County, over 3,000 veterans and chronically homeless people have been helped out of homelessness during the second year of the Plan’s implementation.

Further information about Home for Good, can be found at www.homeforgoodla.org.

Home for Good Funders Collaborative In 2011, the Home for Good Funders Collaborative was launched. This group was formed in alignment with the Home for Good blueprint. The Collaborative is managed by United Way of Greater Los Angeles and consists of 18 other public and private funders who have committed to support chronically homeless people in moving off the streets and obtaining the necessary services to stay housed. LAHD is one of the public funders in the Collaborative. The Home for Good Funders Collaborative will award funds to qualified applicants in less than six months, and the Collaborative process will streamline housing creation.

The collaborative funding enables public and private funders to layer and blend funding streams through a single application process. The Collaborative released its first Request for Proposals (RFP) on March 14, 2012 representing over $75 million in public and private resources. The Collaborative was seeded by a $1 million gift from the Conrad N. Hilton Foundation, a challenge grant with a 4:1 match requirement to the private sector. In total, private funders will contribute $5 million in funds in its first year, and public funders will distribute $37 million in resources through the RFP and will contribute an additional $33 million in resources following the grant awards in June 2012.

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The public resources include the following:

. A new set aside of 500 tenant-based vouchers over two years from HACLA . 100 tenant-based vouchers over two years from the Housing Authority of the County of Los Angeles (HACoLA) . $10 million in resources from LAHD to support new development of permanent supportive housing . $3.25 million in services support from Los Angeles County Departments . 28 project-based vouchers from the City of Pasadena for new development

Seniors City efforts to address the housing needs and problems of large households include but are not limited to:

. Rent Stabilization Ordinance (RSO), established in 1980, provides for reasonable rent increases and prevent arbitrary evictions. The elderly who have lived in the same homes for many years benefit the most from the limited rent increases allowed by the RSO; it is also why they are often targeted for eviction, so that their units can be rented at higher levels. The RSO Rent Investigators respond to complaints about evictions and unfair practices. . Systematic Code Enforcement Program (SCEP), established in 1998, and housing code complaint program inspects all rental housing in the City except single-family homes and enforces State Health and Safety codes, and lead-safe work practices. . AHTF supports the development of new affordable housing, including senior housing. . Preservation of affordable housing at risk of losing its affordability, particularly that financed by FHA with project-based Section 8 rent subsidies, has been a high priority of LAHD since 1990. This housing provides homes to many of the City’s most vulnerable residents, many of whom have aged in place and/or have disabilities. . The Handyworker Program which provides minor home repairs and accessibility items that enable elderly households and those living with disabilities to remain living independently. . In 2002-3: LAHD, working with the Mayor’s office, then-Councilman Mark Ridley- Thomas and local and national advocates, enabled the City to pass a landmark anti- predatory lending ordinance, which was then killed by a lawsuit from the American Financial Services Association. Many victims of predatory lending were elderly. . Fund a robust Citywide Fair Housing Program

Single Parents From April 2004 through March 2011, HRC has assisted over 3,570 tenants who identified themselves as a female-head of household in the City of Los Angeles.

Disability City efforts to address the housing needs and problems of persons living with disability include but are not limited to:

. Rent Stabilization Ordinance (RSO), established in 1980, provides for reasonable rent increases and prevent arbitrary evictions.

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. Systematic Code Enforcement Program (SCEP), established in 1998, and housing code complaint program inspects all rental housing in the city except single-family homes and enforces State Health and Safety Codes, and lead-safe work practices. . AHTF supports the development of new affordable housing, including supportive housing for persons with disabilities. . Preservation of affordable housing at risk of losing its affordability, particularly that financed by FHA with project-based Section 8 rent subsidies, has been a high priority of LAHD since 1990. This housing provides homes to many of the City’s most vulnerable residents, many of whom have aged in place and/or have disabilities. . The Handyworker Program which provides minor home repairs and accessibility items that enable elderly households and those living with disabilities to remain living independently. . Fund a robust Citywide Fair Housing Program

Please also see above response for “Homeless Persons.”

Persons with HIV/AIDS LAHD has been the recipient of the federal Housing Opportunities for Persons with AIDS (HOPWA) Program grant under the Consolidated Plan since the 1990s. LAHD is the sole recipient of HOPWA funds in the County, and services are provided Countywide. LAHD currently administers the HOPWA Program grant for 26 agencies and four housing authorities. The grant provides housing related supportive services and rental assistance programs to low- income, homeless and at-risk of homeless persons living with HIV/AIDS and their families in the County of Los Angeles.

The AHTF supports the development of new affordable housing, including supportive housing for persons living with HIV/AIDS. The AHTF was established in 2000, but LAHD has financed affordable rental housing supportive to residents living with HIV/AIDS since the 1990s.

Other LAHD programs that support homeless persons living with HIV/AIDS include: the Permanent Supportive Housing Program (PSHP), the RSO and the SCEP.

For Program Year 2011-2012, the City of Los Angeles was awarded $12 million in HOPWA funds through the Consolidated Plan. The HOPWA Program provides funding for a wide range of services, which include the following:

. Emergency, Transitional, and Permanent Housing; . Emergency Hotel/Motel and Meal Vouchers; . Supportive services, such as housing case management, substance abuse counseling, mental health counseling, food services, legal services, service animal support, and others; . A web-based clearinghouse that is specially designed for persons living with HIV/AIDS to locate housing and supportive services; . Housing grants that provide permanent housing placement grants (move-in and 1st month’s rent) and short term rent, mortgage, and utility assistance during times of acute illness or loss of income;

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. Technical Assistance (awarded through a separate Request for Qualifications Process); and . Fiscal Monitoring Services to conduct annual fiscal audits of all HOPWA contractors.

In addition to the services listed above, in PY 2011 2010-2011, $1.8 million of HOPWA funds were allocated to the City’s AHTF. Under the AHTF Notice of Funding Availability (NOFA), developers can apply for the HOPWA funds along with other AHTF funds. When the project is complete, a specific number of affordable units must be set-aside for low-income tenants living with HIV/AIDS. Since 2007, $6.5 million of HOPWA funds have been leveraged with the AHTF and other funds to create 25 new HOPWA units.

The HOPWA Connections program was a separate federal grant of $1.2 million awarded to the City in 2004 by HUD. The grant was renewed in 2008 for an additional $1,430,000 and it expires on October 31, 2012. The purpose of the grant was to provide 18-months of rental subsidies to low-income persons diagnosed with HIV/AIDS who were homeless or at-risk of homelessness. The program was subcontracted to HACLA as the lead agency since after 18-months of Connections rental assistance, clients could apply for a regular Section 8 Housing Choice Voucher. HACLA received all funding except for three percent, which LAHD retained for administrative oversight and reporting. The Connections clients were also provided psycho- social assessments and treatment through the County Office of AIDS Policy and Procedures, which received a separately funded HUD Connections grant. Through the Connections program 183 low income persons diagnosed with HIV/AIDS who were previously homeless or at-risk of homelessness have been provided with permanent housing.

The Los Angeles County-wide HOPWA Advisory Committee (LACHAC) has been in existence since the 1990s, and is a policy body for the HOPWA program. It consists of 20 committee members, including staff from: Los Angeles City Mayor’s Office, Los Angeles County, West Hollywood, Pasadena, Long Beach, HACLA, LASHA, several non-profit organizations that provide housing and supportive services to persons living with HIV/AIDS, an affordable housing developer, and at-large members who are diagnosed with HIV/AIDS. LAHD’s HOPWA unit staffs LACHAC. The full LACHAC meets bi-monthly to discuss HOPWA policy and programs and make recommendations for changes and improvements. LACHAC subcommittees meet more frequently. The LACHAC is governed by By-Laws, which it periodically updates and revises. LACHAC meetings are open to the public and are posted according to the Brown Act. About 40-50 people attend the bi-monthly meetings.

The four selected public housing authorities (PHAs) (one of which is HACLA) carry out the HOPWA Tenant- and Project-Based Rental (T/PBRA) programs. The PHAs provide HOPWA funding for 12 months of tenant- or project-based rental assistance, similar to the Section-8 Housing Voucher and Project-Based Voucher Programs.

The City’s funding of a robust Citywide Fair Housing Program also addresses the housing opportunities for persons with HIV/AIDs.

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Renters with Housing Problems City efforts to address the housing needs and problems of renters with Housing Problems include, but are not limited to:

. Rent Stabilization Ordinance (RSO), established in 1980, provides for reasonable rent increases and prevent arbitrary evictions. . Systematic Code Enforcement Program (SCEP), established in 1998, and housing code complaint program inspects all rental housing in the city except single-family homes and enforces State Health and Safety Codes, and lead-safe work practices. . LAHD established a Compliance Division to increase services to renters and owners and coordination of RSO and SCEP complaints. Additional Housing Investigators were hired, a hearing officer program was expanded, and much effort has gone into more effectively responding to rent or code complaints. . Fund a robust Citywide Fair Housing Program.

Housing affordability is the key problem faced by many renters that makes them subject to the other problems of overcrowding and substandard housing. There are insufficient Section 8 subsidies allocated to the City based on the number of eligible households and the program has been cut continuously since the 1990s. Housing affordability is a difficult problem that has no easy solution.

Furthermore, the foreclosure crisis, starting in 2008, led to the illegal eviction of many renters; it is likely there has been a disparate impact on protected classes. To protect the City’s renters, the LAHD has worked with other agencies to develop the following programs:

. Late 2008, the City Council enacted an eviction moratorium applicable to all residential properties in foreclosure in the City to prevent evictions of tenants, because the banks like to have the properties vacant, since they are easier to sell. This has been renewed annually by the City Council. . In July 2010 the City Council approved establishment of a Foreclosure Registry to require lenders of foreclosed properties to register with the City, to ensure rights of tenants and neighbors are preserved, to prevent blight, and to ensure the ability to contact owners in case of emergency.

HRC HRC Housing Counselors have assisted renters with housing problems in several ways. Housing Counselors provide general information and materials on the California Civil Code and other applicable law, and provide clients with referrals to other organizations or city agencies such as Rent Stabilization or the Health Department when their services are necessary. The Director of Counseling is a certified mediator and has trained his staff to identify areas where an amenable agreement between the tenant or tenant applicant and the housing provider may be reached. Housing Counselors also screen client calls for possible discrimination issues. From April 2004 through March 2011, HRC has assisted over 35,645 Los Angeles City renters with housing problems.

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Impediment #14: Access to Financing

The City has a number of fair housing impediments related to access to financing, including:

. Conventional Home Loan Financing (Income Factors): Loan approval rates generally have a positive correlation to household income. Approval rates were highest among the upper-income applicants and lowest among lower-income applicants. The ability of lower-income households in accessing financing is an ongoing housing affordability issue, but not a fair housing issue.

. Conventional Home Loan Financing (Race/Ethnicity Factors): Conventional home loan approval rates vary across racial and ethnic groups. White, Asian, and Joint applicants had the highest approval rates throughout the City while Black applicants consistently had the lowest approval rates. More importantly, approval rates vary widely among ethnic groups within the same income groups. Black and Hispanic applicants frequently received the lowest approval rates regardless of income.

. Government-Backed Loans: Approval rates for government-backed loans tend to vary among ethnic groups of similar income levels. Overall applications for government- backed loans were relatively low for most ethnicities. One exception is Hispanics who are overrepresented in the applicant pool.

. Lenders: Approval rates differ significantly among lenders in Los Angeles, with the largest discrepancy at 34 percentage points.

. Subprime Lending Activity: High approval rates in the subprime market can sometimes be a cause for concern when the target clients are considered high risk. High approval rates may indicate aggressive lending practices. The report found that loan applicants in the Harbor Area had significantly higher approval rates by subprime lenders than all lenders as a whole. Anecdotal evidence and research indicate that predatory lending is an increasing problem in the Los Angeles area with subprime lenders.

. Purchased Loans: In recent years, the practice of selling mortgage loans by the originators to other lenders is prevalent. Allegations have been made that predatory lending is more likely to occur with this practice. For example, when a lender can reduce or eliminate its risk of lending to lower and moderate income households by immediately selling the loans to another lending institution, it may be more aggressive in lending to households that really cannot afford the mortgage. This practice can be considered a form of predatory lending. Within the City’s Neighborhood Service Areas, the percentage of loans purchased reached as high as 43 percent in the North Valley area. Among racial groups, Blacks had the highest percentage of loans purchased, with 17.1 percent, followed closely by Hispanics with 16.9 percent.

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Efforts/Response

Foreclosures Since early 2009 the LAHD has worked with Neighborhood Legal Services, One-LA and other advocates to create a pilot foreclosure prevention program in the Northeast San Fernando Valley. The program is designed to assist homeowners who qualify under the federal Home Affordable Modification Program (HAMP) to obtain sustainable loan modifications with permanent principal reduction. The City of Los Angeles has committed $1,100,000 to the pilot Foreclosure Prevention Program. Bank of America has committed to participating. In mid 2010, LAHD applied to the State CalHFA, which was receiving TARP funds from the U.S. Treasury, to expand the pilot foreclosure program to other parts of the City. The City received an award of $5 million, and, to date, one bank has agreed to participate.

In 2002-03, LAHD, working with the Mayor’s office, then-Councilman Mark Ridley-Thomas and local and national advocates, enabled the City to pass a landmark anti-predatory lending ordinance. This ordinance was then challenged by a lawsuit from the American Financial Services Association. The State Supreme Court ruled that federal law preempted the City’s ordinance. However, this effort was undertaken precisely because federal law was too weak and did not protect Los Angeles residents from predatory and unsafe subprime lending.

In addition to the efforts described above, Los Angeles has also offered affordable first time homebuyer assistance for many years through participating lenders offering prime (not subprime) loans. This program was designed to educate homeowners as well and homebuyer counseling was a requirement of the program. Information on this program is available on the City’s website.

Impediment #15: Public Policies

The City has a number of fair housing impediments related to public policies, including:

. Capacity to Accommodate Additional Housing: Despite the apparent capacity of the City to accommodate additional housing for all income and special needs groups, a study prepared in 2000 concluded that most of the available development capacity is in small parcels that would be difficult to assemble for feasible residential projects and that differences in building code requirements for commercial and residential development could impede mixed-use projects in commercial areas.

. Zoning Definition of Family: The City’s Zoning Code has a restrictive definition of family. If misused by landlords, managers, and sellers, this definition has the potential to discriminate non-traditional families such as gay and lesbian couples, certain cultures that prefer living with extended family members and friends, or college students living together, etc.

. Regulations Affecting Housing Choice for Special Needs Groups: According to a study prepared for the Los Angeles Housing Department, the City’s zoning code contains several potential impediments to fair housing choice. These potential impediments include definitions affecting occupancy of housing; use definitions; and

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reasonable accommodations for persons with disabilities. Additionally, recovery homes are currently not permitted within 600 feet of a school.

. Section 8 Vouchers: Long waiting periods for assistance are common since demand often exceeds the limited resources available. Given the tight housing market, many rental properties have no problem renting out units at market rents, and the rental prices of those properties continue to rise. The financial incentives to participate in the Section 8 program are less attractive in a tight housing market than in a housing market with high vacancy rates. Primarily in economically depressed neighborhoods, where the housing and neighborhood conditions are less than ideal, would voucher recipients likely find rental units that accept voucher payments. Researchers have also found that owners accepting Section 8 vouchers prefer senior households to families. This practice creates a potential fair housing concern.

. Coordination with Housing Authority: Housing Authority monitors only fair housing issues covered by Federal law. State protected classes are often not listed on Housing Authority materials. There have been complaints that the Housing Authority is non- responsive with regard to fair housing complaints.

Efforts/Response

Capacity to Accommodate Additional Housing Per State law (California Government Code §65583.2), the City of Los Angeles maintains an inventory of undeveloped and under-developed sites upon which the required number of housing units can be built without the need for any discretionary zoning action by the City. In the City’s 2006-2014 Housing Element, the City identified 21,522 sites that have the capacity to accommodate a minimum of 382,851 units.

According to State law, a density of at least 30 units per acre serves as a proxy for identifying sites suitable for affordable housing development. Based on this assumption, of the sites and units identified by the City, 19,949 sites are available for low- or very low-income units.

Redevelopment of under-developed sites is common practice in the City of Los Angeles. It has been found that much of the City’s growth has occurred on sites with existing uses. A City of Los Angeles Department of City Planning (DCP) analysis of two years of building permits demonstrated that 77 percent of all multi-family projects were built on sites that had another use on them.

The City’s 2006-2014 Housing Element also provides key information about density and capacity. The report indicates that while the inventory of sites for residential development shows the capacity for a minimum of 382,851 additional units on 21,523 lots, 57 percent of the units are on 8,092 commercially zoned sites, and 43 percent are on 13,431 residentially zoned sites. Recent trends in development show that much of the housing in Los Angeles is now being built in commercial zones. For example, in 2001, 40 percent of building permits for new multi-family housing in the City were on sites in commercial zones. By 2005, 60 percent of all multi-family housing in Los Angeles was being built on commercially-zoned sites.

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Zoning Definition of Family The City revised the definition of “family” in the Reasonable Accommodation Ordinance (Ord. No. : 177325), which was adopted by the Los Angeles City Council and the Mayor in 2006. The ordinance became effective on March 18, 2006.

Regulations Affecting Housing Choice for Special Needs Groups The LAHD and the City Planning Department worked together to create a reasonable accommodation ordinance, with the guidance of Kim Savage, the author of the 2002 Land Use Impediment Study. Ordinance No. 177325 was approved by the City Council on January 18, 2006 and by the Mayor on February 2, 2006. It became effective on March 18, 2006. The City Council File No. 05-0338 contains relevant reports and shows the approval of the ordinance. The Council File can be accessed at http://cityclerk.lacity.org/lacityclerkconnect/index.cfm

The Zoning Ordinance was also updated to amend its definition of family. The City’s Municipal Code Section 12.03 definition of “family” now complies with fair housing laws. In addition, the City’s Zoning Code does not include occupancy standards for group living facilities.

In addition, recent amendments to the Zoning Code (Section 12.21 A.4 (u)) offer a parking reduction of 25 percent of the Zoning Code requirement for service-enriched housing facilities occupied by disabled persons in the RD, R3, RAS3, RAS4, R5, CR, C1, C1.5, C2, C4, or C5 Zones.

Section 8 Vouchers HACLA has focused on increasing Section 8 use and acceptance by landlords to ensure the success of its Housing Choice Voucher Program. Efforts undertaken by HACLA include:

. Working to improve customer service so that landlords want to rent to Housing Choice Voucher clients . Outreach to landlord associations . Housing search assistance to help voucher-holders with disabilities succeed in locating a unit.

HACLA’s Conventional Application Center is responsible for receiving and processing applications, determining eligibility, and providing applicant referrals to different developments for leasing. The conventional public housing program is open to receiving applications on an on-going basis. Interested persons can obtain and complete an application at the Application Center or request an application by telephone. Applications are also available for pick up at any HACLA public housing site during normal business hours and online at www.hacla.org/apply-public-housing. Once received, the application is date and time- stamped and the applicant information is input into the HACLA computer system.

Applicants are scheduled for interviews based on application date and current preference. Eligibility is determined by meeting established income guidelines and other HUD requirements. These guidelines and requirements include, but are not limited to, non-citizen rule requirements, criminal background checks and records of meeting financial obligations. Meeting established eligibility requirements allows the applicant to be place on a Certified Waitlist for housing offers. All protected classes receive offers based on the same system.

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Coordination with Housing Authority The Section 8 Department at HACLA engages in fair housing activity as it relates to HACLA’s primary goal of housing low and very low-income families. Information concerning fair housing issues is provided orally at Owner’s Orientation sessions. Additionally, information is also provided in the “Partners in Housing” booklet for owners. Information for Section 8 participants is also provided in the “Applicant and Participant Information” booklet. The U.S. Department of Housing and Urban Development (HUD) complaint form is given to all Section 8 participants at voucher issuance sessions. This complaint form is available in English, Spanish, Korean, and Russian, and it includes the state protected classes.

HACLA investigates any complaints of employee-related discriminatory actions and takes action as appropriate. When the charges are outside of the organization, staff will assist clients to complete the HUD complaint form or refer the client to the HUD toll-free complaint line.

In 2005, Section 8, HACLA Planning Department staff and disability advocates collaborated on developing a presentation to explain Section 8 department program rights and responsibilities to participants with disabilities. The Section 8 Department also provides a resource brochure for persons with disabilities, posts listings of rentals with modifications for individuals with disabilities on the Socialserve website (www.socialserve.com) and provides ombudspersons to assist individuals with difficulty accessing the program. An individual may file a formal written grievance regarding denial of a reasonable accommodation or discrimination by HACLA staff, based on disability, to be investigated by a Section 504/ADA Coordinator.

Impediment #16: Fair Housing Services

The City has a number of impediments related to fair housing services, including:

. Need for Expanded Capacity: The City’s geography and dense population make outreach and assistance to all residents difficult. Los Angeles is one of the most diverse and multicultural cities in the country, and has seen significant growth, particularly in the two Neighborhood Service Areas of San Fernando Valley. The community outreach meetings conducted for the report revealed that residents are oftentimes simply unaware of their rights and do not know where to begin when they feel they have been discriminated against. There appears to be a need for additional fair housing service capacity in order to reach more residents and provide more comprehensive service.

. Need for Increased Assistance to Homebuyers: Fair housing services often focus more on the rental market and less on the home purchase market. According to HRC statistics, 89 percent of the calls for general and fair housing inquiries received in FY 2004/05 came from in-place tenants. Although the majority of housing discrimination cases typically arise from rental situations, there are indications that potential homebuyers have experienced discrimination as well, as discussed in the report.

. Limited Number of Fair Housing Service Providers: Only three fair housing service providers serve the entire County of Los Angeles – Housing Rights Center, Fair Housing Council of San Fernando Valley, and Fair Housing Foundation. With a population of over 9,500,000 residents, significant burdens are placed on these three agencies.

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Efforts/Response

HRC is one of the largest fair housing organizations in the country and is the largest in the state of California. HRC has mobilized a highly effective and diverse staff of 25 individuals reflective of the communities they serve. They have the capacity to provide fair housing services in eight languages in addition to English: Armenian, Cantonese, Korean, Mandarin, Russian, Spanish, Tagalog, and American Sign Language. They also communicate with deaf or hearing-impaired clients through TTY (213.201.0867), sign language interpreters, and e-mail. All of HRC’s offices are accessible to people with disabilities.

HRC has also established a robust website to provide the public with both general information on fair housing issues and online access to our services. HRC recently concluded a comprehensive upgrade of its website to include new interactive features designed to provide the public with richer fair housing content, more efficient 24-hour access to HRC’s Counseling Department, improved hosting, and an overall look and feel designed to draw traffic to the site and further HRC’s image as a trusted provider of fair housing services.

HRC’s service area includes Los Angeles and Ventura Counties including the cities of: Alhambra, Baldwin Park, Carson, El Monte, Glendale, Glendora, Hawthorne, Inglewood, Lancaster, Los Angeles, Montebello, Monterey Park, Oxnard, Palmdale, Pasadena, Pico Rivera, Pomona, Redondo Beach, Rosemead, San Buenaventura, Simi Valley, West Covina, and Whittier. Through a unified contract with the County of Los Angeles we serve the cities of Agoura Hills, Arcadia, Avalon, Azusa, Bell, Bell Gardens, Beverly Hills, Bradbury, Calabasas, Cerritos, Claremont, Commerce, Covina, Cudahy, Culver City, Diamond Bar, Duarte, El Segundo, Hawaiian Gardens, Hermosa Beach, Irwindale, La Canada/Flintridge, La Habra Heights, La Mirada, La Puente, La Verne, Lawndale, Lomita, Malibu, Manhattan Beach, Maywood, Monrovia, Rancho Palos Verdes, Rolling Hills, Rolling Hills Estates, San Dimas, San Fernando, San Gabriel, San Marino, Santa Fe Springs, Sierra Madre, Signal Hill, South El Monte, South Pasadena, Temple City, Torrance, Walnut, West Hollywood, Westlake Village, and unincorporated areas of the county, including but not limited to areas of Altadena, Canyon Country, Castaic, East Los Angeles, Hacienda Heights, La Crescenta-Montrose, Lennox, Marina Del Rey, Rowland Heights, South San Gabriel, Topanga Canyon, Walnut Park, and Willowbrook. Through a unified contract with the County of Ventura, HRC also serves the cities of Camarillo, Fillmore, Moorpark, Ojai, Port Hueneme, Santa Paula and Thousand Oaks, and unincorporated areas of the county.

HRC investigates housing discrimination complaints brought under both State and Federal fair housing laws. From July 1, 2010 to June 30, 2011, HRC received 1,564 housing discrimination inquiries. They opened and thoroughly investigated 443 housing discrimination cases. In HRC’s investigations of these 443 cases, the Agency found sufficient evidence of discrimination to warrant enforcement activity in 62 percent of cases. HRC successfully conciliated 35 percent of its cases, which typically meant that the clients were able to retain their housing.

From July 2002 to June 2011, HRC has handled 4,622 fair housing cases, and conducted 652 phone tests, 775 on-site tests and 10,231 surveys. HRC has litigated 123 fair housing cases since 1999 with almost one-fifth of those cases (20 cases) being filed in 2011 to date. HRC currently files approximately two fair housing cases per month in federal and/or state court.

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The Fair Housing Foundation (FHF) and the Fair Housing Council San Fernando Valley (FHCSFV) also have several decades of experience in providing direct client services, counseling, investigations, and resolutions of client complaints alleging violations of law or regulations, and an extensive education and outreach program. In fiscal year 2010-11, FHF opened 110 fair housing cases for South Los Angeles residents and conducted 33 tenant surveys in that region.

FHCSFV has conducted more than 4,100 tests and 1,900 surveys. They have trained more than 795 volunteers. Since 2002, FHCSFV has received 4,020 discrimination inquiries and has fully investigated 1,958 of these complaints.

City of Los Angeles Page 202 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 Chapter 7: Fair Housing Action Plan

A. Impediments and Actions

This section presents a list of impediments and key actions to address these impediments:

. Modified: Represents an impediment that is carried over from previous AI reports but is modified to reflect current conditions and efforts.

. New: Represents an impediment that was not specifically identified or addressed in the previous AI reports.

Impediment #1: Housing Discrimination (Modified)

Disability, familial status, and race are the leading factors for discrimination in Los Angeles. Based on the Housing Rights Center’s (HRC) annual reports from 2004 to 2011, African Americans represent a significant portion of clients served by HRC, which indicates African Americans may be disproportionally impacted by fair housing issues. As result, there is a need to expand the housing choices of persons with disabilities, people with children, and minorities.

Timeframe, Funding, and Responsible Actions Agency LAHD’s Occupancy Monitoring/Compliance Unit offers an Timeframe: Ongoing Owner and Property Management Orientation (training schedule pattern: December and January, April and May, Funding: Departmental budget August and September, etc.) to those who have five or more HOME-funded units in projects that are at 75 percent Agency: LAHD completion/ prior to building lease-up. The training topics include a discussion about the following requirements:

. Fair Housing: Owners/managers of HOME-assisted housing are to comply with all fair housing laws, which prohibit discrimination against the protected classes: o Accessibility: Accessible units in HOME-assisted properties must be offered first to persons with disabilities. o Reasonable Accommodation Requests: Housing providers are required to make reasonable accommodations and allow person(s) with a disability(ies) to make reasonable modifications of the premises.

. Affirmative Marketing Plan: Targeted marketing to those least likely to apply and agencies that serve

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Timeframe, Funding, and Responsible Actions Agency populations with disabilities and non-English speakers; at the time of application, ask prospective tenant about his/her special needs (e.g., allow space for applicant to specify type of disability).

. Wait List: Both a general “wait list” and an “accessible wait list”(for those with vision/hearing/mobility needs) are to be maintained for prospective tenants.

. Tenant Selection Policy: This is to include the following: o Objective selection criteria; o Notification process; o Waiting list policy; o Vacancy policy; and o Confirmation that owner, property manager, or any other agent will not refuse to lease to a Section 8 voucher recipient who has met the selection criteria.

Impediment #2: Lack of Outreach and Information Provided to Landlords and Renters (Modified)

Many residents and rental property owners/managers often express concerns that the City demonstrates a bias towards one group over the other. There have also been allegations of housing discrimination against Housing Choice Voucher holders from participants of community meetings. Specifically, many feel that they are not receiving the same treatment from landlords/managers because they use vouchers for rent payments. Reduction of service (lack of repairs) is a primary complaint from voucher holders.

LAHD is responsible for enforcing the Rent Stabilization Ordinance (RSO) and Code Enforcement Program to ensure the safety and livability of neighborhoods. As LAHD implements critical City ordinances and programs to limit and prevent the occurrence of issues like no-fault evictions, illegal rent increases, and uninhabitable living standards, the City faces accusations of behaving unfairly, not acting in the public’s best interest and not equipping City residents with proper information/resources. A community outreach plan is needed to address the concerns of both landlords and renters.

As a recipient of HUD funds, HACLA is also required to actively further fair housing choice: 1) by assessing potential impediments to fair housing; 2) taking actions to address impediments identified; and 3) maintaining fair housing records. HACLA participated in the preparation of this AI.

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Timeframe, Funding, and Responsible Actions Agency After conducting a Request for Proposals (RFP) process, Timeframe: Research completed LAHD selected Stephen Groner and Associates (SGA) to develop a strategy for how to approach a comprehensive Funding: Departmental budget community outreach program, which includes traditional grassroots with media relations for LAHD’s RSO and Code Agency: LAHD Enforcement program.

In order to properly develop a program for LAHD, SGA conducted research to understand the barriers and motivators that need to be addressed for LAHD’s target audiences. Therefore, SGA evaluated a study about the L.A. Housing market (developed and released by LAHD), which served as the leverage for completing the following:

. Creation of Surveys (Administered by LAHD Staff): These surveys provided more insight on various issues including landlords’ and tenants’ preferred methods of communication, reasons for proactively reaching out to LAHD, language preferences and public perceptions of LAHD resources.

. Media Coverage Analysis: This analysis revealed that LAHD’s visibility in the media has been limited in recent years. In addition, there has not been any coverage highlighting LAHD as a resource for landlords or tenants.

The majority of communications strategies and tactics put forth by SGA for the plan originated from research and reflects Los Angeles’ landlord and tenant audiences. The plan was completed in May 2011. Implementation of the plan is a work in progress for LAHD; Timeframe: In progress several outreach components have already been implemented. LAHD has held Landlord-Tenant Workshops Funding: Departmental budget during 2011. Agency: LAHD . The 2011 schedule included topics such as: “Security Deposits & Interest on Security Deposits,” “RSO Basics: Everything You Need to Know about the LA Rent Stabilization Ordinance,” “RSO Allowable Rent Increases: When Can Rents be Raised and by How Much?” and many others.

. LAHD has also scheduled 2012 workshops, a few of the topics include: “Understanding Your Bill,” RSO

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Timeframe, Funding, and Responsible Actions Agency Basics & Updates-What’s New for 2012,” and “Allowable Rent Increases in LA RSO, Including Capital Improvements & Rehabilitation Work Increases.”

LAHD is still in the process of implementing and planning for additional initiatives. LAHD will coordinate with HACLA to provide fair housing Timeframe: In progress information: Funding: Departmental budget . Coordinate the distribution of fair housing materials that cover not only the federal but also the State Agencies: LAHD; HACLA protected classes; and

. Arrange with the fair housing service providers to offer fair housing education workshops with Section 8 and public housing residents.

Impediment #3: Access to Financing (Modified)

Minority households, particularly Black and Hispanic households, tend to have more limited access to financing compared to other households. Loan approval rates for Black households are usually significantly lower than other households even in the same income groups. A significant proportion of minority households rely on lesser known lending institutions for financing. Households in South Los Angeles areas consistently have lower approval rates than households in other NSAs.

Timeframe, Funding, and Responsible Actions Agency LAHD will take a number of actions to expand access to Timeframe: Ongoing financing: Funding: None Required . LAHD will work with federal agencies to obtain data and reports on financing to various minority groups. Agencies: LAHD; HRC

. Monitor HMDA data to identify specific lenders with potential unfair lending practices.

. Contact local banks to discuss findings of HMDA analysis.

. Require lenders participating in City-funded projects to demonstrate fair lending practices.

. Target outreach to minority households regarding

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Timeframe, Funding, and Responsible Actions Agency new federal initiatives such as the Home Affordable Modification Program (HAMP) for foreclosure protections.

Impediment #4: Predatory Lending (Modified)

While predatory lending for home purchase seems to have decreased due to the current depressed housing market, there is a re-emerging trend of predatory lending activities in the home improvement arena. Elderly and minority households are targeted for unnecessary home repairs and scammed to acquire expensive loans with unfair loan terms. Due to these issues and the high rate of foreclosures in Los Angeles, the City must assist borrowers with counseling and prevention efforts.

Timeframe, Funding, and Responsible Actions Agency On December 2, 2011, the City completed the final approval Timeframe: In Progress process for accepting $5 million in CalHFA MAC Innovation Funds. The funds will be used for foreclosure prevention Funding: CalHFA and to convert principal forbearance on a non-HAMP loan modification to principal forgiveness. Of the $5 million total, Agency: LAHD $4.5 million will be used for program funding and $500,000 will be used to administer the grant. Eligible homeowners will receive a grant totaling up to $50,000 per household. Outreach will be conducted by Los Angeles Neighborhood Legal Services. To date, one lender, One West Bank, has committed to participate in the program.

In the next five years, LAHD will continue to:

. Work with housing counseling agencies throughout the City who educate prospective home buyers about the home purchase process. LAHD has executed a Memorandum of Understanding (MOU) with six HUD-certified housing counseling agencies to provide an 8-hour home buyer education training course to home buyers who will be applying for LAHD home purchase assistance loans. LAHD is currently in the process of adding another HUD- certified home buyer education provider (Home Preservation & Prevention, HPP Cares). Some federal and state funding sources that LAHD utilizes for its home buyer programs require that the home buyers receive this type of education training and part of the home education training curriculum may include predatory lending awareness/prevention and other

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Timeframe, Funding, and Responsible Actions Agency fair housing awareness.

The list of approved homebuyer education providers that LAHD has executed an MOU with are: East LA Community Corporation (ELACC), Korean Churches for Community Development (KCCD), Los Angeles Neighborhood Housing Services (LANHS), New Economics for Women (NEW), Shalom Center, and West Angeles Community Development Corporation (WACDC).

. Work with housing advocates to lobby for stronger State legislation to curb predatory lending.

Impediment #5: TODs and Gentrification (New)

Transit Oriented Developments (TOD) have a gentrifying impact on existing neighborhoods, replacing the existing older but affordable housing with new high-cost units. As a result, lower and moderate income and primarily minority households are displaced from TOD areas, not able to enjoy the benefits offered by such developments.

Timeframe, Funding, and Responsible Actions Agency LAHD recently commissioned a report about massive transit Timeframe: Ongoing infrastructure investment and preserving affordable housing in TOD areas/neighborhoods. The report has been Funding: John D. and Catherine completed by Reconnecting America, the only national T. MacArthur Foundation (for nonprofit effort funded by Congress to promote best report written by Reconnecting practices in transit-oriented development. The report is America) entitled: Preservation in Transit-Oriented Districts: A Study on the Need, Priorities, and Tools in Protecting Assisted and Agency: LAHD Unassisted Housing in the City of Los Angeles.

In the report, Reconnecting America provides empirical evidence showing the need for affordable housing preservation near transit. The report also reflects the use of data to analyze maps and develop a framework for preservation of various types of income restricted housing near transit.

LAHD, in collaboration and participation with the Southern California Association of Governments (SCAG) as the lead applicant for the six-county region, applied to HUD for FY2011 Sustainable Communities Regional Planning Grant Program (SCRP Grant). Los Angeles City, through the

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Timeframe, Funding, and Responsible Actions Agency LAHD as the lead for the Los Angeles County Region Consortium, played a critical role in the preparation of the application with partners at SCAG and the Los Angeles County Consortium. The Los Angeles County Consortium for Sustainable and Equitable Communities was comprised of the LAHD; the Los Angeles Department of City Planning; the Los Angeles County Department of Regional Planning; the Los Angeles County Department of Public Health; LA Metropolitan Transportation Authority (METRO); Enterprise Community Partners; Reconnecting America, MoveLA; and the Low Income Investment Fund and the California Community Foundation. The SCRP’s goals and objectives consisted of supporting metropolitan and multi-jurisdictional planning efforts that integrate housing, land use, economic and workforce development, transportation, and infrastructure investments in a manner that empowers jurisdictions to consider the interdependent challenges of: (1) economic competitiveness and revitalization; (2) social equity, inclusion, and access to opportunity; (3) energy use and climate change; and (4) public health and environmental impact.

Although SCAG, and the other partner departments/ agencies were not awarded funding from HUD, LAHD continues to collaborate with the members of the L.A. County Region Consortium on other citywide TOD related projects (i.e., pursue funding/grant options and legislative improvements).

The LAHD, through the Affordable Housing Trust Fund (AHTF), has made available additional financial incentives for projects being developed in City defined priority areas that further the City’s housing goals. These areas include Transit Oriented Developments.

Since 2008, the AHTF has offered a 5 percent TOD subsidy boost over the basic loan limits to 9 percent tax credit projects to make the applications more competitive at the State level. An AHTF TOD-eligible proposed project must be part of a transit-oriented development located within one-quarter mile from a Transit. As of September 2011, 66 AHTF-funded properties and 4,370 AHTF-funded units are located within half a mile from a TOD.

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Impediment #6: Discriminatory Advertising (New)

Online advertising is a popular means of advertising homes for sale and for rent. However, review of 2,000 for-sale and for-rent ads in the month of February 2012 indicate a significant portion of these ads contain potentially discriminatory language.

Timeframe, Funding, and Responsible Actions Agency LAHD will undertake the following actions to reduce Timeframe: Ongoing discriminatory advertising: Funding: None required . LAHD is currently a member of the Southern California Fair Housing Advertising Task Force, along Agency: LAHD with other participants, which include: the Apartment Association of Greater Los Angeles, the California Department of Fair Employment and Housing, the City of Lakewood, the Fair Housing Council of Orange County, the Fair Housing Foundation, the Housing Rights Center, the Los Angeles Times, the San Diego Fair Housing Council, the San Fernando Valley Fair Housing Council and the U.S. Department of Housing and Urban Development (HUD). The purpose of the Fair Housing Advertising Task Force is to inform and educate all housing related industries, media groups and the general public about Federal and State Fair Housing Laws and Guidelines to prevent and discourage housing discrimination.

The Los Angeles Times convenes quarterly meetings with members of the Task Force to discuss topic items such as posting of common fair housing questions and answers in the classified section of the LA Times and online rental sites; upcoming fair housing events/conferences; new State and Federal laws; and sharing of various other fair housing related information.

. In addition, as an LAHD practice, the department actively markets low and moderate income housing opportunities citywide. It also requires owners and developers of multi-family housing who receive financial assistance from the City to develop an affirmative marketing plan consistent with the Department’s requirements. The marketing plan, subject to approval by LAHD, must contain specific procedures to inform and solicit applications from persons in a specific housing market area who are not

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Timeframe, Funding, and Responsible Actions Agency likely to apply without special outreach. Overall, the goal of the plan is to promote equal housing choices for prospective purchasers or tenants.

. LAHD also uses the following affirmative marketing procedures to advertise programs, funding availability, and to solicit bids and requests for proposals: Advertisements in Los Angeles newspapers with citywide circulation, newspapers with a target audience (i.e., newspapers that reach Spanish or Korean speakers), community meetings, newsletters, special workshops, notices on the City’s and LAHD’s websites, and special meetings.

. LAHD will continue to provide information about the department’s training opportunities, which include fair housing education to property owners/managers who have five or more HOME-funded units in projects that are at 75 percent completion and prior to their building lease- up.

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A. Summary of Outreach Process

The City of Los Angeles Analysis of Impediments to Fair Housing Choice (AI) has been developed through a collaborative process including participation of residents, service providers, and City staff. The primary methods utilized to collect input for the AI included:

1. Consultation Meetings

Meetings were held at LAHD facilities to solicit input from local service providers and representatives from neighboring jurisdictions. This process aimed at reaching agencies that engage lower-income persons and those with special needs to supplement the survey and public meetings associated with the AI preparation.

Table A-1: Consultation Meetings Agency Date Invitees Participants February 7, 2012 9:00-11:00 A.M. Housing Advocate Agencies 3 Realtors, Homebuyer Education Organizations, and Apartment 1:00-3:00 P.M. Associations 3 February 8, 2012 CBOs, City Council Offices/Mayor's Office, Government Offices, and Various 9:00-11:00 A.M. L.A. City Departments 5

Meeting Participants

Representatives from the following agencies and organizations attended the consultation meetings:

. Bet Tzedek Legal Services . California Apartment Association (CAA) . The City of Los Angeles Commission on the Status of Women . Community Actively Living Independent & Free (CALIF) . Housing Rights Center of Southern California (HRC) . Los Angeles County Human Relations Commission . Inner City Law Center . International Realty Investment . Law Offices of Hollenbeck & Cardoso, LLP . Legal Aid Foundation of Los Angeles (LAFLA) . Office of the Mayor of the City of Los Angeles . Urban Housing Solutions Inc.

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Key Fair Housing Issues Identified

Key fair housing issues identified during the consultation meetings are summarized below:

. Housing discrimination persists: Most frequent bases for discrimination are disability, race, gender, and familial status. Often, both the tenants and landlords misunderstand the rights and responsibilities offered under reasonable accommodation. Other emerging trends include discrimination based on immigration status and source of income.

. Lack of accessible units: There is a general shortage of accessible units. Furthermore, units are often advertised as accessible, but do not meet accessibility requirements. Even many architects and builders do not seem to fully understand accessibility requirements.

. Gentrification caused by transit-oriented development (TOD): TOD has led to an increase in interest in renting in these transitioning neighborhoods. Some property owners are illegally evicting low-income tenants so they can rent the unit at a higher rent. The State Legislature approved a law that expedited the CEQA process for Farmers Field (the site for the new football stadium in downtown Los Angeles), which some housing advocates claim that may give the public less opportunity to comment on the potential impact of the development.

. Home improvement and foreclosure scams: There is a re-emerging trend of homeowners being victimized by home improvement and foreclosure scams. Seniors and minority households are usually the target.

. Affordable housing lottery: The City and owners of affordable housing developments should conduct more outreach to advertise affordable housing lotteries. Some community and faith-based groups are better at organizing their constituencies to participate in the lottery than others.

2. Public Meetings

Meetings were held on five different dates throughout various sectors of the City. These meetings were held jointly with the City’s Community Development Department and Commission on Community and Family Services. At the meetings, the public was introduced to the AI process and asked to discuss community needs in regards to fair housing issues.

City of Los Angeles Page A-2 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012

Table A-2: Public Meetings Date and Time Location Public Participants Central City Neighborhood Wednesday, February 1, Central/Downtown Partners 2012 26 Los Angeles 501 South Bixel Street 6:00 pm - 7:30 pm Los Angeles, CA 90017 Bradley Milken Family Source Thursday, February 2, 2012 Center Watts/South Los Angeles 4 6:00 pm - 7:30 pm 1773 E. Century Boulevard Los Angeles, CA 90002 Sunland-Tujunga Municipal Thursday, February 9, 2012 Building North Valley 19 6:00 pm - 7:30 pm 7747 Foothill Boulevard Tujunga, CA 91402 Boyle Heights Technology Youth Wednesday, February 22, Center 2012 East Los Angeles 23 1600 E. 4th Street 6:00 pm - 7:30 pm Los Angeles, CA 90033 West Los Angeles Municipal Thursday, February 23, Building 2012 West Los Angeles 22 1645 Corinth Avenue 6:00 pm - 7:30 pm Los Angeles, CA 90025

Meeting Participants

Aside from interested individuals, several service providers and housing professionals participated in the fair housing public meetings, including:

. Center for the Pacific Asian Family . ResCare Arbor, LLC . Rainbow Services . 1736 Family Crisis Center . Fair Housing Council of San Fernando Valley . Jewish Family Services of Los Angeles . Los Angeles Congress of Neighborhoods . Neighborhood Legal Services of Los Angeles County . Thai Community Development Center . Haven Hills, Inc. . Los Angeles Center for Law and Justice . Union de Vecinos . Housing Authority of the City of Los Angeles (HACLA) . Housing Rights Center . East L.A. Community Corporation (ELACC) . Realtor, Century 21 . Field Representative, Assembly Member Holly Mitchell . The Eberly Company (LAHD’s Rent Escrow Account Program (REAP) Outreach Contractor)

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-3 Public Review Draft May 30, 2012

Key Issues Identified

In reviewing the comments received at these meetings, which represent the public’s perception of City resources, programs, and initiatives, several key issues were noted:

. Lack of awareness of available services: More effort is needed from the City to make residents aware of available resources. A key component is integration between agencies. In light of budget cuts and the economy, it is important for agencies to integrate their services in order to better leverage the limited resources.

. Need for elderly and disabled services: Seniors and disabled individuals often have minimal income and limited physical ability. The amount of available resources can be overwhelming and intimidating; a welcoming service environment is needed so that they feel inclined to take advantage of resources.

. Lack of communication between landlords and property management: On-site management may be engaging in acts of discrimination against current tenants and future applicants without a property owner’s awareness.

. Need for landlord and tenant rights training: Landlords and tenants often seek guidance only when a problem is encountered. Instead, preventive education of fair housing laws should be made more readily available.

. Unfair treatment of tenants: Landlords and property management take advantage of tenants in situations such as repair requests and legal problems.

. Discrimination against applicants: Discrimination is prevalent based on race, familial status, income, disability, gender, citizenship status, or income.

. Lack of proper guidance from LAHD: Displacing residents from housing without assistance is not strengthening communities, but unfairly placing people out on the streets.

. Concern regarding the City’s Proposed Community Care Facilities Ordinance: This proposed ordinance redefines “family” as a single housekeeping unit and seeks to limit the number of oral or written leases to only one lease per single-family home in the R-1 and R-2 zones.

. Lack of affordable housing: Affordable housing is unevenly distributed in the City and funding cuts have made it much more difficult to develop affordable housing.

3. Fair Housing Survey

The Fair Housing Survey was prepared to complement the public meeting efforts. The survey sought to gain knowledge about the nature and extent of fair housing issues experienced by residents of Los Angeles. The survey consisted of twelve questions designed to compile

City of Los Angeles Page A-4 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 information on a person’s experience with fair housing issues and perception of fair housing issues in his/her neighborhood. A copy of the survey is included as Appendix A.

The survey was made available in English, Spanish, Armenian, and Korean and distributed via the following methods:

. Posted on the City of Los Angeles Housing Department’s website; . Distributed to participants at all public meetings; and . Solicited the participation of service providers to also post the survey link on their websites and distribute surveys directly to their clients.

Since the survey sample was not controlled, results of the survey are used only to provide insight regarding fair housing issues, but cannot be treated as a statistically valid survey.1 Additionally, fair housing is a complex issue, in which case a survey of this nature can only explore the perception of housing discrimination, but cannot be used as evidence of actual discrimination.

Who Responded to the Survey?

A total of 114 Los Angeles residents responded to the Fair Housing Survey, including residents living in various parts of the City. A majority of survey respondents (72 persons, representing approximately 65 percent) felt that fair housing discrimination was not an issue in their neighborhoods and they have not personally experienced fair housing issues. Of the 114 respondents, 79 persons noted that they were renters, while 35 of the respondents stated that they owned their homes.

Who Do You Believe Discriminated Against You?

Of those respondents indicating fair housing is an issue (35 percent), a majority (79 percent, 27 persons) felt they were discriminated against by a landlord or property manager, while 12 percent (four persons) identified a City/County staff person as the source of discrimination. Potential responses were not mutually exclusive; respondents had the option of listing multiple causes of discrimination.

Where Did the Act of Discrimination Occur?

Among the persons indicating that they had experienced housing discrimination, 65 percent (20 persons) indicated that the incident occurred in an apartment complex. Approximately 23 percent (seven persons) indicated that the incident occurred in a single-family neighborhood, and 13 percent (four persons) indicated that it took place in a public/subsidized housing development.

1 A survey with a “controlled” sample would, through various techniques, “control” the socioeconomic characteristics of the respondents to ensure that the respondents are representative of the general population. This type of survey would provide results that are statistically valid but much more costly to administer.

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-5 Public Review Draft May 30, 2012

Table A-3: Location of Discrimination Number of Percent Respondents Apartment Complex 20 65% Single-Family Neighborhood 7 23% Public/Subsidized Housing Project 4 13% When Applying to a City/County Program 3 10% Condo Development 0 0% Total Number of Respondents for Question 31 --- Source: City of Los Angeles Fair Housing Survey, 2012. Notes: 1. Categories are not mutually exclusive. 2. Survey respondents were not required to provide answers for every question; therefore, total responses will vary by question.

On What Basis Do You Believe You Were Discriminated Against?

Of the people who felt they were discriminated against, 47 percent (16 persons) indicated that they believed the discrimination was based on race, 33 percent (11 persons) believed it was based on source of income, and 21 percent (eight persons) believed it was based on age. Additionally, 24 percent (eight persons) identified some other basis of discrimination, such as a having pets or removing old tenants for a higher price. Other responses included family status, color, disability, gender, national origin, marital status, religion, and sexual orientation.

Table A-4: Basis of Discrimination Number Percent Race 16 47% Source of Income 11 33% Other 8 24% Age 8 24% Family Status 5 15% Disability 3 9% Religion 3 9% Gender 2 6% Marital Status 2 6% Color 1 3% National Origin 1 3% Sexual Orientation 1 3% Ancestry 0 0% Total Number of Respondents for Question 34 --- Source: City of Los Angeles Fair Housing Survey, 2012. Notes: 1. Categories are not mutually exclusive. 2. Survey respondents were not required to provide answers for every question; therefore, total responses will vary by question.

City of Los Angeles Page A-6 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012

Requests for Reasonable Accommodations

Among the persons indicating that they had experienced housing discrimination, 17 percent (five persons) indicated that they had been denied “reasonable accommodation” in rules, policies, or practices for their disability. Of the five respondents, one person specifically indicated denial for a request to continue living on the premises with elder support services, including home visits, cleaning assistance, and social worker monitoring.

Why Did You Not Report the Incident?

Of the survey respondents who felt they were discriminated against, only 28 percent reported the discrimination incident. Many of the respondents who did not report the incident indicated that they did not know where to report the incident (60 percent, or 12 persons), or they did not believe reporting would make a difference (45 percent, or nine persons); 40 percent (eight persons) felt it was too much trouble. Another 20 percent (four persons) were afraid of retaliation.

Table A-5: Reasons for not Reporting Discrimination Number Percent Don't know where to report 12 60% Don't believe it makes a difference 9 45% Too much trouble 8 40% Afraid of retaliation 4 20% Total Number of Respondents for Question 20 --- Source: City of Los Angeles Fair Housing Survey, 2012. Notes: 3. Categories are not mutually exclusive. 4. Survey respondents were not required to provide answers for every question; therefore, total responses will vary by question.

What Was the Basis of the Hate Crime Against You or in Your Neighborhood?

Of all respondents completing the survey, 19 percent (20 persons) indicated that a hate crime had been committed in their neighborhood. Of these 20 respondents, 16 persons indicated one or more causes for the hate crime. About 75 percent (12 persons) indicated that the hate crimes were based on race, 31 percent (five persons) indicated color, and 25 percent (four persons) indicated religion. Other causes of the reported hate crimes included national origin, ancestry, sexual orientation, source of income, gender, age, and homelessness.

4. Public Review of Draft AI

The Draft AI was made available for a 30-day public review from May 30, 2012 to June 30, 2012 accessible online at http://lahd.lacity.org and at http://www.lacity.org, as well as at the Los Angeles Housing Department’s First Floor Public Counter (Garland Center, 1200 West 7th Street, 1st Floor, Los Angeles, CA 90017), Monday-Friday, 9:00 am to 4:00 pm.

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-7 Public Review Draft May 30, 2012 B. Consultation Meetings

The following pages contain the outreach list and sign-in sheets for the consultation meetings. Almost 200 agencies and organizations were invited to attend the consultation meetings. Agencies invited include housing professionals, City/County departments, service providers, and fair housing advocates. Comments received have been summarized in the earlier sections.

City of Los Angeles Page A-8 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012

Table A-6: Master Distribution List for AI Consultation Meetings Organization Contact and Title Address City ZIP Telephone Number Los Angeles City Council and Mayor’s Offices Guadalupe Duran- 1) CD1 - Ed R. Reyes Media, Housing CITY HALL - RM 410 Los Angeles 90012 213-473-7001 Deputy Karo Torossian, 2) CD2 - Paul Krekorian CITY HALL - RM 425 Los Angeles 90012 213-473-7002 Housing Deputy Jonathan Brand, 3) CD3 - Dennis Zine CITY HALL - RM 450 Los Angeles 90012 213-473-7003 Housing Deputy Sharon Shapio, 4) CD4 - Tom LaBonge CITY HALL - RM 480 Los Angeles 90012 213-473-7004 Housing Deputy Christopher Koontz, 5) CD5 - Paul Koretz CITY HALL - RM 440 Los Angeles 90012 213-473-7005 Housing Deputy Miguel Franco, 6) CD6 - Tony Cardenas CITY HALL - RM 455 Los Angeles 90012 213-473-7006 Housing Deputy Ackley Padilla, 7) CD7 - Richard Alarcon CITY HALL - RM 470 Los Angeles 90012 213-473-7007 Housing Deputy Purvi Doshi, Housing 8) CD8 - Bernard C. Parks CITY HALL - RM 460 Los Angeles 90012 213-473-7008 Deputy Marie Rumsey, 9) CD9 - Jan Perry CITY HALL - RM 420 Los Angeles 90012 213-473-7009 Housing Deputy Andrew Westall, 10) CD10 - Herb J. Wesson, Jr. CITY HALL - RM 430 Los Angeles 90012 213-473-7010 Housing Deputy Laura McLennan, 11) CD11 - Bill Rosenthal CITY HALL - RM 415 Los Angeles 90012 213-473-7011 Housing Deputy Phyllis Winger, 12) CD12 - Mitch Englander CITY HALL - RM 405 Los Angeles 90012 213-473-7012 Housing Deputy Sarah Dusseault, 13) CD13 - Eric Garcetti Policy Advisor CITY HALL - RM 475 Los Angeles 90012 213-473-7013 (Housing Deputy) Erik Sanjurjo, Housing 14) CD-14 Jose Huizar CITY HALL - RM 465 Los Angeles 90012 213-473-7014 Deputy Gordon Teuber, 15) CD-15 Joe Buscaino CITY HALL - RM 435 Los Angeles 90012 213-473-7015 Housing Deputy

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-9 Public Review Draft May 30, 2012

Table A-6: Master Distribution List for AI Consultation Meetings Organization Contact and Title Address City ZIP Telephone Number Larry Frank, Deputy OFFICE OF THE MAYOR Mayor of 16) CITY HALL - RM 303 Los Angeles 90012 213-922-9741 Antonio R. Villaraigosa Neighborhood & Community Services Rafael Gonzalez, Associate Director of 6501 Fountain Ave. M: 323-957-6332 17) HOLLYWOOD FIELD OFFICE Los Angeles 90028 Neighborhood & MAIL STOP: 370 D: 213-922-9768 Community Services Ricardo Hong, Associate Director of 638 S. Beacon St. 18) SAN PEDRO CITY HALL San Pedro 90731 213-732-4630 Neighborhood & MAIL STOP: 370 Community Services Brenda Anderson, MARK RIDLEY THOMAS Associate Director of 8475 S. Vermont Ave. M: 323-789-1405 19) CONSTITUENT SERVICE CENTER Los Angeles 90044 Neighborhood & MAIL STOP: 291 D: 323-789-2796 (SOUTH L.A.) Community Services Angelica Ayala, East Valley Director of 14410 Sylvan St., 2nd Fl. 20) VAN NUYS CITY HALL Van Nuys 91404 818-778-4990 Neighborhood & MAIL STOP: 922 Community Services Joseph Hari, West LA 21) WEST LA FIELD OFFICE 7166 W. Manchester Ave. Los Angeles 90045 310-479-3823 Area Director Government Offices William "Bill" Vasquez, HUD - U.S. DEPARTMENT OF Director, Office of 22) HOUSING AND URBAN 611 W. Sixth St., Ste. 1100 Los Angeles 90017 213-534-2551 Community DEVELOPMENT Development HUD – LOS ANGELES OFFICE OF David Quezada, 23) FAIR HOUSING AND EQUAL 611 W. Sixth St., Ste. 1100 Los Angeles 90017 213-534-2600 Driector OPPORTUNITY U.S. DEPARTMENT OF VETERANS Nikki T. Baker, Public VA GREATER LOS ANGELES 24) Los Angeles 90073 310-268-3340 AFFAIRS Affairs Specialist 11301 Wilshire Blvd., 6th Fl.

City of Los Angeles Page A-10 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012

Table A-6: Master Distribution List for AI Consultation Meetings Organization Contact and Title Address City ZIP Telephone Number CITY HUMAN RELATIONS Patricia M. Villasenor, City Hall, Room 2111 25) Los Angeles 90012 213- 978-1660 COMMISSION Director 200 North Spring Street COMMISION ON THE STATUS OF Victoria Minetta, 200 N. SPRING STREET, 213-978-1675 26) Los Angeles 90012 WOMEN Acting Director Room 2111 27) DEPARTMENT OF AGING Veronica Sanchez 580 Wilshire Blvd., Suite 300 Los Angeles 90010 213-252-4097 DEPARTMENT OF PUBLIC SOCIAL 28) Karmen Babayan 2855 E. Olympic Blvd. Los Angeles 90023 323-260-3585 SERVICES HOUSING AUTHORITY OF THE CITY Peter Lynn 29) 2600 Wilshire Blvd Los Angeles 90057 213-252-2500 OF LOS ANGELES (HACLA) Carlos VanNatter LOS ANGELES HOMELESS 30) Beth Stokes 811 Wilshire Blvd Los Angeles 90017 213.683-3333 SERVICES AUTHORITY (LAHSA) Los Angeles City Departments David Lara, Chief DEPARTMENT OF BUILDING AND 201 N. Figueroa St., 10th Fl. D: 213-482-6717 31) Public Information Los Angeles 90012 SAFETY MAIL STOP: 115 C: 213-792-6060 Officer COMMUNITY DEVELOPMENT Lisa Salazar, Acting 32) DEPARTMENT (CDD) 1200 W. 7th St., 6th Fl. Los Angeles 90017 213 744-7191 Chief "Family Source Centers" Ralph Acuna, 201 N. Figueroa St., Ste. 100 33) DEPARTMENT ON DISABILITY (DOD) Information & Referral Los Angeles 90012 213-202-2748 MAIL STOP: 760 Coordinator DEPARTMENT OF NEIGHBORHOOD Gracye Liu, Senior 334-B E. Second St. 34) EMPOWERMENT -- "Neighborhood Los Angeles 90012 213-485-1822 Project Coordinator MAIL STOP: 968 Councils" LOS ANGELES POLICE DEPARTMENT Sgt. Ralph Morales, 100 W. First St. D: 213-486-6010 35) (LAPD) Los Angeles 90012 Community Relations MAIL STOP: 400 M: 213-486-6000 Community Police Stations Andrea Epstein, Acting Public LOS ANGELES RECREATION & 221 N. Figueroa St., 7th Fl. EA: 213-202-2690 36) Information Director Los Angeles 90012 PARKS MAIL STOP: 62521 JB: 213-202-2699 c/o Joanna Bernie, Clerk Typist

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-1 Public Review Draft May 30, 2012

Table A-6: Master Distribution List for AI Consultation Meetings Organization Contact and Title Address City ZIP Telephone Number Housing and Community Based Organizations Gabriel McGowan, 37) APLA - AIDS PROJECT L.A. Director of 3550 Wilshire Blvd., Ste. 330 Los Angeles 90010 213-201-1521 Communications CALHFA - CALIFORNIA HOUSING Kenneth Giebel, 100 Corporate Pointe, Ste. 38) Culver City 90230 310-342-1215 FINANCE AGENCY Director of Marketing 250 JEWISH FAMILY SERVICES OF LOS Nancy Volpert, Public M: 213-761-8800 39) 6505 Wilshire Blvd, Ste. 500 Los Angeles 90048 ANGELES Relations D: 213-260-7906 KCCD - KOREAN CHURCHES OF Hyepin Im, President 40) 3550 Wilshire Blvd., Ste. 736 Los Angeles 90010 213-985-1500 x208 COMMUNITY DEVELOPMENT & CEO NEW - NEW ECONOMICS FOR Bea Stotzer, Executive 41) 530 S. Boyle Ave. Los Angeles 90017 213-483-2060 x106 WOMEN Director Marybeth Larkin, Co- 42) ONE LA - IAF 515 W. 27th St. Los Angeles 90007 213-743-0005 executive Director Gordon Langlois, 43) OPERATION HOPE, INC. Communications 707 Wilshire Blvd., Ste. 3030 Los Angeles 90017 213-891-2900 Manager Robin Moreno, 44) PROJECT SAVING GRACE 1718 N. Cherokee Ave., Ste. B Los Angeles 90028 323-957-6487 Executive Director SCANPH - SOUTHERN CALIFORNIA Robert Dhondrup, 45) ASSOCIATION OF NONPROFIT Director of 501 Shatto Pl., Suite 403 Los Angeles 90020 213-480-1249 x237 HOUSING Communications SOUTH LA CRA OF THE CITY OF LOS Carolyn Hull, Regional 46) 4401 Crenshaw Blvd. Los Angeles 90043 323-290-2820 ANGELES Administrator Taulene Kagan, UNITED WAY OF GREATER LOS 47) Director of 1150 S. Olive St., Ste. T500 Los Angeles 90015 213-808-6436 ANGELES Communications Blair Taylor, President 48) LA URBAN LEAGUE (Headquarters) 3450 Mt. Vernon Dr. Los Angeles 90008 323-299-9660 & CEO VERMONT SLAUSON ECONOMIC Marva Smith Battle- 49) 1130 W. Slauson Ave. Los Angeles 90044 323-753-2335 DEVELOPMENT Bey, President & CEO WACDC - WEST ANGELES Robert Norris, Chief 50) 6028 Crenshaw Blvd. Los Angeles 90043 323-751-3440 x29 COMMUNITY DEVELOPMENT CORP Operations Officer

City of Los Angeles Page A-12 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012

Table A-6: Master Distribution List for AI Consultation Meetings Organization Contact and Title Address City ZIP Telephone Number WATTS/CENTURY LATINO Arturo Ybarra, 51) 10360 Wilmington Ave. Los Angeles 90002 323-564-9164 ORGANIZATION Executive Director Ruth Hern, Executive 52) YWCA OF GREATER LOS ANGELES 3345 Wilshire Blvd., Ste. 300 Los Angeles 90010 213-251-1325 Asst. to CEO Hollywood Senior Center-Armenian ShirleyAnn Hoffasker, 53) 1360 North St. Andrews Place Los Angeles 90028 (323) 957-3900 Services Director 54) Jewish Family Service of Los Angeles Ely Vitzer 6505 Wilshire Boulevard #500 Los Angeles 90048 (323) 761-8800 55) Korean American Coalition Grace Yoo 3540 Wilshire Blvd #911 Los Angeles 90010 (213) 365-5999 Heejoo Yoon, 56) Korean Resource Center 900 S Crenshaw Blvd Los Angeles 90019 (323) 937-3718 Program Director 57) Korean Youth & Community Center Julissa Flores 680 South Wilton Place Los Angeles 90005 (213) 365-7400 Pam Marx, (213) 389-2077 ext. 58) Mental Health Advocacy Services, Inc. 3255 Wilshire Blvd. #902. Los Angeles 90010 Supervising Attorney 12 59) Los Angeles Gay and Lesbian Center Christian Calle 1625 Schrader Boulevard Los Angeles 90028 (323) 993-7400 60) Community Coalition Joanne Kim 8101 S Vermont Ave Los Angeles (323) 750-9087 Favian Gonzalez, Stratejic Actions for a Just Economy 61) Organizing 152 W 32nd St Los Angeles 90007 (213) 745-9961 (SAJE) Coordinator Disability Organizations CALIF - Community Actively Living Reginald Robinson, 62) Independent & Free (Central Los 634 S. Spring St., 2nd Fl. Los Angeles 90014 213-627-0477 Housing Coordinator Angeles) CRS - Community Rehabilation Services Elizabeth Jimenez, 4716 Cesar E. Chavez Ave. 63) Los Angeles 90022 323-266-0453 x220 (East Los Angeles) Outreach Coordinator Building A WCIL - Westside Center for Independent 64) Living Jeff Michelson 12901 Venice Blvd. Los Angeles 90066 310-390-3611 x227 (West Los Angeles) ILCSC - Independent Living Center of Norma Vescovo, 65) 14407 Gilmore St., Suite 101 Van Nuys 91401 818-785-6934 Southern California (Van Nuys) Executive Director Roxy Ortiz, ELARC - Eastern Los Angeles Regional 626-299-4700 66) Information & Training 1000 S. Fremont Ave. Alhambra 91802 Center 626-299-4817 Specialist

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-1 Public Review Draft May 30, 2012

Table A-6: Master Distribution List for AI Consultation Meetings Organization Contact and Title Address City ZIP Telephone Number Diane Campbel 213-383-1300 67) Frank D. Lanterman Regional Center Anand, Executive 3303 Wilshire Blvd., Ste. 700 Los Angeles 90010 FL: 213-252-4902 Director SCLARC - South Central Los Angeles Dexter Henderson, 68) 650 W. Adam Blvd., Ste. 200 Los Angeles 90007 213-744-700 Regional Center Executive Director Michael Danneker, 5901 Green Valley Circle, Ste. 69) WRC - Westside Regional Center Los Angeles 90230 310-258-4000 Executive Director 320 70) PAWS LA Steve Wayland 1150 S Hope St Los Angeles 90015 213-741-1950 Korean Health Ed & Info Research Kirby Van Amburg, 3727 West 6th Street, Suite 71) Los Angeles 90020 213-427-4001 Center (KHEIR) Project Manager 210 Apartment Associations The Apartment Association of Greater Jim Clark, Executive 621 South Westmoreland 72) Los Angeles 90020 (213) 384-4131 Los Angeles (AAGLA) Director Avenue California Apartment Association/Los Ryan Minnear, 320 North Larchmont 73) Los Angeles 90004 (213) 481-7416 Angeles Executive Director Boulevard Minority Apartment Association 74) Malcolm Bennett 1215 South Western Avenue Los Angeles 90040 323-754-2818 International Realty & Investments Apartment Owners Association of Neffertti Solis-Bradley, 75) 5455 Wilshire Blvd., #1009 Los Angeles 90036 (323) 937-8811 California Manager Banks/Lenders/Realtors 76) Altera Home Loans Hector Amendola (562) 646-7320 77) Bank of America Brad Meyer 120 Vegis Ste 410 Aliso Viejo 92656 (949) 244-0941 78) Best Capital Funding Mike Yates 6930 Owensmouth Canoga Park 91303 (818) 887-2779 Westlake (805) 494-9930 ex 79) 2239 Townstead RD. Ste 205 91361 Elite Financial Michael Kagan Village 112 80) Golden Empire Mortgage Roberta Berthold 2233 Honolulu Ste 305 Montrose 91020 (818) 541-9214 81) iMortgage Rurik Madrid N/A (818) 943-0980 82) International City Mortgage David McMahon 367 E. Albertoni St. Ste#104 Carson 90742 (310) 502-6355 83) New Century Real Estate Angiloo Grecia N/A (424) 240-4638 84) Skyline Financial Gino Fronti N/A (818) 652-9739 85) Surety Financial Services Craig Kovler N/A (818) 219-1211

City of Los Angeles Page A-14 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012

Table A-6: Master Distribution List for AI Consultation Meetings Organization Contact and Title Address City ZIP Telephone Number 86) Union Bank Shonta Clark 8513 W. Venice Los Angeles 90034 (424) 354-7411 87) Wells Fargo Home Mortgage Deborah Kristianto 355 E. Rincon St. Corona 92879 (951) 271-5427 88) Wells Fargo Home Mortgage Steve Anderson N/A (661) 299-2790 Homebuyer Education Organizations East LA Community Corporation Maria Cabildo, 89) 530 South Boyle Avenue Los Angeles 90033 (ELACC) President (323) 604-1958 Korean Churches for Community Dev Eunice Program (213) 985-1500 90) 3550 Wilshire Blvd., Suite 922 Los Angeles 90010 (KCCD) manger ext.215 LA Neighborhood Housing Services 91) 3926 Wilshire Blvd., Suite 200 Los Angeles 90010 (LANHS) Lory Gay (213) 381-2862 (213) 483-2060 ext. 92) New Economics for Women (NEW) Maggie Cervantes 303 Loma Drive Los Angeles 90017 305 or Cell 818-625- 6059 93) Shalom Center Jee Lee 2975 Wilshire Blvd., Suite 415 Los Angeles 90010 (213) 380-3700 West Angeles Comm. Dev. Corp. (323) 751-3440 ext. 94) Los Angeles 90043 (WACDC) Twnua Thrash 6028 Crenshaw Blvd. 29 Fair Housing Advocates 95) Bienestar Human Services Silvia Valerio 5326 E. Beverly Blvd. Los Angeles 90022 (323) 727-7896 Patricia A. Van 96) Bet Tzedek Legal Services 145 S. Fairfax Ave, Suite 200 Los Angeles 90036 (323) 939-0506 Dyke,Staff Attorney (213) 617-4914 or 97) Chinatown Service Center Liz Dyer 767 N. Hill Street, Suite 400 Los Angeles 90012 (213) 808-1700 98) Coalition of Econimic Survival Larry Gross 514 Shatto Place, Suite 270 Los Angeles 90020 (213)252-4411 99) Eviction Defence Network Joanne Melgar 1930 Wilshire Blvd, Suite 208 Los Angeles 90057 213-385-8112 Fair Housing Council San Fernando Sharon Kinlaw & 100) 8134 Van Nuys Blvd # 206 Panorama City 91402 (818) 373-1185 Valley Diana Bruno 101) Fair Housing Foundation Maria Benitez 4401 Crenshaw Blvd., Ste 317 Los Angeles 90043 323-295-3302 David Huezo, Director 102) Housing Rights Center 520 S Virgil Ave Ste 400 Los Angeles 90020 (213) 387-8400 of Counseling

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-1 Public Review Draft May 30, 2012

Table A-6: Master Distribution List for AI Consultation Meetings Organization Contact and Title Address City ZIP Telephone Number Adam Murray, Executive Director 103) Inner City Law Center 1309 East 7th Street Los Angeles 90021 213) 891-2880 Marcy Gribin, Staff Attorney Los Angeles Community Action Network 104) Steve Diaz 530 S. Main Street Los Angeles 90013 213-228-0024 (LACAN) Fernando Gaytan, 105) Legal Aid Foundation Of Los Angeles 1102 Crenshaw Boulevard Los Angeles 90019 (323) 801-7991 Attorney Gladys La Torre, 303 N. Glenoaks Blvd., Suite 106) Living Independently in LA Burbank 91502 1-800-806-1191 Supervising Attorney L-130 Gladys La Torre, 107) Los Angeles Center For Law & Justice 2606 E 1st St Los Angeles 90033 213-266-2690 Supervising Attorney 108) MALDEF David D. Fugueroa 634 S. Spring St. Los Angeles 90014 (213) 629-2512 109) Menorah Housing Foundation Dawn Beebe 10991 West Pico Boulevard Los Angeles 90064 (310) 475-6083 Neighborhood Legal Services of Los Jennifer Phan, 7515 Van Nuys Blvd., 5th 110) Van Nuys 91405 (818) 947-4026 Angeles County Attorney Floor 111) Public Counsel Shashi Hamuman 610 South Ardmore Avenue Los Angeles 90005 (213) 385-2977 Groups Media 112) LA Times LeaAnn Tercero

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City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-17 Public Review Draft May 30, 2012

City of Los Angeles Page A-18 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012 C. Public Meetings

The City conducted community meetings to collect information and solicit input regarding community needs and priorities. Discussion regarding fair housing and barriers and impediments to fair housing choice throughout the City was also planned. The meetings consisted of two presentations by staff to introduce the aims of both the Consolidated Plan and the AI. Public participation and comment was scheduled following the presentations. Below are notes taken of the public comments that were presented during the meetings. Summarized notes from the meetings are included in the AI.

Central/Downtown Los Angeles Community Meeting Date: Wednesday, February 1, 2012 Time: 6:00 to 7:30 P.M. Location: Central City Neighborhood Partners, 501 South Bixel Street Los Angeles, CA 90017

Public Comments:

. More information is needed from the City to communicate about services available to residents struggling to find housing. . Integration of services is a key component of creating effective efforts to aid residents. In light of budget cuts and the economy it is more important than ever for agencies to be collaborative and connect residents to service providers that can ultimately help them. For example, it’s important for people who run Work Source and Family Source Centers to know who to call in order to in order to connect residents to the appropriate agency, especially to housing services.

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Watts/South Los Angeles Community Meeting Date: Thursday, February 2, 2012 Time: 6:00 to 7:30 P.M. Location: Bradley Milken Family Source Center, 1773 E. Century Blvd. Los Angeles, CA 90002

Public Comments:

. On-site property management may be enacting regulations not authorized by landlord. In some cases of discrimination projected by management it is not known or supported by landlords. A participant portrayed an example of the issue, in which the manager of the apartment complex she lived in was accepting extra payments under the table from Hispanic applicants who wished to bypass a waiting list. Such problems are rampant throughout the City and allow discrimination to go unchecked. . Programs that work with victims of domestic violence work with clients to find solutions as to what can be done after they receive 30 days of help. In some cases they may receive Section 8 housing support, but it is often hard to find landlords that accept it. Overall the barriers are incredible and the continuing budget cuts are a definite concern.

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City of Los Angeles Page A-22 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012

North Valley Community Meeting Date: Thursday, February 9, 2012 Time: 6:00 to 7:30 P.M. Location: Sunland-Tujunga Municipal Building, 7747 Foothill Blvd. Tujunga, CA 91402

Public Comments:

. Family Source Centers are an integral part of communities and serve to infuse money into the City. When partnered up the LAHD Family Source Centers have been effective in aiding with foreclosure prevention throughout the City. With the budget reductions that are scheduled to occur it is key to look at services that are not performing as well anymore. . Projects outlined within the Consolidated Plan should be examined and supported for their value in contributing to the development of affordable housing throughout the City. . Opposition to affordable housing develops when projects are uncompleted as scheduled do to the depletion of funding. Such projects become a blithe to the neighborhoods in which they are abandoned. . Concern with the amount of funding allocated to housing development as with the increase in foreclosure and the amount of people who moved out of the cities there are already many vacant properties. The focus should not be on building housing, such as projects for homeless, but on other community improvements. . More outreach to neighborhood councils is needed to promote community support of the development of services available. Utilize the councils to have a more proactive role throughout the communities they serve. . The City needs to be conscious of its revenues and expenditures. Code enforcement violations that displace people from their place of residency can create a budget expenditure problem for the City to provide homeless shelters. . Senior and disabled residents often struggle to support themselves as they have little income and ability and may feel that they impose when services are provided. The amount of resources available to them can be overwhelming. An increase in the amount of outreach to them about the services that are directly allocated towards them is necessary to dispatch any intimidation that they may have. . Efforts need be made by the City to accommodate people who cannot find housing such as people who are released early from state prisons, have mental or physical disabilities, no income, etc. The City needs to better address how it plans to deal with these populations increasing as a housing component and how it can do so while not overwhelming the systems of services it already has in place. . Applicants are often discriminated against in the process of trying to obtain a place of residency. The participant portrayed two examples in which first he was discriminated against as an applicant because he had two children and second a friend of his was discriminated against because of his race. It makes many residents uncomfortable in approaching the process of trying to find a place to live when these biases are so prevalent.

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-23 Public Review Draft May 30, 2012

. Continued support for domestic violence services is important to serving the population of those who are abused. Programs target the rebuilding of their clienteles’ economic independence and self-sufficiency, which often involves finding a place of residency. . Funding that enables the most at-risk of domestic violence victims to become survivors is crucial to serving the population and keeping them from becoming homeless. . Domestic violence service agencies often encounter the issue in which a client must go back to living with the batterer or becoming homeless. These programs are a cost effective way to battle domestic violence household problems that may further develop into larger community issues. . Domestic violence services serve as the first intervener in addressing appropriate housing, appropriate solutions, and transitional housing. Collaboration efforts need to be made to direct people to correct services. . Cases in which LAHD kick people out of residencies without providing any assistance or additional time to figure out an alternative solution are not acts of neighborhood improvement. These instances do not strengthen communities, but only create more work for people to aid that are in need. . Concern about the Community Care Facility ordinance as a serious impediment to fair housing, which is currently before the PLUM Committee. . There is need for domestic violence services to be as minimally impacted by funding cuts as possible. The participant expressed disappointment that HOME secure funding was eliminated by the department and that is has not gone unnoticed.

City of Los Angeles Page A-24 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-25 Public Review Draft May 30, 2012

East Los Angeles Community Meeting Date: Wednesday, February 22, 2012 Time: 6:00 to 7:30 P.M. Location: Boyle Heights Technology Youth Center 1600 E. 4th Street Los Angeles, CA 90033

Public Comments:

. Not a lot of affordable housing has been seen in the area. More development needs to be constructed that is within reach of the medium income residents of the community. This will also serve to help realtors sell properties. . A large problem within the Latino community is that they have a tendency to not put money in the bank, which is an issue when they attempt to purchase a home as they qualify, but struggle to receive assistance with down payment programs. Educating residents to save at least some money in the bank, which will help them get into such a program and into an affordable home, is crucial. . Landlords often take advantage of tenants when involved in legal disputes by retracting their initial legal claims only to eventually re-submit a claim against a tenant. It is harassment and a form of discrimination that needs to be addressed. . A lot of discrimination is often experienced by residents in neighborhoods where Hispanic persons of low-income live, in which it is difficult for them to acquire a living place that is in good condition. Landlords often show a lack of interest in addressing issues raised by tenants and when they respond to LAHD orders it is not always done to the best of their abilities. Overall, discrimination is prevalent and the landlords have an advantage over tenants in many situations. . The Affordable Housing Trust Fund has been essential in building affordable housing and funding cuts will make it much more difficult to accomplish. The participant gave an example in which upon recently opening a waiting list for a project over 1,500 applicant requests were received for only 40 units of housing. The demand for affordable housing cannot be stressed enough, especially within the Boyle Heights area.

City of Los Angeles Page A-26 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-27 Public Review Draft May 30, 2012

West Los Angeles Date: Thursday, February 23, 2012 Time: 6:00 to 7:30 P.M. Location: West Los Angeles Municipal Building 1645 Corinth Ave. Los Angeles, CA 90025

Public Comments:

. Concern brought forward from a housing management representative about the legal rights of persons with disabilities and how to address potential abuse of those rights. The participant gave an example of a multitude of tenants receiving questionable legal notes from a medical professional in order to bring a pet into a housing unit. Concern was also raised as to what rights are applicable in situations when tenants with mental health issues, who are not fit to live independently, are no longer provided full support after service agencies withdraw care. . The LAHD does not have appropriate leadership and lacks ability and oversight to have efficient dialogue with people who provide housing. The same can be said of the LA Housing Authority. Code inspections protocol at LAHD should be eliminated as it is operated by unqualified representatives who violate the Department of Building and Safety every time they issue a citation. . The RSO needs to be revised so they can get more people to build housing. It needs to be questioned how it is going to be possible to keep the 630,000 units under the RSO intact when utility costs are on the rise. . There is nothing more important than helping the homeless as they are people who have fallen during hard-times. The City needs to investigate how it can utilize the thousands of acres of vacant land it owns into a resource for future projects for the homeless. . Bootleg units should be granted amnesty, which will allow such tenants to obtain a building permit and construct an actual safe and functional structure. Doing so will allow people of lower-income to legally maintain a much cheaper place of residency. . The LAHD does not effectively service residents to the best of its abilities in dealing landlord-tenant disputes. It is not an agency that residents prefer to seek help from. . Concern brought up in which landlords often figure out what fair housing is after complaints are made against them and it is only then that they are provided opportunity for training. . Need for tenant education in regards to what appropriate interactions between them and property management and owners consists of and also what expectations they should have as far as services and accommodation that occur. . In order to protect property management and owners during housing inspections, tenant education is needed to teach what living conditions are acceptable and unacceptable. . Concern brought forward as to the clustering of affordable housing developments throughout the City. The participant wants to ensure that as a result of this study low- income people have access to housing in a variety of areas in the City and not just specific neighborhoods.

City of Los Angeles Page A-28 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-29 Public Review Draft May 30, 2012

Public Notifications

Two fliers were developed that served as the primary tool for announcement purposes. The first flier promoted the meetings held on February 1, 2, and 9 of 2012 and the second flier detailed the meetings held on February 22, and 23 of 2012. The fliers were posted online at various websites: . LAHD . City of Los Angeles (under the “events” calendar) . Distributed through the Community Development Department’s network (e.g. Family Source Centers) . Councilmember Rosendahl’s Facebook page

Hard-copies of the fliers were made available at multiple locations throughout the City: . LAHD offices located near the public meeting sites (e.g. the West Office and East Office) . LAHD Affordable Housing Commissioners . CD11 West Los Angeles Office . Various community centers and sites located within the vicinity of the meeting locations . The Boyle Heights Technology Youth Center

Additional outreach to advertise the meetings included an email blast to LAHD’s landlord and property owner e-mail lists (e.g. AAGLA, CAA, etc.) and over 100 agencies and individuals from LAHD’s contact lists (i.e. council offices and Mayor’s Office, city departments, community-based organizations, legal aid agencies, disability assistance organizations, banks, lender, realtors, etc.).

City of Los Angeles Page A-30 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-31 Public Review Draft May 30, 2012

City of Los Angeles Page A-32 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012

D. Fair Housing Survey

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City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-35 Public Review Draft May 30, 2012

City of Los Angeles Page A-36 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-37 Public Review Draft May 30, 2012

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City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-39 Public Review Draft May 30, 2012

City of Los Angeles Page A-40 Analysis of Impediments to Fair Housing Choice 2012 Public Review Draft May 30, 2012

City of Los Angeles Analysis of Impediments to Fair Housing Choice 2012 Page A-41 Public Review Draft May 30, 2012

City of Los Angeles Page A-42 Analysis of Impediments to Fair Housing Choice 2012 Appendix B: Home Mortgage Disclosure Data (HMDA)

The following HMDA tables were developed utilizing software from the LendingPatterns.com program: All Neighborhood Service Areas FFIEC-Style Summary Spreadsheet

Total Applications (1) Originated (2) Approved Not Accepted Denied (3) Withdrawn / Incomplete Count % Amount % Units % Dollar $(000) % Count % Amount % Count % Amount % Count % Amount % Loan Purpose and Type

Purchase - Conven 22,699 - 10,132,916 - 13,968 - 6,298,539 - 2,002 - 905,575 - 3,469 - 1,439,132 - 3,260 - 1,489,670 -

Purchase - Govern 12,285 - 3,884,548 - 7,469 - 2,437,263 - 844 - 246,348 - 2,248 - 676,756 - 1,724 - 524,181 -

Home Improvemen 3,257 - 1,024,855 - 1,470 - 654,201 - 161 - 45,488 - 1,064 - 183,820 - 562 - 141,346 -

Refinancing 77,515 - 32,275,589 - 43,822 - 18,176,915 - 4,305 - 1,786,403 - 16,523 - 7,020,503 - 12,865 - 5,291,768 - Applicant Race

American Indian/A 808 - 209,841 - 408 - 112,238 - 51 - 11,284 - 186 - 42,598 - 163 - 43,721 -

Asian 11,410 - 3,920,112 - 6,817 - 2,307,334 - 840 - 297,150 - 2,064 - 729,804 - 1,689 - 585,824 -

Black or African Am 4,468 - 1,229,339 - 2,228 - 598,983 - 261 - 74,850 - 1,211 - 315,671 - 768 - 239,835 -

Hawaiian / Pacific 766 - 240,796 - 429 - 135,547 - 36 - 12,982 - 189 - 54,645 - 112 - 37,622 -

White 73,392 - 29,171,323 - 43,720 - 17,046,201 - 4,772 - 1,913,690 - 14,212 - 5,824,139 - 10,688 - 4,387,293 -

2 or More Minority 108 - 31,955 - 46 - 12,392 - 3 - 813 - 36 - 12,390 - 23 - 6,360 -

Joint Race (White/ 2,189 - 919,577 - 1,434 - 597,774 - 99 - 43,766 - 370 - 153,345 - 286 - 124,692 -

Race Not Available 22,615 - 11,594,965 - 11,647 - 6,756,449 - 1,250 - 629,279 - 5,036 - 2,187,619 - 4,682 - 2,021,618 - Applicant Ethnicity

Hispanic or Latino 19,084 - 4,739,013 - 10,128 - 2,552,289 - 1,393 - 334,884 - 4,592 - 1,115,144 - 2,971 - 736,696 -

Not Hispanic or Lat 73,577 - 30,651,495 - 44,335 - 17,994,435 - 4,649 - 2,000,513 - 13,746 - 5,969,447 - 10,847 - 4,687,100 -

Joint (Hisp/Lat / N 2,185 - 816,495 - 1,360 - 495,968 - 115 - 44,606 - 404 - 156,757 - 306 - 119,164 -

Ethnicity Not Availa 20,910 - 11,110,905 - 10,906 - 6,524,226 - 1,155 - 603,811 - 4,562 - 2,078,863 - 4,287 - 1,904,005 - Minority Status

White Non-Hispani 53,818 - 23,860,608 - 32,986 - 14,098,763 - 3,346 - 1,539,398 - 9,730 - 4,627,406 - 7,756 - 3,595,041 -

Others, Including H 39,780 - 11,777,306 - 22,172 - 6,624,371 - 2,718 - 800,851 - 8,777 - 2,515,708 - 6,113 - 1,836,376 - Applicant Income

Low (0-49% of Me 4,017 - 730,214 - 1,629 - 276,312 - 176 - 26,291 - 1,556 - 311,066 - 656 - 116,545 -

Moderate (50-79% 9,954 - 1,918,556 - 4,991 - 924,503 - 684 - 122,887 - 2,664 - 561,417 - 1,615 - 309,749 -

Middle (80-119% 20,311 - 5,007,668 - 11,440 - 2,777,023 - 1,402 - 334,945 - 4,352 - 1,139,389 - 3,117 - 756,311 -

Upper (>=120% o 73,512 - 34,804,913 - 44,273 - 20,387,822 - 4,750 - 2,347,443 - 13,032 - 6,562,992 - 11,457 - 5,506,656 -

Income Not Availa 7,962 - 4,856,557 - 4,396 - 3,201,258 - 300 - 152,248 - 1,700 - 745,347 - 1,566 - 757,704 - Tract/BNA Characteristics

Substantially Minor 54,379 - 15,750,916 - 29,707 - 8,932,844 - 3,529 - 979,525 - 12,171 - 3,314,326 - 8,972 - 2,524,221 -

Not Substantially M 61,377 - 31,566,992 - 37,022 - 18,634,074 - 3,783 - 2,004,289 - 11,133 - 6,005,885 - 9,439 - 4,922,744 -

Low (0-49% of Me 4,691 - 1,476,932 - 2,270 - 881,466 - 316 - 72,260 - 1,250 - 305,317 - 855 - 217,889 -

Moderate (50-79% 20,031 - 5,369,355 - 10,545 - 2,919,674 - 1,333 - 350,067 - 4,888 - 1,250,480 - 3,265 - 849,134 -

Middle (80-119% 30,276 - 9,909,368 - 17,311 - 5,804,766 - 1,934 - 626,961 - 6,160 - 1,929,677 - 4,871 - 1,547,964 -

Upper (>=120% o 60,747 - 30,557,229 - 36,602 - 17,960,612 - 3,729 - 1,934,526 - 11,000 - 5,833,163 - 9,416 - 4,828,928 -

NA 11 - 5,024 - 1 - 400 - 0 - 0 - 6 - 1,574 - 4 - 3,050 -

Low/Mod and/or S 55,012 - 15,936,442 - 30,073 - 9,043,701 - 3,567 - 990,910 - 12,298 - 3,349,805 - 9,074 - 2,552,026 -

All Other Census T 60,744 - 31,381,466 - 36,656 - 18,523,217 - 3,745 - 1,992,904 - 11,006 - 5,970,406 - 9,337 - 4,894,939 - Applicant Sex

Male 35,220 - 13,778,364 - 19,224 - 7,444,453 - 2,645 - 1,011,208 - 7,687 - 3,057,364 - 5,664 - 2,265,339 -

Female 25,223 - 7,877,448 - 14,432 - 4,486,800 - 1,649 - 524,181 - 5,342 - 1,674,945 - 3,800 - 1,191,522 -

Joint 42,715 - 17,993,677 - 26,791 - 11,056,247 - 2,407 - 1,067,359 - 7,464 - 3,229,047 - 6,053 - 2,641,024 -

Not Applicable 12,598 - 7,668,419 - 6,282 - 4,579,418 - 611 - 381,066 - 2,811 - 1,358,855 - 2,894 - 1,349,080 - North Valley Neighborhood Service Area FFIEC-Style Summary Spreadsheet

Total Applications (1) Originated (2) Approved Not Accepted Denied (3) Withdrawn / Incomplete Count % Amount % Units % Dollar $(000) % Count % Amount % Count % Amount % Count % Amount % Loan Purpose and Type

Purchase - Conven 4,595 - 1,266,796 - 2,770 - 782,822 - 438 - 107,938 - 736 - 191,874 - 651 - 184,162 -

Purchase - Govern 3,456 - 1,028,037 - 2,092 - 638,782 - 256 - 69,124 - 676 - 194,348 - 432 - 125,783 -

Home Improvemen 618 - 121,642 - 271 - 70,752 - 29 - 4,815 - 201 - 22,615 - 117 - 23,460 -

Refinancing 15,167 - 4,364,374 - 8,727 - 2,455,483 - 806 - 238,576 - 3,104 - 928,987 - 2,530 - 741,328 - Applicant Race

American Indian/A 291 - 68,694 - 146 - 37,312 - 22 - 4,561 - 54 - 9,230 - 69 - 17,591 -

Asian 2,825 - 850,861 - 1,710 - 513,355 - 201 - 61,802 - 501 - 151,525 - 413 - 124,179 -

Black or African Am 399 - 106,409 - 219 - 56,675 - 21 - 4,507 - 99 - 28,184 - 60 - 17,043 -

Hawaiian / Pacific 229 - 66,064 - 139 - 41,599 - 9 - 2,528 - 53 - 13,159 - 28 - 8,778 -

White 15,370 - 4,266,152 - 9,203 - 2,552,177 - 1,026 - 277,747 - 2,966 - 824,002 - 2,175 - 612,226 -

2 or More Minority 22 - 4,636 - 10 - 2,275 - 1 - 227 - 7 - 1,028 - 4 - 1,106 -

Joint Race (White/ 422 - 136,045 - 281 - 87,447 - 13 - 3,632 - 67 - 23,195 - 61 - 21,771 -

Race Not Available 4,278 - 1,281,988 - 2,152 - 656,999 - 236 - 65,449 - 970 - 287,501 - 920 - 272,039 - Applicant Ethnicity

Hispanic or Latino 6,181 - 1,488,772 - 3,384 - 832,847 - 491 - 112,837 - 1,422 - 331,658 - 884 - 211,430 -

Not Hispanic or Lat 13,316 - 3,963,414 - 8,198 - 2,407,906 - 791 - 236,475 - 2,382 - 725,059 - 1,945 - 593,974 -

Joint (Hisp/Lat / N 577 - 173,133 - 354 - 106,954 - 31 - 9,286 - 103 - 29,932 - 89 - 26,961 -

Ethnicity Not Availa 3,762 - 1,155,530 - 1,924 - 600,132 - 216 - 61,855 - 810 - 251,175 - 812 - 242,368 - Minority Status

White Non-Hispani 9,318 - 2,763,938 - 5,808 - 1,694,357 - 542 - 162,384 - 1,624 - 498,707 - 1,344 - 408,490 -

Others, Including H 10,577 - 2,803,995 - 6,035 - 1,625,025 - 763 - 194,009 - 2,239 - 574,253 - 1,540 - 410,708 - Applicant Income

Low (0-49% of Me 920 - 149,490 - 390 - 63,177 - 49 - 7,564 - 343 - 56,729 - 138 - 22,020 -

Moderate (50-79% 2,775 - 518,231 - 1,421 - 256,647 - 210 - 34,874 - 712 - 144,709 - 432 - 82,001 -

Middle (80-119% 5,804 - 1,391,747 - 3,377 - 807,272 - 407 - 95,929 - 1,155 - 283,900 - 865 - 204,646 -

Upper (>=120% o 12,565 - 4,136,210 - 7,665 - 2,477,763 - 782 - 258,639 - 2,134 - 735,846 - 1,984 - 663,962 -

Income Not Availa 1,772 - 585,171 - 1,007 - 342,980 - 81 - 23,447 - 373 - 116,640 - 311 - 102,104 - Tract/BNA Characteristics

Substantially Minor 13,482 - 3,440,561 - 7,518 - 1,953,905 - 943 - 225,955 - 2,909 - 721,593 - 2,112 - 539,108 -

Not Substantially M 10,354 - 3,340,288 - 6,342 - 1,993,934 - 586 - 194,498 - 1,808 - 616,231 - 1,618 - 535,625 -

Low (0-49% of Me 121 - 30,897 - 64 - 15,214 - 7 - 1,363 - 29 - 9,274 - 21 - 5,046 -

Moderate (50-79% 2,550 - 544,873 - 1,366 - 301,817 - 200 - 39,255 - 612 - 127,156 - 372 - 76,645 -

Middle (80-119% 8,191 - 2,070,006 - 4,657 - 1,194,849 - 539 - 130,343 - 1,720 - 426,456 - 1,275 - 318,358 -

Upper (>=120% o 12,974 - 4,135,073 - 7,773 - 2,435,959 - 783 - 249,492 - 2,356 - 774,938 - 2,062 - 674,684 -

NA 0- 0 - 0 - 0 - 0 - 0 - 0 - 0 - 0 - 0 -

Low/Mod and/or S 13,595 - 3,469,100 - 7,579 - 1,968,493 - 952 - 228,145 - 2,936 - 729,450 - 2,128 - 543,012 -

All Other Census T 10,241 - 3,311,749 - 6,281 - 1,979,346 - 577 - 192,308 - 1,781 - 608,374 - 1,602 - 531,721 - Applicant Sex

Male 7,110 - 1,928,865 - 3,918 - 1,074,394 - 563 - 147,434 - 1,524 - 400,137 - 1,105 - 306,900 -

Female 4,904 - 1,238,861 - 2,797 - 710,992 - 350 - 87,026 - 1,000 - 245,001 - 757 - 195,842 -

Joint 9,678 - 2,927,881 - 6,120 - 1,823,096 - 505 - 153,926 - 1,704 - 532,733 - 1,349 - 418,126 -

Not Applicable 2,144 - 685,242 - 1,025 - 339,357 - 111 - 32,067 - 489 - 159,953 - 519 - 153,865 -

Total 23,836 - 6,780,849 - 13,860 - 3,947,839 - 1,529 - 420,453 - 4,717 - 1,337,824 - 3,730 - 1,074,733 - South Valley Neighborhood Service Area FFIEC-Style Summary Spreadsheet

Total Applications (1) Originated (2) Approved Not Accepted Denied (3) Withdrawn / Incomplete Count % Amount % Units % Dollar $(000) % Count % Amount % Count % Amount % Count % Amount % Loan Purpose and Type

Purchase - Conven 6,218 - 2,505,033 - 3,948 - 1,593,201 - 559 - 224,970 - 858 - 324,114 - 853 - 362,748 -

Purchase - Govern 2,501 - 923,872 - 1,626 - 620,688 - 148 - 49,294 - 425 - 146,415 - 302 - 107,475 -

Home Improvemen 709 - 183,868 - 351 - 106,078 - 35 - 10,643 - 209 - 38,533 - 114 - 28,614 -

Refinancing 21,037 - 8,057,172 - 12,401 - 4,632,078 - 1,189 - 455,386 - 4,174 - 1,683,538 - 3,273 - 1,286,170 - Applicant Race

American Indian/A 125 - 35,271 - 77 - 22,489 - 6 - 2,043 - 18 - 3,439 - 24 - 7,300 -

Asian 2,185 - 710,724 - 1,312 - 426,214 - 169 - 54,593 - 382 - 128,357 - 322 - 101,560 -

Black or African Am 346 - 160,186 - 184 - 65,234 - 27 - 12,203 - 80 - 32,496 - 55 - 50,253 -

Hawaiian / Pacific 157 - 48,476 - 88 - 25,296 - 9 - 4,459 - 37 - 10,718 - 23 - 8,003 -

White 21,281 - 7,931,821 - 13,123 - 4,768,601 - 1,389 - 528,778 - 3,846 - 1,501,855 - 2,923 - 1,132,587 -

2 or More Minority 15 - 4,272 - 7 - 1,402 - 0 - 0 - 4 - 1,736 - 4 - 1,134 -

Joint Race (White/ 530 - 208,436 - 364 - 141,213 - 26 - 11,973 - 82 - 30,842 - 58 - 24,408 -

Race Not Available 5,826 - 2,570,759 - 3,171 - 1,501,596 - 305 - 126,244 - 1,217 - 483,157 - 1,133 - 459,762 - Applicant Ethnicity

Hispanic or Latino 2,711 - 739,100 - 1,524 - 417,247 - 189 - 51,489 - 626 - 165,546 - 372 - 104,818 -

Not Hispanic or Lat 21,563 - 8,208,818 - 13,390 - 4,949,602 - 1,404 - 546,365 - 3,759 - 1,507,079 - 3,010 - 1,205,772 -

Joint (Hisp/Lat / N 588 - 221,779 - 364 - 130,080 - 36 - 14,954 - 109 - 46,527 - 79 - 30,218 -

Ethnicity Not Availa 5,603 - 2,500,248 - 3,048 - 1,455,116 - 302 - 127,485 - 1,172 - 473,448 - 1,081 - 444,199 - Minority Status

White Non-Hispani 18,008 - 6,951,358 - 11,251 - 4,213,201 - 1,156 - 458,453 - 3,132 - 1,287,386 - 2,469 - 992,318 -

Others, Including H 6,451 - 2,066,383 - 3,792 - 1,189,297 - 449 - 146,590 - 1,301 - 411,052 - 909 - 319,444 - Applicant Income

Low (0-49% of Me 826 - 163,047 - 363 - 67,052 - 34 - 5,690 - 310 - 67,790 - 119 - 22,515 -

Moderate (50-79% 2,094 - 416,373 - 1,086 - 203,725 - 133 - 24,728 - 560 - 126,166 - 315 - 61,754 -

Middle (80-119% 5,164 - 1,299,631 - 3,060 - 751,097 - 355 - 86,656 - 1,028 - 280,821 - 721 - 181,057 -

Upper (>=120% o 20,459 - 8,802,871 - 12,727 - 5,299,515 - 1,342 - 594,910 - 3,381 - 1,576,341 - 3,009 - 1,332,105 -

Income Not Availa 1,922 - 988,023 - 1,090 - 630,656 - 67 - 28,309 - 387 - 141,482 - 378 - 187,576 - Tract/BNA Characteristics

Substantially Minor 8,007 - 2,131,711 - 4,602 - 1,245,999 - 544 - 140,089 - 1,666 - 435,399 - 1,195 - 310,224 -

Not Substantially M 22,458 - 9,538,234 - 13,724 - 5,706,046 - 1,387 - 600,204 - 4,000 - 1,757,201 - 3,347 - 1,474,783 -

Low (0-49% of Me 67 - 17,909 - 35 - 10,751 - 6 - 1,348 - 10 - 2,343 - 16 - 3,467 -

Moderate (50-79% 3,658 - 975,749 - 2,051 - 567,813 - 243 - 59,654 - 836 - 215,329 - 528 - 132,953 -

Middle (80-119% 7,763 - 2,364,777 - 4,581 - 1,403,193 - 543 - 165,655 - 1,472 - 436,993 - 1,167 - 358,936 -

Upper (>=120% o 18,977 - 8,311,510 - 11,659 - 4,970,288 - 1,139 - 513,636 - 3,348 - 1,537,935 - 2,831 - 1,289,651 -

NA 0- 0 - 0 - 0 - 0 - 0 - 0 - 0 - 0 - 0 -

Low/Mod and/or S 8,272 - 2,190,717 - 4,763 - 1,284,286 - 555 - 142,054 - 1,718 - 446,125 - 1,236 - 318,252 -

All Other Census T 22,193 - 9,479,228 - 13,563 - 5,667,759 - 1,376 - 598,239 - 3,948 - 1,746,475 - 3,306 - 1,466,755 - Applicant Sex

Male 8,889 - 3,346,660 - 4,975 - 1,833,329 - 681 - 256,528 - 1,862 - 711,716 - 1,371 - 545,087 -

Female 6,491 - 1,980,376 - 3,901 - 1,159,565 - 430 - 139,752 - 1,221 - 390,729 - 939 - 290,330 -

Joint 11,751 - 4,712,651 - 7,704 - 3,003,491 - 666 - 273,457 - 1,863 - 794,448 - 1,518 - 641,255 -

Not Applicable 3,334 - 1,630,258 - 1,746 - 955,660 - 154 - 70,556 - 720 - 295,707 - 714 - 308,335 -

Total 30,465 - 11,669,945 - 18,326 - 6,952,045 - 1,931 - 740,293 - 5,666 - 2,192,600 - 4,542 - 1,785,007 - West Los Angeles Neighborhood Service Area FFIEC-Style Summary Spreadsheet

Total Applications (1) Originated (2) Approved Not Accepted Denied (3) Withdrawn / Incomplete Count % Amount % Units % Dollar $(000) % Count % Amount % Count % Amount % Count % Amount % Loan Purpose and Type

Purchase - Conven 4,086 68.21 3,250,774 85.57 2,558 77.07 1,997,739 98.25 348 80.18 308,383 110.52 578 45.95 438,089 52.23 602 61.49 506,563 78.18

Purchase - Govern 490 8.18 260,114 6.85 326 9.82 171,950 8.46 26 5.99 14,276 5.12 61 4.85 33,048 3.94 77 7.87 40,840 6.30

Home Improvemen 507 8.46 254,912 6.71 270 8.13 159,900 7.86 34 7.83 14,175 5.08 124 9.86 51,281 6.11 79 8.07 29,556 4.56

Refinancing 17,059 284.79 10,606,932 279.20 10,076 303.59 6,169,468 303.43 988 227.65 599,265 214.76 3,282 260.89 2,158,240 257.32 2,713 277.12 1,679,959 259.27 Applicant Race

American Indian/A 44 0.73 24,103 0.63 23 0.69 12,978 0.64 0 - 0 - 13 1.03 6,254 0.75 8 0.82 4,871 0.75

Asian 1,919 32.04 907,591 23.89 1,195 36.00 542,337 26.67 148 34.10 74,247 26.61 319 25.36 159,261 18.99 257 26.25 131,746 20.33

Black or African Am 198 3.31 85,156 2.24 109 3.28 48,322 2.38 14 3.23 4,028 1.44 40 3.18 17,099 2.04 35 3.58 15,707 2.42

Hawaiian / Pacific 72 1.20 30,675 0.81 41 1.24 16,978 0.84 3 0.69 877 0.31 11 0.87 4,315 0.51 17 1.74 8,505 1.31

White 14,389 240.22 8,896,438 234.18 8,753 263.72 5,188,284 255.17 901 207.60 589,426 211.24 2,619 208.19 1,730,464 206.32 2,116 216.14 1,388,264 214.26

2 or More Minority 10 0.17 6,296 0.17 5 0.15 1,750 0.09 0 - 0 - 3 0.24 3,844 0.46 2 0.20 702 0.11

Joint Race (White/ 575 9.60 314,888 8.29 388 11.69 210,663 10.36 32 7.37 18,011 6.45 90 7.15 49,217 5.87 65 6.64 36,997 5.71

Race Not Available 4,935 82.39 4,107,585 108.12 2,716 81.83 2,477,745 121.86 298 68.66 249,510 89.42 950 75.52 710,204 84.68 971 99.18 670,126 103.42 Applicant Ethnicity

Hispanic or Latino 670 11.19 296,606 7.81 361 10.88 161,140 7.93 34 7.83 13,765 4.93 157 12.48 72,996 8.70 118 12.05 48,705 7.52

Not Hispanic or Lat 16,341 272.80 9,882,795 260.14 10,019 301.87 5,800,547 285.28 1,058 243.78 668,888 239.71 2,897 230.29 1,884,807 224.72 2,367 241.78 1,528,553 235.91

Joint (Hisp/Lat / N 331 5.53 175,401 4.62 211 6.36 105,297 5.18 15 3.46 7,719 2.77 58 4.61 32,553 3.88 47 4.80 29,832 4.60

Ethnicity Not Availa 4,800 80.13 4,017,930 105.76 2,639 79.51 2,432,073 119.61 289 66.59 245,727 88.06 933 74.17 690,302 82.30 939 95.91 649,828 100.29 Minority Status

White Non-Hispani 13,269 221.52 8,328,920 219.24 8,108 244.29 4,861,120 239.08 839 193.32 556,477 199.43 2,379 189.11 1,608,002 191.72 1,943 198.47 1,303,321 201.15

Others, Including H 3,737 62.39 1,808,060 47.59 2,284 68.82 1,080,765 53.15 241 55.53 116,896 41.89 678 53.90 341,072 40.67 534 54.55 269,327 41.57 Applicant Income

Low (0-49% of Me 297 4.96 93,677 2.47 110 3.31 25,921 1.27 3 0.69 554 0.20 135 10.73 51,486 6.14 49 5.01 15,716 2.43

Moderate (50-79% 555 9.27 132,754 3.49 267 8.04 56,438 2.78 30 6.91 6,155 2.21 166 13.20 50,336 6.00 92 9.40 19,825 3.06

Middle (80-119% 1,486 24.81 426,692 11.23 825 24.86 217,261 10.69 91 20.97 23,899 8.56 358 28.46 125,348 14.94 212 21.65 60,184 9.29

Upper (>=120% o 18,663 311.57 12,305,080 323.90 11,435 344.53 7,264,906 357.30 1,239 285.48 858,684 307.73 3,142 249.76 2,232,822 266.21 2,847 290.81 1,948,668 300.74

Income Not Availa 1,141 19.05 1,414,529 37.23 593 17.87 934,531 45.96 33 7.60 46,807 16.77 244 19.40 220,666 26.31 271 27.68 212,525 32.80 Tract/BNA Characteristics

Substantially Minor 3,493 58.31 1,465,546 38.58 2,067 62.28 881,160 43.34 217 50.00 91,391 32.75 626 49.76 250,713 29.89 583 59.55 242,282 37.39

Not Substantially M 18,649 311.34 12,907,186 339.75 11,163 336.34 7,617,897 374.66 1,179 271.66 844,708 302.72 3,419 271.78 2,429,945 289.72 2,888 294.99 2,014,636 310.93

Low (0-49% of Me 32 0.53 19,373 0.51 16 0.48 14,590 0.72 2 0.46 506 0.18 10 0.79 2,828 0.34 4 0.41 1,449 0.22

Moderate (50-79% 740 12.35 326,015 8.58 417 12.56 180,145 8.86 42 9.68 19,828 7.11 160 12.72 73,212 8.73 121 12.36 52,830 8.15

Middle (80-119% 3,143 52.47 1,389,136 36.57 1,845 55.59 837,781 41.20 207 47.70 92,245 33.06 579 46.03 239,006 28.50 512 52.30 220,104 33.97

Upper (>=120% o 18,227 304.29 12,638,208 332.67 10,952 329.98 7,466,541 367.22 1,145 263.82 823,520 295.13 3,296 262.00 2,365,612 282.05 2,834 289.48 1,982,535 305.97

NA 0- 0 - 0 - 0 - 0 - 0 - 0 - 0 - 0 - 0 -

Low/Mod and/or S 3,493 58.31 1,465,546 38.58 2,067 62.28 881,160 43.34 217 50.00 91,391 32.75 626 49.76 250,713 29.89 583 59.55 242,282 37.39

All Other Census T 18,649 311.34 12,907,186 339.75 11,163 336.34 7,617,897 374.66 1,179 271.66 844,708 302.72 3,419 271.78 2,429,945 289.72 2,888 294.99 2,014,636 310.93 Applicant Sex

Male 5,990 100.00 3,798,985 100.00 3,319 100.00 2,033,270 100.00 434 100.00 279,037 100.00 1,258 100.00 838,730 100.00 979 100.00 647,948 100.00

Female 4,107 68.56 1,803,111 47.46 2,515 75.78 1,069,333 52.59 253 58.29 119,924 42.98 780 62.00 363,024 43.28 559 57.10 250,830 38.71

Joint 9,118 152.22 5,903,637 155.40 5,889 177.43 3,653,017 179.66 545 125.58 374,655 134.27 1,416 112.56 997,980 118.99 1,268 129.52 877,985 135.50

Not Applicable 2,927 48.86 2,866,999 75.47 1,507 45.41 1,743,437 85.75 164 37.79 162,483 58.23 591 46.98 480,924 57.34 665 67.93 480,155 74.10

Total 22,142 369.65 14,372,732 378.33 13,230 398.61 8,499,057 418.00 1,396 321.66 936,099 335.47 4,045 321.54 2,680,658 319.61 3,471 354.55 2,256,918 348.32 Central Los Angeles Neighborhood Service Area FFIEC-Style Summary Spreadsheet

Total Applications (1) Originated (2) Approved Not Accepted Denied (3) Withdrawn / Incomplete Count % Amount % Units % Dollar $(000) % Count % Amount % Count % Amount % Count % Amount % Loan Purpose and Type

Purchase - Conven 3,676 - 1,948,248 - 2,323 - 1,231,271 - 303 - 165,589 - 531 - 282,710 - 519 - 268,678 -

Purchase - Govern 480 - 245,972 - 261 - 145,461 - 33 - 16,663 - 102 - 46,699 - 84 - 37,149 -

Home Improvemen 353 - 299,816 - 149 - 236,172 - 17 - 5,942 - 117 - 31,169 - 70 - 26,533 -

Refinancing 8,748 - 4,900,410 - 4,764 - 2,688,735 - 475 - 260,474 - 1,982 - 1,149,315 - 1,527 - 801,886 - Applicant Race

American Indian/A 40 - 14,541 - 18 - 6,835 - 5 - 1,340 - 10 - 4,091 - 7 - 2,275 -

Asian 2,351 - 850,393 - 1,408 - 495,039 - 179 - 66,763 - 416 - 158,767 - 348 - 129,824 -

Black or African Am 346 - 146,118 - 170 - 67,639 - 26 - 12,924 - 88 - 40,271 - 62 - 25,284 -

Hawaiian / Pacific 80 - 29,457 - 39 - 15,473 - 5 - 2,658 - 25 - 8,053 - 11 - 3,273 -

White 7,369 - 4,021,663 - 4,248 - 2,244,932 - 434 - 249,044 - 1,534 - 903,444 - 1,153 - 624,243 -

2 or More Minority 15 - 5,999 - 8 - 3,382 - 0 - 0 - 5 - 1,500 - 2 - 1,117 -

Joint Race (White/ 228 - 122,586 - 143 - 75,376 - 11 - 5,173 - 42 - 23,526 - 32 - 18,511 -

Race Not Available 2,828 - 2,203,689 - 1,463 - 1,392,963 - 168 - 110,766 - 612 - 370,241 - 585 - 329,719 - Applicant Ethnicity

Hispanic or Latino 564 - 194,523 - 247 - 85,731 - 40 - 15,200 - 165 - 57,719 - 112 - 35,873 -

Not Hispanic or Lat 9,802 - 4,948,523 - 5,732 - 2,793,303 - 623 - 323,783 - 1,935 - 1,060,652 - 1,512 - 770,785 -

Joint (Hisp/Lat / N 168 - 86,823 - 96 - 51,076 - 12 - 5,780 - 34 - 17,822 - 26 - 12,145 -

Ethnicity Not Availa 2,723 - 2,164,577 - 1,422 - 1,371,529 - 153 - 103,905 - 598 - 373,700 - 550 - 315,443 - Minority Status

White Non-Hispani 6,627 - 3,709,453 - 3,892 - 2,090,511 - 386 - 227,992 - 1,329 - 817,866 - 1,020 - 573,084 -

Others, Including H 3,723 - 1,424,683 - 2,090 - 785,458 - 272 - 108,389 - 771 - 305,793 - 590 - 225,043 - Applicant Income

Low (0-49% of Me 295 - 69,349 - 92 - 18,854 - 12 - 2,506 - 137 - 37,235 - 54 - 10,754 -

Moderate (50-79% 492 - 111,752 - 229 - 47,032 - 24 - 6,413 - 153 - 39,464 - 86 - 18,843 -

Middle (80-119% 1,431 - 385,276 - 782 - 200,952 - 107 - 26,201 - 314 - 100,360 - 228 - 57,763 -

Upper (>=120% o 10,089 - 5,718,256 - 5,902 - 3,223,008 - 660 - 395,062 - 1,900 - 1,193,398 - 1,627 - 906,788 -

Income Not Availa 950 - 1,109,813 - 492 - 811,793 - 25 - 18,486 - 228 - 139,436 - 205 - 140,098 - Tract/BNA Characteristics

Substantially Minor 5,444 - 2,363,428 - 3,006 - 1,437,213 - 346 - 137,675 - 1,158 - 431,462 - 934 - 357,078 -

Not Substantially M 7,813 - 5,031,018 - 4,491 - 2,864,426 - 482 - 310,993 - 1,574 - 1,078,431 - 1,266 - 777,168 -

Low (0-49% of Me 1,570 - 753,668 - 787 - 501,354 - 107 - 29,743 - 397 - 125,768 - 279 - 96,803 -

Moderate (50-79% 2,158 - 809,504 - 1,209 - 469,644 - 139 - 55,493 - 450 - 153,914 - 360 - 130,453 -

Middle (80-119% 3,393 - 1,783,770 - 1,924 - 1,073,908 - 209 - 109,744 - 680 - 342,343 - 580 - 257,775 -

Upper (>=120% o 6,125 - 4,042,480 - 3,576 - 2,256,333 - 373 - 253,688 - 1,199 - 886,294 - 977 - 646,165 -

NA 11 - 5,024 - 1 - 400 - 0 - 0 - 6 - 1,574 - 4 - 3,050 -

Low/Mod and/or S 5,695 - 2,459,022 - 3,147 - 1,492,958 - 364 - 144,905 - 1,206 - 448,358 - 978 - 372,801 -

All Other Census T 7,562 - 4,935,424 - 4,350 - 2,808,681 - 464 - 303,763 - 1,526 - 1,061,535 - 1,222 - 761,445 - Applicant Sex

Male 4,698 - 2,476,996 - 2,633 - 1,342,008 - 328 - 165,792 - 991 - 585,820 - 746 - 383,376 -

Female 2,942 - 1,197,611 - 1,639 - 658,129 - 183 - 75,685 - 662 - 277,315 - 458 - 186,482 -

Joint 3,870 - 2,062,253 - 2,335 - 1,205,934 - 222 - 128,030 - 708 - 400,639 - 605 - 327,650 -

Not Applicable 1,747 - 1,657,586 - 890 - 1,095,568 - 95 - 79,161 - 371 - 246,119 - 391 - 236,738 -

Total 13,257 - 7,394,446 - 7,497 - 4,301,639 - 828 - 448,668 - 2,732 - 1,509,893 - 2,200 - 1,134,246 - East Los Angeles Neighborhood Service Area FFIEC-Style Summary Spreadsheet

Total Applications (1) Originated (2) Approved Not Accepted Denied (3) Withdrawn / Incomplete Count % Amount % Units % Dollar $(000) % Count % Amount % Count % Amount % Count % Amount % Loan Purpose and Type

Purchase - Conven 1,613 - 521,641 - 984 - 316,351 - 116 - 44,074 - 260 - 81,620 - 253 - 79,596 -

Purchase - Govern 1,012 - 338,643 - 610 - 208,942 - 66 - 21,404 - 183 - 60,439 - 153 - 47,858 -

Home Improvemen 380 - 72,857 - 155 - 36,314 - 19 - 4,827 - 126 - 15,848 - 80 - 15,868 -

Refinancing 6,549 - 2,010,810 - 3,516 - 1,084,415 - 345 - 101,945 - 1,522 - 466,249 - 1,166 - 358,201 - Applicant Race

American Indian/A 123 - 30,126 - 62 - 15,540 - 5 - 1,370 - 41 - 9,728 - 15 - 3,488 -

Asian 1,209 - 341,076 - 675 - 187,301 - 71 - 19,532 - 256 - 74,857 - 207 - 59,386 -

Black or African Am 110 - 35,494 - 65 - 21,510 - 5 - 1,737 - 18 - 5,817 - 22 - 6,430 -

Hawaiian / Pacific 148 - 44,548 - 77 - 23,694 - 6 - 1,460 - 39 - 12,034 - 26 - 7,360 -

White 5,842 - 1,771,875 - 3,321 - 1,004,964 - 360 - 108,124 - 1,247 - 376,683 - 914 - 282,104 -

2 or More Minority 9- 2,616 - 5 - 1,207 - 1 - 379 - 3 - 1,030 - 0 - 0 -

Joint Race (White/ 215 - 74,179 - 136 - 46,575 - 6 - 1,941 - 37 - 11,764 - 36 - 13,899 -

Race Not Available 1,898 - 644,037 - 924 - 345,231 - 92 - 37,707 - 450 - 132,243 - 432 - 128,856 - Applicant Ethnicity

Hispanic or Latino 2,743 - 664,078 - 1,402 - 345,490 - 180 - 45,258 - 717 - 168,028 - 444 - 105,302 -

Not Hispanic or Lat 4,960 - 1,626,768 - 2,899 - 935,208 - 289 - 92,737 - 969 - 330,139 - 803 - 268,684 -

Joint (Hisp/Lat / N 243 - 76,829 - 157 - 48,808 - 8 - 3,255 - 41 - 12,285 - 37 - 12,481 -

Ethnicity Not Availa 1,608 - 576,276 - 807 - 316,516 - 69 - 31,000 - 364 - 113,704 - 368 - 115,056 - Minority Status

White Non-Hispani 3,287 - 1,126,901 - 1,967 - 656,787 - 195 - 65,836 - 621 - 224,280 - 504 - 179,998 -

Others, Including H 4,594 - 1,216,192 - 2,466 - 661,326 - 274 - 72,978 - 1,093 - 280,707 - 761 - 201,181 - Applicant Income

Low (0-49% of Me 449 - 77,250 - 177 - 30,576 - 23 - 2,685 - 167 - 30,568 - 82 - 13,421 -

Moderate (50-79% 991 - 194,920 - 463 - 87,973 - 65 - 11,226 - 285 - 59,432 - 178 - 36,289 -

Middle (80-119% 2,086 - 506,563 - 1,157 - 280,628 - 111 - 26,532 - 466 - 113,511 - 352 - 85,892 -

Upper (>=120% o 5,287 - 1,861,458 - 3,038 - 1,048,257 - 315 - 113,849 - 1,032 - 379,509 - 902 - 319,843 -

Income Not Availa 741 - 303,760 - 430 - 198,588 - 32 - 17,958 - 141 - 41,136 - 138 - 46,078 - Tract/BNA Characteristics

Substantially Minor 9,195 - 2,775,431 - 5,047 - 1,547,833 - 526 - 162,165 - 2,023 - 592,495 - 1,599 - 472,938 -

Not Substantially M 359 - 168,520 - 218 - 98,189 - 20 - 10,085 - 68 - 31,661 - 53 - 28,585 -

Low (0-49% of Me 263 - 59,845 - 122 - 29,111 - 16 - 3,301 - 71 - 15,108 - 54 - 12,325 -

Moderate (50-79% 3,426 - 937,761 - 1,787 - 498,014 - 206 - 62,871 - 841 - 220,496 - 592 - 156,380 -

Middle (80-119% 4,233 - 1,385,812 - 2,382 - 791,895 - 233 - 75,985 - 874 - 279,803 - 744 - 238,129 -

Upper (>=120% o 1,632 - 560,533 - 974 - 327,002 - 91 - 30,093 - 305 - 108,749 - 262 - 94,689 -

NA 0- 0 - 0 - 0 - 0 - 0 - 0 - 0 - 0 - 0 -

Low/Mod and/or S 9,195 - 2,775,431 - 5,047 - 1,547,833 - 526 - 162,165 - 2,023 - 592,495 - 1,599 - 472,938 -

All Other Census T 359 - 168,520 - 218 - 98,189 - 20 - 10,085 - 68 - 31,661 - 53 - 28,585 - Applicant Sex

Male 2,990 - 894,621 - 1,584 - 476,366 - 201 - 58,935 - 697 - 207,461 - 508 - 151,859 -

Female 2,300 - 630,982 - 1,274 - 353,206 - 140 - 35,058 - 548 - 149,014 - 338 - 93,704 -

Joint 3,265 - 1,029,411 - 1,918 - 598,110 - 172 - 57,063 - 628 - 199,885 - 547 - 174,353 -

Not Applicable 999 - 388,937 - 489 - 218,340 - 33 - 21,194 - 218 - 67,796 - 259 - 81,607 -

Total 9,554 - 2,943,951 - 5,265 - 1,646,022 - 546 - 172,250 - 2,091 - 624,156 - 1,652 - 501,523 - South Los Angeles Neighborhood Service Area FFIEC-Style Summary Spreadsheet

Total Applications (1) Originated (2) Approved Not Accepted Denied (3) Withdrawn / Incomplete Count % Amount % Units % Dollar $(000) % Count % Amount % Count % Amount % Count % Amount % Loan Purpose and Type

Purchase - Conven 1,742 - 423,369 - 904 - 236,005 - 173 - 36,867 - 395 - 91,065 - 270 - 59,432 -

Purchase - Govern 3,747 - 897,140 - 2,157 - 522,727 - 272 - 61,981 - 714 - 169,125 - 604 - 143,307 -

Home Improvemen 517 - 63,030 - 196 - 28,543 - 18 - 2,756 - 226 - 18,507 - 77 - 13,224 -

Refinancing 5,374 - 1,303,073 - 2,342 - 585,478 - 289 - 66,706 - 1,702 - 405,742 - 1,041 - 245,147 - Applicant Race

American Indian/A 144 - 27,861 - 57 - 11,000 - 10 - 1,398 - 42 - 8,285 - 35 - 7,178 -

Asian 437 - 127,001 - 237 - 68,018 - 37 - 9,780 - 101 - 30,824 - 62 - 18,379 -

Black or African Am 2,900 - 650,901 - 1,384 - 313,664 - 161 - 37,306 - 848 - 181,776 - 507 - 118,155 -

Hawaiian / Pacific 39 - 9,338 - 17 - 4,109 - 2 - 331 - 15 - 3,886 - 5 - 1,012 -

White 5,787 - 1,318,273 - 3,064 - 712,418 - 426 - 89,304 - 1,382 - 309,751 - 915 - 206,800 -

2 or More Minority 35 - 7,302 - 10 - 1,959 - 1 - 207 - 13 - 2,835 - 11 - 2,301 -

Joint Race (White/ 114 - 32,859 - 63 - 19,079 - 7 - 1,873 - 29 - 7,955 - 15 - 3,952 -

Race Not Available 1,924 - 513,077 - 767 - 242,506 - 108 - 28,111 - 607 - 139,127 - 442 - 103,333 - Applicant Ethnicity

Hispanic or Latino 4,876 - 1,013,722 - 2,490 - 527,293 - 365 - 70,912 - 1,215 - 248,447 - 806 - 167,070 -

Not Hispanic or Lat 4,771 - 1,184,169 - 2,374 - 601,515 - 291 - 71,773 - 1,301 - 308,654 - 805 - 202,227 -

Joint (Hisp/Lat / N 106 - 30,327 - 64 - 19,464 - 6 - 1,418 - 26 - 6,853 - 10 - 2,592 -

Ethnicity Not Availa 1,627 - 458,394 - 671 - 224,481 - 90 - 24,207 - 495 - 120,485 - 371 - 89,221 - Minority Status

White Non-Hispani 1,296 - 368,670 - 702 - 203,496 - 86 - 22,791 - 304 - 85,167 - 204 - 57,216 -

Others, Including H 8,418 - 1,850,930 - 4,223 - 942,925 - 569 - 119,827 - 2,221 - 477,726 - 1,405 - 310,452 - Applicant Income

Low (0-49% of Me 1,063 - 150,178 - 430 - 60,358 - 47 - 5,762 - 405 - 57,997 - 181 - 26,061 -

Moderate (50-79% 2,516 - 446,429 - 1,237 - 220,572 - 184 - 31,819 - 667 - 117,575 - 428 - 76,463 -

Middle (80-119% 3,208 - 720,425 - 1,579 - 359,591 - 257 - 57,779 - 805 - 177,879 - 567 - 125,176 -

Upper (>=120% o 3,529 - 1,035,062 - 1,781 - 524,312 - 215 - 60,083 - 917 - 267,657 - 616 - 183,010 -

Income Not Availa 1,064 - 334,518 - 572 - 207,920 - 49 - 12,867 - 243 - 63,331 - 200 - 50,400 - Tract/BNA Characteristics

Substantially Minor 11,376 - 2,684,225 - 5,596 - 1,370,516 - 752 - 168,310 - 3,037 - 684,439 - 1,991 - 460,960 -

Not Substantially M 4- 2,387 - 3 - 2,237 - 0 - 0 - 0 - 0 - 1 - 150 -

Low (0-49% of Me 2,530 - 569,132 - 1,204 - 300,077 - 168 - 33,635 - 707 - 143,262 - 451 - 92,158 -

Moderate (50-79% 6,119 - 1,416,908 - 2,991 - 712,821 - 418 - 90,620 - 1,651 - 370,633 - 1,059 - 242,834 -

Middle (80-119% 1,943 - 478,744 - 987 - 245,766 - 111 - 27,699 - 511 - 120,986 - 334 - 84,293 -

Upper (>=120% o 788 - 221,828 - 417 - 114,089 - 55 - 16,356 - 168 - 49,558 - 148 - 41,825 -

NA 0- 0 - 0 - 0 - 0 - 0 - 0 - 0 - 0 - 0 -

Low/Mod and/or S 11,380 - 2,686,612 - 5,599 - 1,372,753 - 752 - 168,310 - 3,037 - 684,439 - 1,992 - 461,110 -

All Other Census T 0- 0 - 0 - 0 - 0 - 0 - 0 - 0 - 0 - 0 - Applicant Sex

Male 3,950 - 883,505 - 1,926 - 439,261 - 314 - 66,204 - 1,019 - 221,088 - 691 - 156,952 -

Female 3,417 - 753,347 - 1,663 - 370,069 - 232 - 51,069 - 931 - 198,266 - 591 - 133,943 -

Joint 3,003 - 742,753 - 1,584 - 399,931 - 167 - 39,839 - 783 - 191,399 - 469 - 111,584 -

Not Applicable 1,010 - 307,007 - 426 - 163,492 - 39 - 11,198 - 304 - 73,686 - 241 - 58,631 -

Total 11,380 - 2,686,612 - 5,599 - 1,372,753 - 752 - 168,310 - 3,037 - 684,439 - 1,992 - 461,110 - Harbor Neighborhood Service Area FFIEC-Style Summary Spreadsheet

Total Applications (1) Originated (2) Approved Not Accepted Denied (3) Withdrawn / Incomplete Count % Amount % Units % Dollar $(000) % Count % Amount % Count % Amount % Count % Amount % Loan Purpose and Type

Purchase - Conven 769 - 217,055 - 481 - 141,150 - 65 - 17,754 - 111 - 29,660 - 112 - 28,491 -

Purchase - Govern 599 - 190,770 - 397 - 128,713 - 43 - 13,606 - 87 - 26,682 - 72 - 21,769 -

Home Improvemen 173 - 28,730 - 78 - 16,442 - 9 - 2,330 - 61 - 5,867 - 25 - 4,091 -

Refinancing 3,581 - 1,032,818 - 1,996 - 561,258 - 213 - 64,051 - 757 - 228,432 - 615 - 179,077 - Applicant Race

American Indian/A 41 - 9,245 - 25 - 6,084 - 3 - 572 - 8 - 1,571 - 5 - 1,018 -

Asian 484 - 132,466 - 280 - 75,070 - 35 - 10,433 - 89 - 26,213 - 80 - 20,750 -

Black or African Am 169 - 45,075 - 97 - 25,939 - 7 - 2,145 - 38 - 10,028 - 27 - 6,963 -

Hawaiian / Pacific 41 - 12,238 - 28 - 8,398 - 2 - 669 - 9 - 2,480 - 2 - 691 -

White 3,354 - 965,101 - 2,008 - 574,825 - 236 - 71,267 - 618 - 177,940 - 492 - 141,069 -

2 or More Minority 2- 834 - 1 - 417 - 0 - 0 - 1 - 417 - 0 - 0 -

Joint Race (White/ 105 - 30,584 - 59 - 17,421 - 4 - 1,163 - 23 - 6,846 - 19 - 5,154 -

Race Not Available 926 - 273,830 - 454 - 139,409 - 43 - 11,492 - 230 - 65,146 - 199 - 57,783 - Applicant Ethnicity

Hispanic or Latino 1,339 - 342,212 - 720 - 182,541 - 94 - 25,423 - 290 - 70,750 - 235 - 63,498 -

Not Hispanic or Lat 2,824 - 837,008 - 1,723 - 506,354 - 193 - 60,492 - 503 - 153,057 - 405 - 117,105 -

Joint (Hisp/Lat / N 172 - 52,203 - 114 - 34,289 - 7 - 2,194 - 33 - 10,785 - 18 - 4,935 -

Ethnicity Not Availa 787 - 237,950 - 395 - 124,379 - 36 - 9,632 - 190 - 56,049 - 166 - 47,890 - Minority Status

White Non-Hispani 2,013 - 611,368 - 1,258 - 379,291 - 142 - 45,465 - 341 - 105,998 - 272 - 80,614 -

Others, Including H 2,280 - 607,063 - 1,282 - 339,575 - 150 - 42,162 - 474 - 125,105 - 374 - 100,221 - Applicant Income

Low (0-49% of Me 167 - 27,223 - 67 - 10,374 - 8 - 1,530 - 59 - 9,261 - 33 - 6,058 -

Moderate (50-79% 531 - 98,097 - 288 - 52,116 - 38 - 7,672 - 121 - 23,735 - 84 - 14,574 -

Middle (80-119% 1,132 - 277,334 - 660 - 160,222 - 74 - 17,949 - 226 - 57,570 - 172 - 41,593 -

Upper (>=120% o 2,920 - 945,976 - 1,725 - 550,061 - 197 - 66,216 - 526 - 177,419 - 472 - 152,280 -

Income Not Availa 372 - 120,743 - 212 - 74,790 - 13 - 4,374 - 84 - 22,656 - 63 - 18,923 - Tract/BNA Characteristics

Substantially Minor 3,382 - 890,014 - 1,871 - 496,218 - 201 - 53,940 - 752 - 198,225 - 558 - 141,631 -

Not Substantially M 1,740 - 579,359 - 1,081 - 351,345 - 129 - 43,801 - 264 - 92,416 - 266 - 91,797 -

Low (0-49% of Me 108 - 26,108 - 42 - 10,369 - 10 - 2,364 - 26 - 6,734 - 30 - 6,641 -

Moderate (50-79% 1,380 - 358,545 - 724 - 189,420 - 85 - 22,346 - 338 - 89,740 - 233 - 57,039 -

Middle (80-119% 1,610 - 437,123 - 935 - 257,374 - 92 - 25,290 - 324 - 84,090 - 259 - 70,369 -

Upper (>=120% o 2,024 - 647,597 - 1,251 - 390,400 - 143 - 47,741 - 328 - 110,077 - 302 - 99,379 -

NA 0- 0 - 0 - 0 - 0 - 0 - 0 - 0 - 0 - 0 -

Low/Mod and/or S 3,382 - 890,014 - 1,871 - 496,218 - 201 - 53,940 - 752 - 198,225 - 558 - 141,631 -

All Other Census T 1,740 - 579,359 - 1,081 - 351,345 - 129 - 43,801 - 264 - 92,416 - 266 - 91,797 - Applicant Sex

Male 1,593 - 448,732 - 869 - 245,825 - 124 - 37,278 - 336 - 92,412 - 264 - 73,217 -

Female 1,062 - 273,160 - 643 - 165,506 - 61 - 15,667 - 200 - 51,596 - 158 - 40,391 -

Joint 2,030 - 615,091 - 1,241 - 372,668 - 130 - 40,389 - 362 - 111,963 - 297 - 90,071 -

Not Applicable 437 - 132,390 - 199 - 63,564 - 15 - 4,407 - 118 - 34,670 - 105 - 29,749 -

Total 5,122 - 1,469,373 - 2,952 - 847,563 - 330 - 97,741 - 1,016 - 290,641 - 824 - 233,428 -