Your SlideShare is downloading. ×
Regional Analysis of Impediments to Fair Housing (RAI) Part 1
Upcoming SlideShare
Loading in...5
×

Thanks for flagging this SlideShare!

Oops! An error has occurred.

×
Saving this for later? Get the SlideShare app to save on your phone or tablet. Read anywhere, anytime – even offline.
Text the download link to your phone
Standard text messaging rates apply

Regional Analysis of Impediments to Fair Housing (RAI) Part 1

1,453
views

Published on


0 Comments
1 Like
Statistics
Notes
  • Be the first to comment

No Downloads
Views
Total Views
1,453
On Slideshare
0
From Embeds
0
Number of Embeds
1
Actions
Shares
0
Downloads
1
Comments
0
Likes
1
Embeds 0
No embeds

Report content
Flagged as inappropriate Flag as inappropriate
Flag as inappropriate

Select your reason for flagging this presentation as inappropriate.

Cancel
No notes for slide

Transcript

  • 1. CARRAS COMMUNITY INVESTMENT, INC.Part 1:Seven/50Regional Analysis of Impediments to Fair Housing (RAI)OCTOBER 2012 DRAFT In partial fulfillment of the requirements of Fair Housing Planning for the Seven|50 Southeast Florida Prosperity Plan—HUD Sustainable Communities Regional Planning Initiative PART 1, SECTIONS: 1 Introduction: Analyzing Impediments to Fair Housing 2 SEFLA Region Background Data 3 Fair Housing Profile 4 Lending Profile 5 Identified ImpedimentsSEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |1Carras Community Investment, Inc.
  • 2. Executive SummaryThis report contains a Regional Analysis of Impediments to fair housing (RAI) which identifies, explains, and analyzes the fair housingmilieu in Southeast Florida (SEFLA). It is produced in partial fulfillment of HUD defined Fair Housing Equity Assessment (FHEA)requirements for the Seven|50 regional plan. This plan is being produced by a consortium led by the South Florida and Treasure CoastRegional Planning Councils as a grantee of HUD’s Sustainable Communities Regional Planning Initiative. The counties included in thisanalysis, listed in order from north to south, are 1) Indian River, 2) Martin, 3) St. Lucie, 4) Palm Beach, 5) Broward, 6) Miami-Dade, and 7)Monroe.Summary of Key Findings: 1. SEFLA Region Background Data   The region has very high levels of cost-burdened households especially for renters. 60% of renting households, regardless of income, pay more than 30% of their monthly income on housing costs while 46% of household that own pay the same proportion.   Our analysis identifies single female householders with children as especially in need. As a region, one third of all single- female households with children are below poverty level.   efficient public transportation options are lacking throughout the entire region—the development of which are especially essential near areas that are primarily minority and renter-occupied when employment opportunities are not located near these areas 2. Fair Housing Profile   Assisted housing units are highly concentrated: 94% of all units within properties that offer assisted housing are assisted.   The vast majority of assisted housing units are reserved for renters in the 55-60% AMI. Only 627 of the nearly 85,000 assisted housing units in SEFLA are reserved for those in the lowest income bracket, and therefore those in the greatest need of affordable housing opportunities. 512 of these are in Broward County compared to only 40 in Miami-Dade (which has the highest poverty rate in the region at 17%); none are located in Indian River, St. Lucie and Martin Counties.   Disability is, over the 5-year period and for each county, the largest alleged discriminating factor in fair housing complaints (43%). This is followed by race (17%), national origin (13%), and familial status (11%). 3. Lending Profile   There are disparities in loan origination rates and subprime lending rates across the seven South Florida counties. Though these disparities are seen across racial groups, the data suggests no racial group at a significant disparity or disadvantage across all seven counties. 4. Top 10 Identified Impediments   1: Lack of Knowledge, Awareness of, or Education on Fair Housing Protections   2: Fair and Equal Lending Disparities   3: Housing/Lending Discrimination on the Basis of Race, Color, National Origin, Religion, Sex, Familial Status and Disability   4: Shortage of Affordable Housing Opportunities   5: Violations of Federal, State and Local Housing Laws CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |2
  • 3.   6: Housing Market Segregation  7: Predatory Lending  8: Limited Funding to Meet Need for Affordable Housing  9: Zoning/Land Use  10: Improvement of the Housing Discrimination Complaint Process CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |3
  • 4. 1. Analyzing Impediments to Fair HousingThe right to fair housing choice is among America’s most basic civilrights as defined by federal, state and local laws and as such it isstructurally integral to the Sustainable Communities RegionalPlanning Grant program. Specifically, HUD defines impediments tofair housing choice as: • Any actions, omissions, or decisions taken because of race, color, religion, sex, disability, familial status, or national origin which restrict housing choices or the availability of housing choices • 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, religion, sex, disability, familial status, or national origin.All households, regardless of arbitrary factors such as familial statusand race are guaranteed equal access to housing opportunitiesyet disparities in the receipt of these opportunities based in suchgrounds are still commonplace throughout regions. The seven-county Southeast Florida Region (SEFLA) is no different.Sustainable Communities Regional Grantees are thereforerequired to complete a Fair Housing and Equity Assessment (FHEA)and recommended to produce a Regional Analysis ofImpediments to fair housing (Regional AI) in hopes of addressingthese disparities.The broad purpose of performing a Regional AI is to increasehousing choice through assembling fair housing information andidentifying problems. More specifically focusing on furthering fairhousing on a regional scale allows grantees to: Figure 1: SEFLA Region 1. Overcome spatial segregation making assisted housing accessible to all in all areas of the metro region, which overcomes jurisdictional and artificial program delivery barriers. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |4
  • 5. 2. The ability to integrate assisted housing waiting lists into one regional waiting list & the integration of racial or ethnic groups into areas where they have low impact (areas where they compose less than 30% of population). 3. To make public housing a path to social mobility rather than housing of last resort by modernizing them to be appealing to both current residents and suburban residents. 4. To secure the cooperation of other important actors whose impact upon fair housing is substantial (jobs, schools, transportation agencies, social service agencies, Government not for Profits, Government Agencies). 5. To break down the statistical racial disparity between HUD’s public housing program and its Section 8 existing housing program by encouraging more non-minorities by promoting desegregation within assisted and insured programs by establishing a one stop metropolitan wide housing assistance, marketing, information and referral center. 6. To discourage discrimination in all programs by encouraging all persons regardless of color, national origin, sex, disability or familial status to consider all housing options.This report contains the SEFLA Regional AI. The counties included in this analysis, listed in order from north to south, are 1) Indian River, 2)Martin, 3) St. Lucie, 4) Palm Beach, 5) Broward, 6) Miami-Dade, and 7) Monroe. While the study area is relatively large andheterogeneous, there are definite benefits to conducting an AI at this scale as many fair housing issues, especially those mostintractable, are best addressed at a regional level. By analyzing fair housing on this level, the jurisdiction seeks to overcome spatialseparation and segregation by eliminating housing delivery barriers, integrating waiting lists between jurisdictions, and broadening thehousing choices available to all eligible participants throughout SEFLA.As outlined in the U.S. Department of Housing and Urban Development, Office of Fair Housing and Equal Opportunity, Fair HousingPlanning Guide, recipients of HUD’s housing and community development grants must certify that they will affirmatively further fairhousing (AFFH). These provisions are found within the mandate of Section 808(e)(5) of the Fair Housing Act. The extent of the AFFHobligation has never been defined statutorily. However, HUD defines it as requiring a grantee to: 1. Conduct an analysis to identify impediments to fair housing choice within the jurisdiction 2. Take appropriate actions to overcome the effects of any impediments identified through the analysis 3. Maintain records reflecting the analysis and actions taken in this regard. Grantee jurisdiction providing opportunities for inclusive patterns of housing occupancy regardless of race, color religion, sex familial status, disability and national origin.This report fulfills the first of three AFFH requirements by reviewing impediments to fair housing choice in the public and private sector. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |5
  • 6. Entity Engaged to Conduct the 2012, Seven-50 SEFLA Regional AICarras Community Investment Inc. (CCI, Inc.) CCI, Inc. is a nationally recognized leader in implementing asset-based strategies for housing and community development. Our professional expertise in affordable housing, fair lending, and economic development includes advisory services in market analysis, strategic planning, and financing. Over the past thirty years, CCI, Inc. has provided planning services to over 200 clients across the country, resulting in over $10 billion of investment in underserved communities. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |6
  • 7. Methodology and Data SourcesRegional Profile - Methodology This section includes background data on the jurisdiction to serve as bases for identifying and contextualizing impediments. Variable are chosen that relate to the degree of segregation and restricted housing by race and ethnicity, and families with children in particular (see table1). Variables and data sources are also chosen to parallel as best as possible a dataset compiled by HUD’s office of Policy Development & Research (PD&R). This dataset was intended to provide program participants with data to support this analysis and additional fair housing research. Regrettably however, the data package provided for SEFLA was incomplete (only data for the three most southern counties was provided -Broward, Miami-Dade and Monroe) and therefore inappropriate to use for the full regional profile. However, given that a large proportion of the population, especially minority residents, is located within Broward and Miami-Dade counties this information is still relevant to the discussion. Therefore, this data is summarized in the Appendix under the HUD PD&R Data Package section. Descriptions of their variables and methodology are cited directly from the FHEA 2012 Data Documentation guide provided to all entitlement regions through HUD’s regional planning grant program. Data within this section is collected at both the census tract and county level. Given the large area analyzed in this report most data is summarized at a county level. Data displayed within maps, however, utilizes census tract level data to show, in detail, the spatial relationship and patterns of variables within counties and throughout the region as a whole. Per the 2010 Census, a total of 1,333 populated census tracts exist across the seven counties of Southeast Florida: 29 in Indian River County, 43 in St. Lucie County, 34 in Martin County, 331 in Palm Beach County, 360 in Broward County, 508 in Miami- Dade County, and 28 in Monroe County. When reading the report maps, it is important to consider that lower population densities and distributions are likelier to occur in geographically larger areas such as those in the Western portions of most counties and the more northern counties. Most data comes from the American Community Survey 2006-2010 estimates. Where census 2010 data is available however it is used in place of ACS data to allay concerns about sampling error. Table 2 lists the specific data source for variables within the Regional Profile section. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |7
  • 8. Table 1: Data Sources for the Regional Background Profile Section Table 2: Populated Census Tracts by County Section Variable Data Source County Number of Populated Census Tracts Population totals and density Indian River 29 Demographics 2010 Census SF1 Age St. Lucie 43 Segregation Race and Ethnicity 2010 Census SF1 Martin 34 Tenancy Housing ACS 2006-2010 Palm Beach 331 Cost Burdon Broward 360 Family Poverty Rate Poverty ACS 2006-2010 Miami-Dade 508 Poverty By Race & Ethnicity Unemployment Monroe 28 Labor force Participation Rate TOTAL 1,333 Labor and Commuting ACS 2006-2010 Commute Time Commute Mode CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |8
  • 9. Fair Housing Profile - MethodologyThe process creating a Fair Housing Profile included review national and local studies/reports, and data gathered from local agenciesand organizations. Major data sources include: • All most-recent existing AIs produced by local jurisdictions within SEFLA INDIAN RIVER ST. LUCIE MARTIN PALM BEACH MIAMI-DADE MONROE County BROWARD COUNTY COUNTY COUNTY COUNTY COUNTY COUNTY COUNTY • None • City Of Port • None • Palm Beach • Broward County • Miami-Dade • None Saint Lucie County • City Of Coconut County • City Of Fort • City Of Boca Creek • City Of Pierce Raton • City Of Coral Miami • City Of Boynton Springs • City Of Beach • City Of Hollywood Miami Beach • City Of Deerfield • City Of Fort • City Of Beach Lauderdale Miami • City Of Delray • City Of Lauderhill Gardens Beach • City Of Miramar • City Of North Entitlement • City Of West • City Of Margate Miami Jurisdiction Palm Beach • City Of Pembroke • City Of • Town Of Pines Homestead Wellington • City Of Plantation • City Of • Town Of Jupiter • City Of Pompano Hialeah Beach • City Of Sunrise • City Of Tamarac • City Of Westin • Town Of Davie • Florida Housing Data Clearing House (Existing Assisted Housing Inventory) • Data from various state and local Fair Housing Agencies o Florida Commission on Human Relations o Palm Beach County Office of Equal Opportunity o Broward County Office of Equal Opportunity | Civil Rights Division o Miami-Dade Office of Human Rights and Fair Employment Practices CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |9
  • 10. Lending Profile- MethodologyLending data for this section was retrieved from the University of Florida Housing Data Clearinghouse. Racial lending data and overall2010 lending data by county and for the State of Florida were analyzed to identify disparities and trends in lending patterns by race,ethnicity and by county. The data used for the county lending analysis is original research, due to the fact that the most recent lendingdata in the existing county-level Analysis of Impediments to Fair Housing documents available (Miami-Dade & Broward County) arefrom the years 2008 & 2009. The data used in this analysis is more recent, from the year 2010.Identified Impediments to Fair Housing- MethodologyThis section of the South Florida Regional Analysis of Impediments to Fair Housing Choice examines the ten most prevalent impedimentsto fair housing choice in the region. This examination was done through the examination of available analysis of impediments (AIs) tofair housing choice documents for entitled communities within the study-recognized seven-county south Florida region, both at themunicipal and at the county level. Three countywide and twenty-eight municipal-level AIs were consulted in this analysis. Two countiesin the region, Martin County & Monroe County, lack entitled communities and information on the impediments to fair housing withinthese counties are not included within this analysis, though, since the issues pointed out in the other counties and municipalities in theregion are largely similar, it is likely that the non-entitled counties experience impediments similar to those discussed in this analysis. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |10
  • 11. CARRAS COMMUNITY INVESTMENT, INC.2. SEFLA Regional Background Data: CONTEXTUALIZING THE FAIR HOUSING DISCUSSIONThis section discusses data primarily at the county and regional level, although maps are displayed using census tract level data tomore accurately represent spatial patterns. Municipalities and landmark areas are referenced occasionally to contextualize and orientthe discussion but are not the primary units of analysis.Demographics • Total Population: 138,028 Indian River • Population Density: 274.5 people/mi2 County • Dominant Age Group: 50-54 SEFLA, Total Population by Rank, 2010 • Total Population: 277,789 St. Lucie • Population Density: 485.7 people/mi2 County • Dominant Age Group: 45-49 Miami-Dade County 2,496,435 • Total Population: 146,318 Martin • Population Density: 269.2 people/mi2 Broward County 1,748,066 County • Dominant Age Group: 50-54 Palm Beach County 1,320,134 • Total Population: 1,320,134 Palm Beach • Population Density: 670.2 people/mi2 St. Lucie County 277,789 County • Dominant Age Group: 45 to 49 Martin County 146,318 • Total Population: 1,748,066 Broward • Population Density: 1,444.9 people/mi2 Indian River County 138,028 County • Dominant Age Group: 45 to 49 Monroe County 73,090 • Total Population: 2,496,435 Miami-Dade • Population Density: 1.315.5 people/mi2 County • Dominant Age Group: 45 to 49 Figure 2: SEFLA, Total Population by Rank, 2010 • Total Population: 73,090 Monroe • Population Density: 74.3 people/mi2 County • Dominant Age Group: 55 to 59SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |11Carras Community Investment, Inc.
  • 12. The three most populous counties are, in decreasingorder, Miami-Dade, Broward, and Palm Beach.These three counties are similarly the densest in termsof population per square mile. Given BrowardCounty’s smaller land area however, populationdensity is actually higher within Broward than Miami-Dade. Map 1, to the left, shows that the region’spopulation is also concentrated in the easternportion of the counties, which is a reflection of bothhistoric settlement patterns as well as the Evergladeswamp areas to the west. In all, the region has atotal population of over 6 million and a populationdensity of around 800 people per square mile. Thatis equivalent to the 5th largest metropolitan region inthe United States. Map 1: Population Density, Seven-50 SE Florida Region, 2010 • Total Population: 6,199,860 SEFLA • Population Density: 807.4 people per mi2 • Dominant Age Group: 45-49 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |12
  • 13. SEFLA, Population Density by Rank, 2010 Broward County 1444.9 Miami-Dade County 1315.5 7-County SE Florida Region 807.4 Palm Beach County 670.2 St. Lucie County 485.7 Indian River County 274.5 Martin County 269.2 Monroe County 74.3Figure 3: SEFLA, Population Density by Rank, 2010Race & EthnicityThree primary categories of race and ethnicity are discussed within this analysis (White, African American, and Hispanic/Latino). Thesethree categories account for the large majority of all persons living in SEFLA. Persons of other ancestries or of two or more races are notanalyzed in this report because of their less significant representation within the study area. It is important to note, people of Hispanicorigin may be any race. This should be kept in mind when comparing race and ethnicity, which is done throughout the report.Someone of Black or White race may also be categorized as Hispanic due to Census methodology.Within this section, the spatial and segregation patterns of residence by race and ethnicity are the focus. Beyond segregation patterns,race & ethnicity are analyzed in conjunction with other variables throughout the remainder of the Regional Profile; in analyzingequitable access to fair housing, understanding the relationship of race and ethnicity to other germane variables is fundamentallyimportant. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |13
  • 14. Indian River 15,465 12,397 116,346 White Black or African American Hispanic or Latino:Map 2: Indian River County Race/Ethnicity Dot Map Figure 4: Indian River County, Population by Race/Ethnicity 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |14
  • 15. St. Lucie County 45,995 53,036 199,336 White Black or African American Hispanic or Latino:Map 3: St. Lucie County Race/Ethnicity Dot Map Figure 5: St. Lucie County, Population by Race/Ethnicity 2010Martin County CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |15
  • 16. 45,995 53,036 199,336 White Black or African American Hispanic or Latino: Figure 6: Martin County, Population by Race/Ethnicity 2010Map 4: Martin County Race/Ethnicity Dot MapPalm Beach County 250,823 White Black or African 228,690 American 970,121 Hispanic or Latino: Figure 7: Palm beach County, Population by Race/Ethnicity 2010Map 5: Palm Beach County Race/Ethnicity Dot Map CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |16
  • 17. Broward County White 438,247 Black or African American 467,519 1,102,231 Hispanic or Latino: Figure 8: Broward County, Population by Race/Ethnicity 2010Map 6: Broward County Race/Ethnicity Dot MapMiami-Dade County CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |17
  • 18. White 1,623,859 Black or 1,841,887 African American Hispanic or Latino: 472,976 Figure 9: Miami-Dade County, Population by Race/Ethnicity 2010Map 7: Miami-Dade County Race/Ethnicity Dot MapMonroe County 15,071 White 4,194 Black or African American 65,409 Hispanic or Latino:Map 8: Monroe County Race/Ethnicity Dot Map CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |18
  • 19. Figure 10: Monroe County, Population by Race/Ethnicity 2010SEFLA Region CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |19
  • 20. Within the regions total population of 6.1 million, nearly 4.5 million are white accounting for two thirds of the population. 2.1 million African American persons and 2.4 Hispanics of all races reside within the SEFLA jurisdictional boundary. Monroe, Martin, and Indian River Counties have the largest percentages of white people in comparison to their total 39% populations. Similarly within these counties, the Hispanic and Black populations are relatively dispersed. St. Lucie County White has higher percentages of minority populations than the three 71% previously mentioned counties. Additionally within St. Lucie Black or African there is a segregated concentration of African Americans to American 20% the south of the St. Lucie County International Airport. Palm Hispanic or Latino Beach, Broward, and Monroe are more diverse in population yet they also have higher levels of segregation. Areas where African Americans are highly concentrated include north Miami-Dade County, central Broward County, and the BelleFigure 11: Race/ethnicity for the SEFLA Region, 2010 Glade and West Palm Beach areas in Palm Beach County. Central Broward County and north Miami-Dade County both have neighborhoods of historical African American affiliation including Sistrunk, Lauderdale Lakes and Lauderhill in Broward and Opa-locka and Miami Gardens in Miami-Dade. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |20
  • 21. Housing Housing occupancy by tenancy and monthly housing costs are the two major variables analyzed within this section. A breakdown of these variables by race and ethnicity is also undertaken. Housing occupancy by tenure relates to neighborhood stability in that high rental turnover tends to lend itself to fluctuating neighborhood conditions which is generally viewed negatively. A housing unit is considered to be owner-occupied if the owner or co-owner lives in the unit, even if it is mortgaged or not fully paid for. All other occupied units are classified as "renter occupied," including units rented for cash rent and those occupied without payment of cash rent. Monthly housing costs as a percentage of household income provides information on the cost of monthly housing expenses for owners and renters. The information offers an excellent measure of housing affordability and excessive shelter costs. Households spending more than 30 percent of their monthly income on housing costs and considered cost-burdened and tend to be at risk of economic hardship over time. The trends of housing occupancy by tenancy and housing costs burden on a county scale are similar throughout the SEFLA. Throughout the region, the vast majority of housing units are owner-occupied. This trend holds true for the white population of each county, but is reversed for both Hispanics and African American households in each county. Renter- occupied households as a whole are more likely to spend more than 30% of their monthly income on housing costs than those that own. When considering various incomes, within lower income brackets there are more renters than owners. Also within this income range, households that rent have higher probabilities of paying above 30% of their household income than those that own. Conversely within the higher income brackets there are more owner-occupied housing units and henceforth more owners are cost-burdened in these brackets. Proportionally, however renting households making less than $20,000 are the most cost-burdened group within each county in SEFLA In the region as a whole, there are 1.5 million owner-occupied housing units in comparison to .75 million renter- occupied units. Spatially, in the urbanized areas of the counties, owner occupied housing is prominent inland in the more suburban areas. Conversely rental opportunities are more common in the eastern and denser portions of the region. The region has very high levels of cost-burdened households especially for renters. 60% of renting households, regardless of income, pay more than 30% of their monthly income on housing costs while 46% of household that own pay the same proportion. Moving into the future, more affordable housing options is a key issue for SEFLA. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |21
  • 22. Indian River Households paying 30% or more of their income on monthly housing costs, 2010 Indian River County 30.0% 25.0% 20.0% 15.0% 10.0% 5.0% 0.0% Less than $20,000 to $35,000 to $50,000 to $75,000 or $20,000 $34,999 $49,999 $74,999 more Owner-occupied Renter-occupied Figure 12: Indian River County, Cost Burdened households by tenure, 2010 Hispanic or Latino 14% origin 5% Black or African Owner- 14% 13,374 American 5% occupied housing units 81% White Renter- 44,186 occupied 93% housing units Renter-occupied housing unitsFigure 13: Indian River Tenancy by Race/Ethnicity, 2010 Figure 14: Indian River County, Housing Occupancy by Tenure, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |22
  • 23. CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |23
  • 24. St. Lucie County Households paying 30% or more of their income on monthly housing costs, 2010 St. Lucie County 25.0% 20.0% 15.0% 10.0% 5.0% 0.0% Less than $20,000 to $35,000 to $50,000 to $75,000 or $20,000 $34,999 $49,999 $74,999 more Owner-occupied Renter-occupied Figure 15: St. Lucie County, Cost Burdened households by tenure, 2010 18% Hispanic or Latino origin 9% Black or African 24% Owner- 24,763 American 12% occupied housing units 69% Renter- White occupied 84% 78,340 housing units Renter-occupied housing units Owner-occupied housing units Figure 16: St. Lucie County Tenancy by Race/Ethnicity, 2010 Figure 17: St. Lucie County, Housing Occupancy by Tenure, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |24
  • 25. CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |25
  • 26. Martin County Households paying 30% or more of their income on monthly housing costs, 2010 Martin County 25.0% 20.0% 15.0% 10.0% 5.0% 0.0% Less than $20,000 to $35,000 to $50,000 to $75,000 or $20,000 $34,999 $49,999 $74,999 more Owner-occupied Renter-occupied Figure 18: Martin County, Cost Burdened households by tenure, 2010 16% Hispanic or Latino origin 4% 12,140 Black or African 7% Owner-occupied American 2% housing units Renter-occupied 86% housing units White 47,063 96% Renter-occupied housing units Owner-occupied housing units Figure 20: Martin County, Housing Occupancy by Tenure, 2010Figure 19: Martin County, Tenancy by Race/Ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |26
  • 27. CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |27
  • 28. Palm Beach County Households paying 30% or more of their income on monthly housing costs, 2010 Palm Beach County 25.0% 20.0% 15.0% 10.0% 5.0% 0.0% Less than $20,000 to $35,000 to $50,000 to $75,000 or $20,000 $34,999 $49,999 $74,999 more Owner-occupied Renter-occupied Figure 21: Palm Beach County, Cost Burdened households by tenure, 2010 Hispanic or 21% Latino origin 10% Black or 138,155 Owner- 24% African occupied 9% American housing units 384,995 Renter- 67% occupied White 87% housing units Renter-occupied housing units Figure 23: Palm Beach County, Housing Occupancy by Tenure, 2010 Figure 22: Palm Beach County, Tenancy by Race/Ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |28
  • 29. CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |29
  • 30. Broward County Households paying 30% or more of their income on monthly housing costs, 2010 Broward County 25.0% 20.0% 15.0% 10.0% 5.0% 0.0% Less than $20,000 to $35,000 to $50,000 to $75,000 or $20,000 $34,999 $49,999 $74,999 more Owner-occupied Renter-occupied Figure 24: Broward County, Cost Burdened households by tenure, 2010 Hispanic or Latino origin 23% 18% Black or African 32% Owner- American 17% 205,387 occupied housing units White 59% 76% Renter- 463,511 occupied housing units Renter-occupied housing units Owner-occupied housing units Figure 25: Broward County, Tenancy by Race/Ethnicity, 2010 Figure 26: Broward County, Housing Occupancy by Tenure, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |30
  • 31. CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |31
  • 32. Miami-Dade County Households paying 30% or more of their income on monthly housing costs, 2010 Miami-Dade County 35.0% 30.0% 25.0% 20.0% 15.0% 10.0% 5.0% 0.0% Less than $20,000 to $35,000 to $50,000 to $75,000 or $20,000 $34,999 $49,999 $74,999 more Owner-occupied Renter-occupied Figure 27: Miami-Dade County, Cost Burdened households by tenure, 2010 Hispanic or Latino origin 66% 62% Owner- occupied Black or African 22% 347,024 housing units American 14% 480,532 Renter- occupied White 71% 79% housing units Renter-occupied housing units Owner-occupied housing unitsFigure 28: Miami-Dade County, Tenancy by Race/Ethnicity, 2010 Figure 29: Miami-Dade County, Housing Occupancy by Tenure, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |32
  • 33. Monroe County Households paying 30% or more of their income on monthly housing costs, 2010 Monroe County 20.0% 15.0% 10.0% 5.0% 0.0% Less than $20,000 to $35,000 to $50,000 to $75,000 or $20,000 $34,999 $49,999 $74,999 more Owner-occupied Renter-occupied Figure 30: Monroe County, Cost Burdened households by tenure, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |33
  • 34. 22% Hispanic or Latino origin 12% Owner- Black or African 8% occupied 10,581 American 3% housing units 19,210 Renter- occupied 89% housing units White 95% Renter-occupied housing units Owner-occupied housing units Figure 31: Monroe County, Tenancy by Race/Ethnicity, 2010 Figure 32: Monroe County, Housing Occupancy by Tenure, 2010SEFLA Region Table 3: Occupied Housing Units by Race/Ethnicity and Tenure, 2010- SEFLA Region Occupied housing Owner-occupied housing Renter-occupied housing units units units Total 2,269,261 1,517,837 751,424 White 84% 87% 75% Black or African 12% 9% 19% American Hispanic or Latino origin 19% 17% 26% CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |34
  • 35. Tenure of Occupied Housing Units: 751,424 1,517,837 Owner-occupied housing units Renter-occupied housing units Figure 33: SEFLA Region, Occupied Housing Units by tenure, 2010Map 9: Occupied Housing Units by tenure,2010, SEFLA Region CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |35
  • 36. Tenure of Occupied Housing by County and for the SEFLA Region 60% 58% 57% 56% 57% 61% 60% 46% 51% 48% 50% 46% 43% 42% 34% 35% Renter-occupied Renter-occupied Renter-occupied Renter-occupied Renter-occupied Renter-occupied Renter-occupied Renter-occupied Owner-occupied Owner-occupied Owner-occupied Owner-occupied Owner-occupied Owner-occupied Owner-occupied Owner-occupied7-County SE Florida Indian River St. Lucie County, Martin County, Palm Beach Broward County, Miami-Dade Monroe County, Region Average County, Florida Florida Florida County, Florida Florida County, Florida Florida Figure 34: Seven-50 SE Florida Region Occupied Housing Units by Tenure and County, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |36
  • 37. Households paying 30% or more of their income on monthly housing costs, 2010 SEFLA Region 20.00% 15.00% 10.00% 5.00% 0.00% Less than $20,000 to $35,000 to $50,000 to $75,000 or $20,000 $34,999 $49,999 $74,999 more Owner-occupied housing units Renter-occupied housing units Figure 35: Seve-50 SE Florida Region, Cost Burdened households by tenure, 2010 CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |37
  • 38. Poverty This section summarizes both individual and family poverty rates within the 7 counties individually as well as for SEFLA as a whole. Poverty indicators show the percentage of individuals or families that are below poverty threshold. The Census Bureau identifies poverty thresholds according to the composition of the household; different types of households (by age and size) have different poverty thresholds. Since poverty is defined at the family level and not the household level, the poverty status of the household is determined by the poverty status of the householder. “Population below poverty level” refers to the sum of people in families and the number of unrelated individuals identified as poor. We summarize individual poverty rates by race/ethnicity and age. The family poverty rate distinguishes between families and families with children under the age of 18, which is then further divided into various household types including married couples below the poverty level and single female householders below the poverty level. For SEFLA poverty is a large concern. In total there are over 850,000 people below poverty level, 13% percent of the total population. 15% of all families with children under the age of 18 are below the poverty level and of the population under 18, one fifth are living below the poverty line. Miami-Dade has the highest proportion of individuals living in poverty at 17%. Furthermore, poverty is clearly linked to race and ethnicity throughout the region. While the predominant race throughout the region is white, proportionally there are about half as many white people in poverty in comparison to both African American and Hispanic populations. Finally, our analysis identifies single female householders with children as especially in need. As a region, one third of all single-female households with children are below poverty level. In St. Lucie County, the proportion reaches its highest at 37% and within other counties the lowest this percentage reaches is 27% in Broward. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |38
  • 39. Indian River 16,984 9,322 5,322 2,340 Population for Under 18 years 18 to 64 years 65 years and whom poverty over status is determined Figure 36: Indian River County, Individuals below poverty level, 2010% Female householders with no 7.50% 31% husband present below White 27% Poverty Level 18.20% % Married Couples below 9% Black or African Poverty Level 5% American Hispanic or Latino origin 16% 23.80% (of any race) % Families Below Poverty Level 9% With related children under 18 years Families Figure 37: Indian River County, Family Poverty Rates, 2010 Figure 38: Indian River County, Poverty Rate by Race and Ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |39
  • 40. St. Lucie County 36,457 19,513 12,725 4,219 Population for Under 18 years 18 to 64 years 65 years and whom poverty over status is determined Figure 39: St. Lucie County, Individuals below poverty level, 2010 37% 7.70% % Female householders with no husband present below White 27% Poverty Level 19.00% % Married Couples below 9% Black or African Poverty Level 6% American Hispanic or Latino origin % Families Below Poverty 17% (of any race) Level 10% 19.60% With related children under 18 years Families Figure 40: St. Lucie County, Family Poverty Rates, 2010 Figure 41: St. Lucie County, Poverty Rate by Race and Ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |40
  • 41. CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |41
  • 42. Martin County 14,724 8,046 4,507 2,171 Population for Under 18 years 18 to 64 years 65 years and whom poverty over status is determined Figure 42: Martin County, Individuals below poverty level, 2010 4.80%% Female householders with no 34% husband present below White 25% Poverty Level % Married Couples below 7% Black or African Poverty Level 3% 17.30% American 30.90% Hispanic or Latino origin 13% (of any race) % Families Below Poverty Level 6% With related children under 18 years Families Figure 43: Martin County, Family Poverty Rates, 2010 Figure 44: Martin County, Poverty Rate by Race and Ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |42
  • 43. Palm Beach County 156,759 86,743 48,840 21,176 Population for Under 18 years 18 to 64 years 65 years and whom poverty over status is determined Figure 45: Palm Beach County, Individuals below poverty level, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |43
  • 44. 6.00%% Female householders with no 31% husband present below White 24% Poverty Level 16.60% % Married Couples below 7% Black or African Poverty Level 5% American Hispanic or Latino origin 15% (of any race)% Families Below Poverty Level 19.80% 9% With related children under 18 years Families Figure 46: Palm Beach County, Family Poverty Rates, 2010 Figure 47: Palm Beach County, Poverty Rate by Race and Ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |44
  • 45. Broward County 210,964 118,477 63,164 29,323 Population for Under 18 years 18 to 64 years 65 years and whom poverty over status is determined Figure 48: Broward County, Individuals below poverty level, 2010 6.20%% Female householders with no 27% husband present below 9.40% White 21% Poverty Level % Married Couples below 6% Black or African Poverty Level 5% American Hispanic or Latino origin 13% (of any race) % Families Below Poverty Level 9% 16.20% With related children under 18 years Families Figure 49: Broward County, Family Poverty Rates, 2010 Figure 50: Broward County, Poverty Rate by Race and Ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |45
  • 46. CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |46
  • 47. Miami-Dade County 410,093 217,985 118,792 73,316 Population for Under 18 years 18 to 64 years 65 years and whom poverty over status is determined Figure 51: Miami-Dade County, Individuals below poverty level, 2010% Female householders with no 35% 11.90% husband present below 13.90% White 26% Poverty Level % Married Couples below 10% Black or African Poverty Level 9% American Hispanic or Latino origin 18% (of any race) % Families Below Poverty Level 14% 22.10% With related children under 18 years Families Figure 52: Miami-Dade County, Family Poverty Rates, 2010 Figure 53: Miami-Dade County, Poverty Rate by Race and Ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |47
  • 48. CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |48
  • 49. Monroe County 7,776 5,327 1,275 1,174 Population for Under 18 years 18 to 64 years 65 years and whom poverty over status is determined Figure 54: Monroe County, Individuals below poverty level, 2010 6.70%% Female householders with no 30% husband present below White 25% Poverty Level 12.60% % Married Couples below 3% Black or African Poverty Level 4% American Hispanic or Latino origin 10% (of any race) % Families Below Poverty Level 7% 12.40% With related children under 18 years Families Figure 55: Monroe County, Family Poverty Rates, 2010 Figure 56: Monroe County, Poverty Rate by Race and Ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |49
  • 50. SEFLA Region 853,757 465,413 254,625 133,719 Population for Under 18 years 18 to 64 years 65 years and whom poverty over status is determined Figure 57: SEFLA Region, Individuals below poverty level, 2010% Female householders with 7.26% 32%no husband present below 25% Poverty Level White % Married Couples below 7% 17.23% Poverty Level 5% Black or African American % Families Below Poverty 15% Level 9% Hispanic or Latino origin (of any race) 18.74% With related children under 18 years FamiliesFigure 58: SEFLA Region, Family Poverty Rates, 2010 Figure 59: SEFLA Region, Poverty Rate by Race and Ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |50
  • 51. 17% 14% 13% 12% 12% 10% 11% Figure 61: SEFLA Region, Percent Population below poverty level by county, 2010Figure 60: SEFLA Region, Percent Population below poverty level by census tract, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |51
  • 52. Labor Force and Commuting This section examines the labor force participation rate as well as basic commuting trends by county and for the region. The labor force participation rate is a representation of the proportion of the area’s population in the labor force. This includes both employed and unemployed (job-seeking) civilians 16 years and over as well as members of the U.S. Armed Forces (people on active duty with the United States Army, Air Force, Navy, Marine Corps, or Coast Guard). Conversely, those not in the labor force includes all people 16 years old and over who are not accounted for by the labor force participation rate. These are typically students, retired workers, homemakers, institutionalized people and people doing incidental unpaid family work. Of the 7 counties, Broward has the highest labor force participation rate at 68%. Both Martin and Indian River have the lowest at 55%. The region on average has a labor force participation of 60% compared to 65% in the United State. Commuting trends may seem out of place in a fair housing assessment but commuting patterns are directly reflective of the relationship between housing and jobs. To understand commuting trends in this section we summarize mean travel time to work by mode of travel, mode of travel by tenure, and mode of travel by race/ethnicity. Mean travel time to work is measured in minutes and represents the average travel time that workers usually took to get from home to work. The travel time also accounts for time spent waiting for public transportation, as well as for picking up carpool passengers. Mode of travel refers to the method of transportation used to get from home to work. High travel times may indicate an imbalance between jobs and housing. Similarly the relationship between tenure and transportation mode can inform the type of transportation options that should be readily available to certain demographics. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |52
  • 53. We find in the region that individuals utilizing public transportation options have higher average travel times to work.And in all counties more renters use public transit than homeowners. The same is true of minorities in comparison to whitepersons. Overall there is a staggering difference between those that drive alone (78% in the 7-county area) and thosethat use public transportation only (4%). This all indicates that efficient public transportation options are lackingthroughout the entire region—the development of which are especially essential near areas that are primarily minorityand renter-occupied when employment opportunities are not located near these areas. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |53
  • 54. Indian River 50 40 30 45.50% 20 10 54.50% 0 Total Drive Alone Carpool Public transportation In labor force Not in labor force Mean travel time to work (minutes) Figure 62: Indian River County, Labor Force, 2010 Figure 63: Indian River County, Mean Travel Time to Work by Travel Mode, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |54
  • 55. 100.00% 90.00%80.00% 80.00%70.00% 70.00%60.00% 60.00%50.00% 50.00% 40.00%40.00% 30.00%30.00% 20.00%20.00% 10.00%10.00% 0.00% 0.00% White Black or African American Owner-occupied housing units Renter-occupied housing units Hispanic or Latino origin (of any race) Figure 64: Indian River County, Travel Mode by housing tenure, 2010 Figure 65: Indian River County, Travel Mode by race/ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |55
  • 56. St. Lucie County 70 60 50 41.60% 40 30 58.40% 20 10 In labor force Not in labor force 0 Total Drive Alone Carpool Public transportation Figure 66: St. Lucie County, Labor Force, 2010 Mean travel time to work (minutes) Figure 67: St. Lucie County, Mean Travel Time to Work by Travel Mode, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |56
  • 57. 80.00% 90.00% 80.00% 70.00% 70.00% 60.00% 60.00% 50.00% 50.00% 40.00% 40.00% 30.00% 30.00% 20.00% 20.00% 10.00% 10.00% 0.00% 0.00% White Black or African American Owner-occupied housing units Hispanic or Latino origin (of any Renter-occupied housing units race) Figure 68: St. Lucie County, Travel Mode by housing tenure, 2010 Figure 69: St. Lucie County, Travel Mode by race/ethnicity, 2010Martin County CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |57
  • 58. 27 26 25 45.30% 24 23 22 54.70% 21 20 Total Drive Alone Carpool Public In labor force Not in labor force transportation Mean travel time to work (minutes) Figure 70: Martin County, Labor Force, 2010 Figure 71: Martin County, Mean Travel Time to Work by Travel Mode, 2010 100.00%90.00% 90.00%80.00% 80.00%70.00% 70.00%60.00% 60.00%50.00% 50.00%40.00% 40.00%30.00% 30.00%20.00% 20.00%10.00% 10.00% 0.00% 0.00% White Black or African American Owner-occupied housing units Hispanic or Latino origin (of any Renter-occupied housing units race) Figure 72: Martin County, Travel Mode by housing tenure, 2010 Figure 73: Martin County, Travel Mode by race/ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |58
  • 59. Palm Beach County 50 40 39.50% 30 20 10 60.50% 0 Total Drive Alone Carpool Public In labor force Not in labor force transportation Mean travel time to work (minutes) Figure 74: Palm Beach County, Labor Force, 2010 Figure 75: Palm Beach County, Mean Travel Time to Work by Travel Mode, 2010 80.00% 70.00% 60.00% 50.00% 40.00% 30.00% 20.00% 10.00% 0.00% White Black or African American Hispanic or Latino origin (of any race) Figure 77: Palm Beach County, Travel Mode by race/ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |59
  • 60. 80.00%70.00%60.00%50.00%40.00%30.00%20.00%10.00% 0.00% Owner-occupied housing units Renter-occupied housing units Figure 76: Palm Beach County, Travel Mode by housing tenure, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |60
  • 61. Broward County 60 50 40 32.60% 30 20 67.40% 10 0 Total Drive Alone Carpool Public In labor force Not in labor force transportation Mean travel time to work (minutes) Figure 78: Broward County, Labor Force, 2010 Figure 79: Broward County, Mean Travel Time to Work by Travel Mode, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |61
  • 62. 80.00% 80.00% 70.00% 70.00% 60.00% 60.00% 50.00% 50.00% 40.00% 40.00% 30.00% 30.00% 20.00% 20.00% 10.00% 0.00% 10.00% 0.00% White Owner-occupied housing units Black or African American Renter-occupied housing units Hispanic or Latino origin (of any race) Figure 80: Broward County, Travel Mode by housing tenure, 2010 Figure 81: Broward County, Travel Mode by race/ethnicity, 2010Miami-Dade County CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |62
  • 63. 50 40 30 37.20% 20 10 62.80% 0 Total Drive Alone Carpool Public transportation In labor force Not in labor force Mean travel time to work (minutes) Figure 82: Miami-Dade County, Labor Force, 2010 Figure 83: Miami-Dade County, Mean Travel Time to Work by Travel Mode, 2010 90.00%70.00% 80.00%60.00% 70.00%50.00% 60.00% 50.00%40.00% 40.00%30.00% 30.00% 20.00%20.00% 10.00%10.00% 0.00% 0.00% White Owner-occupied housing units Black or African American Renter-occupied housing units Hispanic or Latino origin (of any race) Figure 84: Miami-Dade County, Travel Mode by housing tenure, 2010 Figure 85: Miami-Dade County, Travel Mode by race/ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |63
  • 64. Monroe County 25 20 35.00% 15 10 65.00% 5 0 In labor force Not in labor force Total Drive Alone Carpool Public transportation Mean travel time to work (minutes) Figure 86: Monroe County, Labor Force, 2010 Figure 87: Monroe County, Mean Travel Time to Work by Travel Mode, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |64
  • 65. 80.00% 100.00% 90.00%70.00% 80.00%60.00% 70.00%50.00% 60.00% 50.00%40.00% 40.00%30.00% 30.00%20.00% 20.00%10.00% 10.00% 0.00% 0.00% White Owner-occupied housing units Black or African American Renter-occupied housing units Hispanic or Latino origin (of any race) Figure 88: Monroe County, Travel Mode by housing tenure, 2010 Figure 89: Monroe County, Travel Mode by race/ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |65
  • 66. SEFLA Region 0% 20% 40% 60% 80% 100% 50 Indian River County 40 Martin County 30 St. Lucie County Palm Beach County 20 Broward County 10 Miami-Dade County Monroe County 0 7-County SE Florida Region Total Drive Alone Carpool Public transportation Mean travel time to work (minutes) In labor force Not in labor force Figure 90: SEFLA Region, Labor Force by County, 2010 Figure 91: SEFLA Region, Mean Travel Time to Work by Travel Mode, 2010 80% 90% 70% 80% 70% 60% 60% 50% 50% 40% 40% 30% 30% 20% 20% 10% 10% 0% Total Drive Alone Carpool Public 0% transportation Total Drive Alone Carpool Public transportation White Owner-occupied housing units Black or African American Renter-occupied housing units Hispanic or Latino origin (of any race)Figure 92: SEFLA Region, Travel Mode by housing tenure, 2010 Figure 93: SEFLA Region, Travel Mode by race/ethnicity, 2010 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |66
  • 67. Travel Mode By County, 2010 0% 10% 20% 30% 40% 50% 60% 70% 80% Drive Alone CarpoolPublic Transportation Indian River County, Florida St. Lucie County, Florida Martin County, Florida Palm Beach County, Florida Broward County, Florida Miami-Dade County, Florida Monroe County, Florida 7-County SE Florida Region Figure 94: SEFLA Region, County, Travel Mode by County CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |67
  • 68. 3. Fair Housing Legal EvaluationFair Housing Laws and Programs Housing development and the affordability of what is produced is highly influenced both by public and private forces such as real estate markets, profits, zoning, land use, impact fees, and concurrency requirements. The existence of a regulatory framework is necessary to promote and protect fair housing opportunities. This section summarizes existing fair housing laws and programs at the federal, state, and local level.Federal Fair Housing Act & U.S. HUD, Fair Housing and Equal Opportunity The 1968 Fair Housing Act prohibits discrimination during the sale and rental of housing so that all people in the United States have an increased opportunity to maintain stable and healthy lives for themselves and their families. As amended by the Fair Housing Amendments Act of 1988, it is unlawful to discriminate on the basis of race, color, sex, religion, national origin, disability and familial status. The U.S. Department of Housing and Urban Development (HUD), and on occasion the U.S. Department of Justice, is responsible for investigating and enforcing violations of the Fair Housing Act. HUD also provides Fair Housing Assistance Program (FHAP) funds annually and on a noncompetitive basis to State and local agencies that enforce fair housing laws substantially equivalent to the Fair Housing Act.Florida Fair Housing The Florida Fair Housing Act1, which closely reiterates the Federal Fair Housing Act, was passed by the Florida Legislature in 1983, and amended in 1989. It declares it illegal to discriminate in the sale, rental, advertising, financing, or brokerage of housing. It goes on further to ensure the accessibility of all new multifamily developments built within Florida. The preceding Regional Profile section highlights that affordable housing options, which are integral to fair housing opportunity, are a problem for SEFLA. The issue of affordable housing has been long debated in Florida and there are a number of programs to fund this initiative. In Florida, Section 163.3177 Fla. Stat. (2000) and Rule 9J-5 of the Florida Administration Code require that each community, county and the State of Florida adopt a housing element in their Comprehensive Plan which must contain standards, plans, and principles to create and preserve safe and healthy affordable housing options. Of these laws the William E. Sadowski Affordable Housing Act, passed in 1992 is notably important. The act established one of the largest dedicated trust funds for affordable housing. Revenues are generated through a documentary stamp tax, a real estate transfer fee levied when registering a deed or mortgage into public records. The Sadowski Act increased the existing documentary stamp tax by 10 cents per $100 (from 60 cents to 70 cents)1 State of Florida, Civil Rights Statutes, Title XLIX, Chapter 760.2 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |68
  • 69. for the purposes of funding housing programs in the State. Three years later, the bill reallocated an additional 10 cents tothe housing trust. The funds are uniquely tied to the real estate market so that revenues increase as housing prices (andthe subsidy required to house Florida’s workforce) increase. The Sadowski Act not only funded existing state housing programs such as the Predevelopment Loan Program (PLP),the State Apartment Incentive Loan (SAIL), and the Homeownership Assistance Program (HAP) but also establishedseveral new initiatives, including the Low-Income Emergency Home Repair Program, the HOME Investment PartnershipsProgram, the HOPE Program, the Florida Affordable Housing Guarantee Program, the Affordable Housing CatalystProgram for Technical Assistance and Training, and the State Housing Initiatives Partnership Program (SHIP). Programsranged from rental housing, homeownership, special needs, and more recently, disaster relief and workforce housing. The Florida Housing Finance Corporation (Florida Housing) was designated as the administrator for all of the programs,directing 30 percent of the revenue into a statewide trust and the other 70 percent into a local housing trust. The localfunds are distributed to all 67 counties and 48 entitlement cities in the State through the SHIP program. The SHIP programensures both accountability and flexibility. • Accountability: In order to receive funding, each local government must adopt a SHIP Plan in accordance with state guidelines and local comprehensive plans.   • Flexibility: Local jurisdictions are able to direct money towards the specific needs of their community. Locally adopted strategies set-aside funding for extremely low to moderate-income households and support a variety of services, including new construction, rehabilitation, down payment assistance, homebuyer education, and foreclosure prevention.    When the Florida House and Senate entered the 2008 session, they were confronted with a major budget shortfall. Thecurrent fiscal year faced over $1 billion deficit, estimates for 2009 were upwards of $3 billion. Legislators were forced to cutprograms, limit spending, and search for other sources of revenue. Consequently, the Florida Legislature transferred $250million from dedicated affordable housing trust funds to general revenue. They also implemented a $243 million cap onexisting and future funding for affordable housing. Funds generated through the Sadowski Act above that amount will beautomatically deposited into general revenue. It is estimated that as a result of the cap, an additional $185 million inhousing funds will be lost over the next two years (FY07-08 and FY 08-09).   Although the budget cuts took place in the 2007-2008 fiscal year, they were originally authorized three years earlier(prior to the budget crisis) under Governor Jeb Bush. The cap was approved after attempts to completely remove thehousing trust fund failed in the 2003 and 2004 Legislative Sessions. The Governor decided to “maintain trust fund spending CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |69
  • 70. at levels consistent with historical expectations while using windfall revenues to fund other priorities.” Housing advocates argued that this view was misleading. They claimed that while revenues into the housing trust funds had grown substantially since their creation, funding was purposely tied to documentary stamp tax revenues so that subsidies for affordable housing would rise as the cost of land, construction and housing increased.   The loss of these revenues has drastically cut local housing programs. Housing supporters continue to advocate to the State to “scrap the cap” and reauthorize the Sadowski Act, which is set to sunset. In the meantime, there is a strong need for a dedicated source of funding for affordable housing at the Regional, County and City level. Both a linkage fee program and inclusionary housing program have been considered, but never created.Fair Housing Assistance Agencies within SEFLA Table 4: SEFLA Fair Housing Assistance Agencies County Name Agency Type State Agency; N/A- State Level Federal Commission on Human Rights Government Legal Aid Society of Palm Beach County Private Palm Beach Palm Beach County Office of Equal Government Opportunity Broward County Office of Equal Broward Government Opportunity | Civil Right Division Housing Opportunities for Project Private Excellence, H.O.P.E Inc. Miami Miami-Dade Office of Human Rights and Government Fair Employment Practices (OHRFEP) CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |70
  • 71. Existing Assisted Housing Inventory2 77688 Table 5: Total Properties and Units, Assisted Housing Number of Total Assisted % 40514 Properties Units Units Assisted Indian River 26 2,858 2,856 99.9% 17129 St. Lucie 18 2,623 2,480 95% 12652 2856 2480 1219 838 Martin 17 1,221 1,219 100% Palm Beach 93 13,802 12,652 92% Broward 121 21,116 17,129 81% Miami-Dade 334 42,346 40,514 96% Monroe 17 861 838 97% 7-County SE Florida Region 626 84,827 77,688 94.3% Figure 95: Assisted Housing Units By County Population Rank Assisted Units Rank Within SEFLA there are currently 626 properties providing assisted housing units for a total of almost 78- Indian River 6 4 thousand units. These assisted units are highly St. Lucie 4 5 concentrated: 94% of all units within properties that Martin 5 6 offer assisted units are assisted. Miami-Dade, Broward, Palm Beach 3 3 Palm Beach, and Monroe are consistent in their ranking Broward 2 2 of assisted units in comparison to their rank in Miami-Dade 1 1 population. However, Indian River ranks 6th in Monroe 7 7 population yet has more assisted units than St. Lucie Table 6: Assisted Housing Units and Population, Ranks by County and Martin counties which both have higher population totals.2 All data within the Existing Assisted Housing Inventory is drawn from the Florida Housing Data Clearinghouse CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |71
  • 72. Table 7 Income Restrictions, Florida Housing Properties Number of Units Designated for Renters with Income: Various assisted housing units are <=35% AMI 40-50% AMI 55-60% AMI 65-80% AMI >80% AMI reserved for renters in certain incomeIndian River 100 423 1790 8 0 brackets. The vast majority of these areSt. Lucie 179 209 1853 0 0 for renters in the 55-60% AMI. Regionally,Martin 60 50 770 1 0 there are 44 thousand units designatedPalm Beach 344 825 7708 324 62 for this income bracket. For those in theBroward 460 652 9870 212 512 lowest income bracket, and thereforeMiami-Dade 1537 3505 21771 136 40 those in the greatest need of housingMonroe 73 57 555 121 13 opportunities designated specifically forSEFLA 2753 5721 44317 802 627 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |72
  • 73. them, only 627 units are designated for Figure 96: Number of Units Designated for Renters with Income at these renters across the 7-county SEFLA 0 5000 10000 15000 20000 region. 512 of these are in Broward County compared to 40 in Miami-Dade Indian River where 17% of the population is below poverty level and zero in Indian River, St. St. Lucie Lucie and Martin Counties. Martin Palm Beach Broward Miami-Dade Monroe <=35% AMI 40-50% AMI 55-60% AMI 65-80% AMI >80% AMI Table 8 Target Population, Assisted Housing Figure 97: Target Population, Assisted Housing, SEFLA Family Elderly Farmworker Fisher Homeless Persons with DisabilitiesIndian River 2294 685 426 - - 16 St. Lucie 2090 286 104 - - - Martin 1055 140 117 - - 24Palm Beach 10170 3628 916 - 93 46 Broward 14383 4202 173 - - 71Miami-Dade 28835 11981 1582 - 815 318 Monroe 777 28 14 92 - 19 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |73
  • 74. SEFLA 59604 20950 3332 92 908 494 Family Elderly Farmworker Fisher Homeless Persons with Disabilities Figure 98: Target Population, Assisted Housing, By County The target population for the vast majority Monroe of assisted housing is families followed by elderly peoples, farmworkers, homeless, Persons withMiami-Dade Disabilities persons with disabilities, and finally fishers (this is only a target population in Monroe Homeless County). All 7 counties have assisted Broward housing targeting families, elderly and farmworkers. St. Lucie county is alone in its Fisher lack of any assisted housing targetingPalm Beach persons with disabilities. Finally homeless Farmworker people are the target populations for Martin assisted housing in only Palm Beach and Miami-Dade. Elderly St. Lucie FamilyIndian River 0 5000 10000 15000 20000 25000 30000 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |74
  • 75. Figure 99: Race and Ethnicity of Tenants in Assisted Housing Units as of 2008 Table 9 Race and Ethnicity of Tenants in Assisted Housing Units as of 2008 % Minority % Black % Hispanic 100% Indian River 8% 6% 0% 90% 80% St. Lucie 81% 72% 9% 70% Martin 10% 2% 6% 60% 50% Palm Beach 58% 37% 21% 40% Broward 68% 43% 24% 30% 20% Miami-Dade 91% 21% 70% 10% Monroe 61% 9% 52% 0% SEFLA 54% 27% 26% % Minority % Black % Hispanic 54% of the region’s assisted housing units have minority tenants; 27% are Black and 26% Hispanic. Miami-Dade has the highest percentage of minority tenants at 91% followed by St. Lucie County at 81% (72% or which are Black). People of Hispanic origin occupy notably none of Indian River’s assisted housing units. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |75
  • 76. Fair Housing Discrimination Complaints: 2007-2012 This section details fair housing complaints reported to various authorized Fair Housing Agencies (FHAP) throughout the region. The year that cases are closed in is the year that those complaints are accounted for. Data was collected from various sources: 1) already completed AIs for Palm Beach, Broward, and Miami-Dade Counties, 2) data compiled by HUD for all seven counties for years 2010-2012 specifically for the purposes of this report, 3) public records requests from the Florida Commission on Human Rights as well as the Palm Beach and Miami-Dade County Offices of Equal Opportunity. It should be noted, that the total number of bases/issues in the housing discrimination complaint tables are not necessarily equal to the total number of individuals that filed complaints because oftentimes, the complaints alleged multiple bases and issues. Similarly, there may be overlap of reports between tables so trends therefore summary of the proportions of the basis for complaints are examined as opposed to total numbers. Furthermore, national studies conducted by HUD provide evidence of a major underreporting of housing discriminations3. Therefore, the following trends can be used as a tool to begin understanding housing discrimination within SEFLA but should not be interpreted to represent the problem of housing discrimination exhaustively.3 “Do We Know More Now? Trends in Public Knowledge, Support, and Use of Fair Housing Laws,” 2006 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |76
  • 77. Indian River County Indian River County, Florida Table 10 Housing Discrimination Complaints- 2010-8/31/2012 Reported to HUD/FHAP 2010 2011 2012 Total % RACE 0 0 0 0 0% COLOR 0 0 0 0 0% NATIONAL ORIGIN 0 0 2 2 12% RELIGION 0 0 0 0 0% SEX 1 0 1 2 12% FAMILIAL STATUS 0 0 1 1 6% DISABILITY 2 2 5 9 53% AGE 0 0 0 0 0% OTHER 0 1 2 3 18% Total 3 3 11 17 Indian River County, Florida Table 11 Housing Discrimination Complaints- 2007-2012 Florida Commission on Human Relations % 2007 2008 2009 2010 2011 2012 Total RACE 0 1 0 0 0 0 1 5% COLOR 0 0 0 0 0 0 0 0% NATIONAL ORIGIN 0 0 8 0 0 0 8 42% RELIGION 0 0 0 0 0 0 0 0% SEX 0 0 0 0 0 0 0 0% FAMILIAL STATUS 0 1 0 0 0 0 1 5% DISABILITY 1 3 1 1 0 2 8 42% AGE 0 0 0 0 0 0 0 0% OTHER 0 1 0 0 0 0 1 5% Total 1 6 9 1 0 2 19 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |77
  • 78. Figure 100: Average Summary Percentage of Housing Complaints for all Cited Figure 101: Summary of Housing Discrimination Complaints, By Year, Indian River Agencies, Indian River County, 2007-2012 County, 2007-2012 40% 3% RACE 35% 11% COLOR 30% NATIONAL ORIGIN 25% 27% RELIGION 20% SEX 15% FAMILIAL STATUS 10% 6% 48% DISABILITY 6% 5% AGE 0% OTHER 2007 2008 2009 2010 2011 2012Table 12: Bases for Discrimination Complaints, Rank and Proportion, Indian RiverCounty 2007-2012 Basis % Rank DISABILITY 48% 1 There are relatively few fair housing complaints in Indian NATIONAL ORIGIN 27% 2 River. Lower population levels as well as a lack of local OTHER 11% 3 fair housing agencies may account this for. 48% of complaints registered over the 5 years are based on SEX 6% 4 disability discrimination, and 27% are related to national FAMILIAL STATUS 6% 5 origin. There are no fair housing complaints in alleged RACE 3% 6 discrimination of religion, color, or age. 2012 showed a RELIGION 0% 7 general spike in the proportion of complaints overall. COLOR 0% 8 AGE 0% 9 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |78
  • 79. CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |79
  • 80. St. Lucie County St. Lucie County, Florida Table 13 Housing Discrimination Complaints- 2010-8/31/2012 By HUD or FHAP 2010 2011 2012 Total % RACE 5 0 0 5 25% COLOR 0 0 0 0 0% NATIONAL ORIGIN 2 0 0 2 10% RELIGION 1 0 0 1 5% SEX 2 0 0 2 10% FAMILIAL STATUS 4 1 0 5 25% DISABILITY 2 2 1 5 25% AGE 0 0 0 0 0% OTHER 0 0 0 0 0% Total 16 3 1 20 St. Lucie County, Florida Table 14: Housing Discrimination Complaints- 2007-2012 Florida Commission on Human Relations 2007 2008 2009 2010 2011 2012 Total % RACE 2 4 2 1 0 0 9 24% COLOR 0 0 0 0 0 0 0 0% NATIONAL ORIGIN 0 0 0 0 0 0 0 0% RELIGION 0 0 0 0 0 0 0 0% SEX 0 0 2 1 0 0 3 8% FAMILIAL STATUS 0 4 1 2 1 0 8 21% DISABILITY 2 9 3 1 1 1 17 45% AGE 0 0 0 0 0 0 0 0% OTHER 0 1 0 0 0 0 1 3% CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |80
  • 81. Total 4 18 8 5 2 1 38 CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |81
  • 82. Figure 102: Average Summary Percentage of Housing Complaints for all Cited Figure 103: Summary of Housing Discrimination Complaints, By Year, St. Lucie Agencies, St. Lucie County, 2007-2012 County, 2007-2012 40% 1% 35% RACE 30% COLOR 25% 24% NATIONAL ORIGIN 20% 35% RELIGION 15% SEX 5% 10% FAMILIAL STATUS 3% 5% DISABILITY 9% 0% AGE 2007 2008 2009 2010 2011 2012 23% OTHERTable 15: Bases for Discrimination Complaints, Rank and Proportion, St. Lucie Since 2010 the number of complaints has beenCounty 2007-2012 declining in St. Lucie but over the five-year period the number of reported cases has varied substantially. 35% Basis % Rank of complaints from 2007-2012 are based in disability DISABILITY 35% 1 discrimination, 24% for race and 23% for familial status. RACE 24% 2 There are no registered fair housing complaints for FAMILIAL STATUS 23% 3 either age or color. SEX 9% 4 NATIONAL ORIGIN 5% 5 RELIGION 3% 6 OTHER 1% 7 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |82
  • 83. COLOR 0% 8 AGE 0% 9Martin County Martin County, Florida Table 16: Housing Discrimination Complaints- 2010-8/31/2012 By HUD or FHAP 2010 2011 2012 Total % RACE 1 1 0 2 13% COLOR 0 0 0 0 0% NATIONAL ORIGIN 0 1 0 1 6% RELIGION 0 0 0 0 0% SEX 0 1 0 1 6% FAMILIAL STATUS 0 0 0 0 0% DISABILITY 4 2 4 10 63% AGE 0 0 0 0 0% OTHER 1 1 0 2 13% Total 6 6 4 16 Martin County, Florida Table 17: Housing Discrimination Complaints- 2007-2012 Florida Commission on Human Relations 2007 2008 2009 2010 2011 2012 Total % RACE 0 1 0 1 1 0 3 9% COLOR 0 0 0 0 0 0 0 0% NATIONAL ORIGIN 1 0 1 1 1 0 4 12% RELIGION 0 0 1 2 0 0 3 9% SEX 0 2 0 0 3 0 5 15% FAMILIAL STATUS 0 2 1 0 0 0 3 9% DISABILITY 1 2 0 7 2 2 14 42% AGE 0 0 0 0 0 0 0 0% CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |83
  • 84. OTHER 0 0 0 0 1 0 1 3% Total 2 7 3 11 8 2 33 CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |84
  • 85. Figure 104 Average Summary Percentage of Housing Complaints for all Cited Figure 105 Summary of Housing Discrimination Complaints, By Year, Martin Agencies, Martin County, 2007-2012 County, 2007-2012 40% 35% 8% 11% RACE 30% COLOR 25% 9% NATIONAL ORIGIN 20% RELIGION 5% 15% SEX 10% 11% FAMILIAL STATUS 52% DISABILITY 5% 5% AGE 0% 2007 2008 2009 2010 2011 2012 OTHERTable 18: Bases for Discrimination Complaints, Rank and Proportion, Martin In Martin county between 2007 and 2012 over half ofCounty 2007-2012 Basis % Rank the registered fair housing complaints are against disability discrimination. All other categories (besides DISABILITY 52% 1 color, for which there are no complaints) range from 5- RACE 11% 2 11%. There was a rise in the proportion of complaints in SEX 11% 3 2010. NATIONAL ORIGIN 9% 4 OTHER 8% 5 RELIGION 5% 6 FAMILIAL STATUS 5% 7 COLOR 0% 8 AGE 0% 9 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |85
  • 86. CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |86
  • 87. Palm Beach County Palm Beach County, Florida Table 19: Housing Discrimination Complaints- 2010-8/31/2012 By HUD/FHAP 2010 2011 2012 Total % RACE 26 16 10 52 18% COLOR 2 3 1 6 2% NATIONAL ORIGIN 18 10 6 34 12% RELIGION 3 3 2 8 3% SEX 10 7 2 19 7% FAMILIAL STATUS 18 9 4 31 11% DISABILITY 54 42 32 128 44% AGE 0 0 0 0 0% OTHER 3 9 2 14 5% Total 134 99 59 292 Palm Beach County, Florida Table 20: Housing Discrimination Complaints- 2007-2012 Florida Commission on Human Relations 2007 2008 2009 2010 2011 2012 Total % RACE 0 0 0 1 1 0 2 12% COLOR 0 0 0 0 0 0 0 0% NATIONAL ORIGIN 0 0 0 1 0 0 1 6% RELIGION 0 0 0 0 0 0 0 0% SEX 0 1 0 1 0 1 3 18% FAMILIAL STATUS 1 1 0 0 1 0 3 18% DISABILITY 0 4 0 0 3 0 7 41% AGE 0 0 0 0 0 0 0 0% OTHER 0 0 0 0 1 0 1 6% CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |87
  • 88. Total 1 6 0 3 6 1 17 Palm Beach County, Florida Table 21: Housing Discrimination Complaints- FY 2007-2012 Legal Aid Society Of Palm Beach County, Inc. 2007 2008 2009 2010 2011 2012 Total % RACE 11 16 15 9 11 --- 62 17% COLOR 0 0 0 0 0 --- 0 0% NATIONAL ORIGIN 12 20 17 9 16 --- 74 20% RELIGION 1 1 0 0 0 --- 2 1% SEX 6 3 1 1 1 --- 12 3% FAMILIAL STATUS 5 3 14 8 6 --- 36 10% DISABILITY 31 25 15 33 38 --- 142 39% AGE 2 4 8 10 0 --- 24 7% OTHER 4 2 2 2 0 --- 10 3% Total 72 74 72 72 72 --- 362 Palm Beach County, Florida Table 22: Housing discrimination Complaints- FY 2007-2012 Palm Beach County Office of Equal Opportunity 2007 2008 2009 2010 2011 2012 Total % RACE 25 13 13 20 16 14 101 19% COLOR 0 0 0 0 0 0 0 0% NATIONAL ORIGIN 12 6 6 15 7 7 53 10% RELIGION 1 1 3 2 1 2 10 2% SEX 4 0 4 6 4 5 23 4% FAMILIAL STATUS 15 9 24 30 1 9 88 16% CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |88
  • 89. DISABILITY 33 37 43 51 44 33 241 45% AGE 0 2 2 0 1 1 6 1% OTHER 6 2 1 2 2 3 16 3% Total 96 70 96 126 76 74 538 CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |89
  • 90. Figure 106: Average Summary Percentage of Housing Complaints for all Cited Figure 107: Summary of Housing Discrimination Complaints, By Year, Palm Beach Agencies, Palm Beach County, 2007-2012 County, 2007-2012 30% 2% 25% 4% RACE 16% 20% COLOR 1% NATIONAL ORIGIN 15% RELIGION 12% 10% SEX 42% 5% FAMILIAL STATUS 1% 8% DISABILITY 0% AGE 2007 2008 2009 2010 2011 2012 14% OTHERTable 23: Bases for Discrimination Complaints, Rank and Proportion, Palm Beach Palm Beach County had a spike in 2010 for fairCounty 2007-2012 Basis % Rank housing complaints, and overall has larger number of complaints than its three northern counterparts. This DISABILITY 42% 1 makes sense given the larger population however as RACE 16% 2 well as the fact that there are two local FHAPs, the FAMILIAL STATUS 14% 3 Palm Beach County Office of Equal Opportunity and NATIONAL ORIGIN 12% 4 the Legal Aid Society of Palm Beach County. 42% of SEX 8% 5 complaints are based on discrimination against OTHER 4% 6 disability, 16% against race, 14% against familial status, AGE 2% 7 and 12% against national origin. RELIGION 1% 8 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |90
  • 91. COLOR 1% 9 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |91
  • 92. Broward County Broward County, Florida Table 24: Housing discrimination Complaints- 2010-8/31/2012 By HUD/FHAP 2010 2011 2012 Total % RACE 27 32 13 72 20% COLOR 0 4 0 4 1% NATIONAL ORIGIN 22 28 10 60 16% RELIGION 4 2 2 8 2% SEX 8 6 5 19 5% FAMILIAL STATUS 18 13 6 37 10% DISABILITY 74 40 36 150 41% AGE 0 0 0 0 0% OTHER 6 2 8 16 4% Total 159 127 80 366 Broward County, Florida Table 25: Housing discrimination Complaints- 2007-2012 Florida Commission on Human Relations 2007 2008 2009 2010 2011 2012 Total % RACE 0 4 5 4 3 0 16 21% COLOR 0 0 1 0 0 0 1 1% NATIONAL ORIGIN 1 4 2 2 3 1 13 17% RELIGION 0 2 2 1 0 0 5 7% SEX 0 2 1 1 1 0 5 7% FAMILIAL STATUS 1 3 0 2 2 2 10 13% DISABILITY 2 4 6 9 3 1 25 33% AGE 0 0 0 0 0 0 0 0% CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |92
  • 93. OTHER 0 0 0 0 0 0 0 0% Total 4 19 17 19 12 4 75 Broward County, Florida Table 26: Housing discrimination Complaints – FY 2007-2012 HOPE FAIR HOUSING CENTER 2007 2008 2009 2010 2011 2012 Total % RACE 16 14 17 8 ---- ---- 55 36% COLOR 0 0 0 0 ---- ---- 0 0% NATIONAL ORIGIN 2 3 1 0 ---- ---- 6 4% RELIGION 0 0 0 1 ---- ---- 1 1% SEX 0 2 1 0 ---- ---- 3 2% FAMILIAL STATUS 0 11 1 2 ---- ---- 14 9% DISABILITY 24 14 19 10 ---- ---- 67 44% AGE 0 4 2 0 ---- ---- 6 4% OTHER 0 0 2 0 ---- ---- 2 1% Total 42 48 43 21 ---- --- 154 Broward County, Florida Table 27: Housing discrimination Complaints- FY 2007-2012 Broward County Office of Equal Opportunity 2007 2008 2009 2010 2011 2012 Total % RACE ---- 18 15 25 ---- ---- 58 19% COLOR ---- 0 0 0 ---- ---- 0 0% NATIONAL ORIGIN ---- 16 14 18 ---- ---- 48 15% RELIGION ---- 2 1 2 ---- ---- 5 2% SEX ---- 2 6 5 ---- ---- 13 4% FAMILIAL STATUS ---- 6 8 10 ---- ---- 24 8% DISABILITY ---- 54 47 56 ---- ---- 157 50% CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |93
  • 94. AGE ---- 1 0 1 ---- ---- 2 1% OTHER ---- 1 2 1 ---- ---- 4 1% Total ---- 100 93 118 ---- ---- 311 CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |94
  • 95. Figure 108: Average Summary Percentage of Housing Complaints for all Cited Figure 109: Summary of Housing Discrimination Complaints, By Year, Broward Agencies, Broward County, 2007-2012 County, 2007-2012 40% 2% 1% 35% RACE 30% 24% COLOR 25% NATIONAL ORIGIN 20% RELIGION 42% 1% 15% SEX 10% FAMILIAL STATUS 13% DISABILITY 5% AGE 0% 4% 2007 2008 2009 2010 2011 2012 10% 3% OTHERTable 28: Bases for Discrimination Complaints, Rank and Proportion, Broward Fair Housing Discrimination complaints within BrowardCounty 2007-2012 Basis % Rank County between 2007 & 2012 are quite similar to Palm Beach. Notably, complaints against race are more DISABILITY 42% 1 prevalent however which might be reflective of the RACE 24% 2 larger proportion of minorities in Broward. Also similar NATIONAL ORIGIN 13% 3 to other counties in the region is the higher proportion FAMILIAL STATUS 10% 4 of complaints closed in 2010. Broward County Office of SEX 4% 5 Equal Opportunity did not provide data for 2007, 2011, RELIGION 3% 6 and 2012. Likewise we were unable to obtain data for OTHER 2% 7 2011 and 2012 for complaints registered with HOPE in AGE 1% 8 Broward County. Data in tables 26 & 27 therefore is COLOR 1% 9 reflective of the county’s 2010 AI. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |95
  • 96. Miami-Dade County Miami-Dade County, Florida Table 29: Housing Discrimination Complaints- 2010-8/31/2012 By HUD or FHAP 2010 2011 2012 Total % RACE 19 14 8 41 17% COLOR 0 3 0 3 1% NATIONAL ORIGIN 18 10 17 45 18% RELIGION 5 3 3 11 5% SEX 8 2 10 20 8% FAMILIAL STATUS 10 3 8 21 9% DISABILITY 39 26 24 89 36% AGE 0 0 0 0 0% OTHER 4 4 6 14 6% Total 103 65 76 244 Miami-Dade County, Florida Table 30: Housing discrimination Complaints- 2007-2012 Florida Commission on Human Relations 2007 2008 2009 2010 2011 2012 Total % RACE 9 16 17 17 16 5 80 18% COLOR 0 1 1 0 3 1 6 1% NATIONAL ORIGIN 7 11 15 10 8 12 63 14% RELIGION 0 3 8 4 4 2 21 5% SEX 4 5 9 7 2 8 35 8% FAMILIAL STATUS 6 9 9 6 3 7 40 9% DISABILITY 20 42 39 32 29 23 185 41% AGE 0 0 0 0 0 0 0 0% CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |96
  • 97. OTHER 4 6 6 5 2 3 26 6% Total 50 93 104 81 67 61 456 Miami-Dade County, Florida Table 31: Housing discrimination Complaints – FY 2007-2012 HOPE FAIR HOUSING CENTER 2007 2008 2009 2010 2011 2012 Total % RACE 33 9 12 16 7 --- 77 36% COLOR 0 1 0 0 0 --- 1 0% NATIONAL ORIGIN 8 3 0 3 3 --- 17 8% RELIGION 0 0 0 0 0 --- 0 0% SEX 1 0 0 0 1 --- 2 1% FAMILIAL STATUS 3 3 5 2 3 --- 16 7% DISABILITY 27 7 22 19 7 --- 82 38% AGE 0 0 2 2 0 --- 4 2% OTHER 1 3 2 3 6 --- 15 7% Total 73 26 43 45 27 --- 214 Miami-Dade County, Florida Table 32: Housing discrimination Complaints- FY 2007-2012 Miami-Dade County Office of Human Rights and Fair Employment Practices 2007 2008 2009 2010 2011 2012 Total % RACE 10 9 14 4 4 8 49 16% COLOR 2 0 0 1 0 0 3 1% NATIONAL ORIGIN 12 8 8 4 18 8 58 19% RELIGION 5 0 1 0 1 0 7 2% SEX 1 2 1 0 3 4 11 4% FAMILIAL STATUS 1 2 2 0 6 5 16 5% CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |97
  • 98. DISABILITY 14 13 18 7 3 8 63 20% AGE 3 1 3 0 2 3 12 4% OTHER 25 11 24 1 21 12 94 30% Total 73 46 71 17 58 48 313 CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |98
  • 99. Figure 110: Average Summary Percentage of Housing Complaints for all Cited Figure 111: Summary of Housing Discrimination Complaints, By Year, Miami-Dade Agencies, Miami-Dade County, 2007-2012 County, 2007-2012 25% 20% 12% RACE 1% 21% COLOR 15% NATIONAL ORIGIN 1% RELIGION 10% SEX 15% FAMILIAL STATUS 5% 34% DISABILITY AGE 0% 2007 2008 2009 2010 2011 2012 5% 7% 3% OTHERTable 33: Bases for Discrimination Complaints, Rank and Proportion, Miami-Dade In Miami-Dade county, the range of fair housingCounty 2007-2012 complaints is more spread out between bases than for Basis % Rank counties with smaller populations. 34% can be DISABILITY 34% 1 attributed to disability, 21% to race, 15% to national RACE 21% 2 origin, and 12% to “other” complaints (mostly for NATIONAL ORIGIN 15% 3 retaliation). Over the five years, there is more stability in the proportion of complaints overall even though OTHER 12% 4 there is still a spike in 2010. As with Broward County, FAMILIAL STATUS 7% 5 HOPE acts as a FHAP. We did not receive updated SEX 5% 6 information for 2012 from this organization however so RELIGION 3% 7 data in table 31 is cited from Miami-Dade Counties AGE 1% 8 2011 AI. COLOR 1% 9 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT |99
  • 100. Monroe County Monroe County, Florida Table 34: Housing Discrimination Complaints- 2010-8/31/2012 By HUD or FHAP 2010 2011 2012 Total % RACE 2 1 0 3 19% COLOR 0 0 0 0 0% NATIONAL ORIGIN 2 0 1 3 19% RELIGION 0 1 0 1 6% SEX 0 0 1 1 6% FAMILIAL STATUS 0 1 2 3 19% DISABILITY 3 1 0 4 25% AGE 0 0 0 0 0% OTHER 1 0 0 1 6% Total 8 4 4 16 Monroe County, Florida Table 35: Housing Discrimination Complaints- 2007-2012 Florida Commission on Human Relations 2007 2008 2009 2010 2011 2012 Total % RACE 0 1 1 1 1 0 4 17% COLOR 0 0 0 0 0 0 0 0% NATIONAL ORIGIN 0 0 0 1 1 0 2 8% RELIGION 0 0 0 0 0 0 0 0% SEX 0 0 0 0 0 0 0 0% FAMILIAL STATUS 0 0 0 0 1 1 2 8% DISABILITY 4 8 0 1 2 1 16 67% AGE 0 0 0 0 0 0 0 0% CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 101. OTHER 0 0 0 0 0 0 0 0% Total 4 9 1 3 5 2 24 CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 102. Figure 112: Average Summary Percentage of Housing Complaints for all Cited Figure 113: Summary of Housing Discrimination Complaints, By Year, Monroe Agencies, Monroe County, 2007-2012 County, 2007-2012 30% 3% 25% RACE 18% COLOR 20% NATIONAL ORIGIN 15% RELIGION 14% SEX 10% 46% FAMILIAL STATUS 5% DISABILITY 3% AGE 0% 3% 2007 2008 2009 2010 2011 2012 14% OTHERTable 36: Bases for Discrimination Complaints, Rank and Proportion, Monroe Monroe has very few fair housing complaints. Of thoseCounty 2007-2012 registered 46% claim discrimination based on disability, Basis % Rank 18% on race, and 14% on both national origin and DISABILITY 46% 1 familial status. Over the time period there have been RACE 18% 2 large variances in the proportion of complaints year by NATIONAL ORIGIN 14% 3 year with the largest amount in 2010. FAMILIAL STATUS 14% 4 RELIGION 3% 5 SEX 3% 6 OTHER 3% 7 COLOR 0% 8 AGE 0% 9 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 103. CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 104. SEFLA Figure 114: Average Summary Percentage of Housing Complaints for all Cited Figure 115: Summary of Housing Discrimination Complaints, SEFLA Agencies, SEFLA, 2007-2012 30% 1% 25% 6% RACE 17% COLOR 0.3% 20% NATIONAL ORIGIN RELIGION 15% 14% SEX 43% 10% FAMILIAL STATUS 2% DISABILITY 7% 5% AGE 11% OTHER 0% 2007 2008 2009 2010 2011 2012 Housing complaints based on discrimination againstTable 37: Bases for Discrimination Complaints, Rank and Proportion,SEFLA 2007-2012 disability ranks highest in SEFLA by more than twice as much Basis % Rank as racially based complaints which rank second. Disability DISABILITY 43% 1 is, over the 5-year period and for each county, the largest RACE 17% 2 alleged discriminating factor in fair housing complaints NATIONAL ORIGIN 14% 3 (43%). For the region race (17%), national origin (13%), and FAMILIAL STATUS 11% 4 familial status (11%) follow in ranking which has been consistent over time except for in 2012 when race dipped SEX 7% 5 slightly below national origin (See Figure 117). There is OTHER 6% 6 variation of rank across individual counties (see figures 116). RELIGION 2% 7 Within all counties except Indian River, there was a spike in AGE 1% 8 reported fair housing complaints in 2010. COLOR 0.3% 9 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 105. Figure 116: Top 4 Ranked Bases for Complaints by County, 2007-2012 Average 60% 50% 40% 30% 20% 10% 0% DISABILITY RACE NATIONAL ORIGIN FAMILIAL STATUS CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 106. Figure 117: Top 4 Ranked Bases for Complaints SEFLA 2007-2012 450 400 350 300 250 200 150 100 50 0 2007 2008 2009 2010 2011 2012 DISABILITY RACE NATIONAL ORIGIN FAMILIAL STATUS CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 107. 4. Lending Profile4.1 Potential Discriminatory Lending PracticesHousing/Lending Discrimination on the Basis of Color, National Origin, Religion, Sex, Familial Status and Disability, (Protected classdiscrimination)Discrimination in housing acquisition and financing on the basis of color, national origin, religion, sex, familial status or disability is illegalunder the Fair Housing Act, also known as Title VIII of the U.S. Civil Rights Act. Under the act, mortgage lenders cannot refuse a loan toone of the classes of people protected under the act, also referred to as protected classes, nor can they set different conditions to aloan based on the above factors (Palm Bay FL, 2009; U.S. Department of Housing and Urban Development, N.D.). Discrimination underTitle VIII can occur in a variety of ways in addition to those already mentioned. Discrimination under Title VIII may occur when afinancier or lender refuses to provide information to a member of a protected class based on their membership in that class.Subprime Lending, Redlining & Predatory LendingSubprime lending is defined as higher than average rate loans given to persons who are of higher credit risk due to less thansatisfactory credit. The higher rate regularly referred as “higher cost” reflects the increased risk of lending to a loan applicant with lessthan satisfactory credit. There are other indicators of subprime loans besides the loan rate being higher than average, like the potentialfor the loan to reset to much higher rates in the future (Coconut Creek AI, 2011). Subprime lending is more prevalent in minority-majorityneighborhoods than in non-minority majority neighborhoods, suggesting an overrepresentation of minority recipients of mortgages thatare subprime in nature (Department of Housing and Urban Development, N.D.). Because of the apparent concentration of subprimeloans in minority neighborhoods and among minority loan applicants, it has been argued that subprime lenders target minoritycommunities through reverse redlining.Redlining was a practice that enabled minorities and their neighborhoods to be systematically excluded from acquiring home loans.This limited the housing choices for minorities, preventing them from improving and purchasing housing in their “red-lined” communities(Broward County, AI, 2011; Encyclopedia of Chicago, 2005). This practice led to deteriorating housing stock in minority-majoritycommunities and increased rental tenancy in those areas.Predatory lending has no officially recognized federal definition. The federal government does, however, associate certain practiceswith the act of predatory lending. These acts are seen as indicators of predatory lending and they include: high pressure andmisleading sales practices, abusive and aggressive collection practices, balloon payments (an oversized payment due at the end of aloan), steering borrowers to higher cost mortgages when they qualify for lower cost ones and the failure to report credit informationthat allows borrowers to get the best rates on loans based on their complete credit history, among others (U.S. Senate Committee onBanking, Housing and Urban Affairs, 2000; www.Investopedia.com, 2012). CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 108. 4.2 Home Mortgage Disclosure Act Data Analysis (HMDA)4The following analysis examines the equity in lending trends within SEFLA. The South Florida region held over six million people in 2010,with 89.6 percent of them living in Miami-Dade, Broward and Palm Beach County. Because of the concentration of South Floridiansthat live in these three counties, a few statistics on the lending in the leading cities of these counties is warranted.The City of Miami is located in Miami-Dade County, the most populous county in the seven-county South Florida region, and serves asits county seat. In Miami, American Indians/Alaskan Natives have the highest percentage of home loan denials among all racialgroups, at 36.62%. African Americans have the second highest denial rate at 33% and Hispanics and Whites have moderate loandenial rates of 22% and 17% respectively. Asian/Pacific Islanders have the lowest home loan denials rates, at 15.15%. When looking atloan rates across income levels, home loan denial rates are highest among low income individuals and lowest among upper incomeindividuals (City of Miami AI, 2007).The City of Fort Lauderdale is located in Broward County, Florida, the second-most populous county in the seven-county South Floridaregion with a population of 1,780,172 people in 2010(U.S. Census Bureau, 2010). In Fort Lauderdale during the year 2008, AfricanAmericans earning less than 50% of the area’s median income (AMI) had the highest percentage of loan denials under FHA/VA loansand Hispanics/Latinos earning less than 50% of the area’s median income (AMI) had the highest percentage of loan denials underconventional loans, edging out the less than 50% AMI African American denial percentage by one percentage point. Rates of loandenials under both loan types generally dropped as the income class increased, except for a few instances, most notably, AfricanAmericans conventional loan applicants above 120+% AMI had a higher percentage of loan denials than their 1000-119% AMIcounterparts at with rates of 41% to 35% respectively. The most prevalent reason for loan denials in the city for all races was debt (FortLauderdale AI, 2010).The City of West Palm Beach is located in Palm Beach County, Florida, the third-most populous county in the seven-county SouthFlorida region with a population of 1,320,134 people in 2010 (U.S. Census Bureau, 2010). In West Palm Beach in 2009, AmericanIndian/Alaska Natives had the lowest percentage of approved and accepted loan applications, at 33.33%. Whites had the highestpercentage of approved and accepted loan applications at 62.16%, almost twice that of American Indian/Alaska Natives. The rangeof approved and accepted applications across AMI income classes with available income fell within a percentage point 16 range,between a low of 46.50% for applicants earning less than 50% of the metropolitan statistical area (MSA) median income and a high of62.83% for applicants earning 120% or more of the MSA median income (City of West Palm Beach, 2011).4 Data source throughout HMDA Analysis:: 2010 Florida Housing Data Clearinghouse HMDA Home Mortgage Lending Data. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 109. Loan Dispositions in SEFLAOf the seven counties in the South Florida region, MartinCounty has the highest overall loan origination rate, at68.88% and Miami-Dade County has the highest overall loandenial rate, at 25.64%. Only two counties in the region, Martinand Indian River Counties, have loan origination rates thatare above the state’s loan origination average of 61.59%.Three South Florida Counties, Indian River County, MartinCounty and St. Lucie County, have loan denial rates belowthe state average of 19.61%.Four of the seven South Florida Counties have loan denialrates that are higher than the state rate of 19.01%. Overall Loan Dispositions for the Seven County Southeast Florida Region & The State of Florida County Originated/Approved Denied Other Total Broward 12954 5277 4957 23188 (55.87%) (22.76%) (21.38%) Indian 1133 261 278 1672 River (67.76%) (15.61%) (16.05%) County Martin 1193 261 278 1732 County (68.88%) (15.07%) (16.05%) Miami- 10807 5390 4824 21,021 Dade (51.41%) (25.64%) (22.95%) County Monroe 707 242 230 1179 County (59.97%) (20.53%) (19.51%) Palm 9765 3241 3213 16219 Beach (60.21%) (19.98%) (19.81%) County St. Lucie 2571 802 818 4191 County (61.35%) (19.14%) (19.52%) Florida 144931 46139 44259 235329 (61.59%) (19.61%) (18.81%) CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 110. Loan Application Denial Reasons for the Seven County Southeast Florida Region By CountyCounty Debt-to- Employment Credit History Collateral Insufficient Unverifiable Credit Mortgage Other Reason Not Total Denied Income Ratio History Cash Information Application Insurance Available Applications Incomplete DeniedBroward 1363County 85 (1.61%) 516 (9.78%) 1234 (23.38%) 138 (2.61%) 208 (3.94%) 415 (7.86%) 6 (0.11%) 516 (9.78%) 796 (15.08%) 5277 (25.83%)Indian RiverCounty 76 (29.12%) 10 (3.83%) 23 (8.81%) 65 (24.90%) 10 (3.83%) 8 (3.07%) 35 (13.41%) 1 (0.38%) 15 (5.74%) 18 (6.90%) 261MartinCounty 66 (25%) 4 (1.56%) 34 (12.89%) 69 (26.14%) 6 (2.27%) 15 (5.68%) 22 (8.34%) 1 (0.39%) 23 (8.71%) 24 (9.09%) 264Miami- 1275Dade 61 (1.13%) 463 (8.59%) 1353 (25.10%) 116 (2.15%) 221 (4.10%) 438 (8.12%) 6 (0.11%) 511 (9.48%) 946 (17.55%) 5390 (23.65%)CountyMonroeCounty 72 (29.75%) 3 (1.24%) 15 (6.20%) 63 (26.03%) 7 (2.89%) 13 (5.37%) 20 (8.26%) 0 (0%) 26 (10.74%) 23 (9.50%) 242Palm 836Beach 50 (1.54%) 306 (9.44%) 689 (21.26%) 78 (2.41%) 136 (4.20%) 357 (11.02%) 6 (0.19%) 293 (9.04%) 490 (15.12%) 3241 (25.79%)CountySt. LucieCounty 224 107 16 (2 %) 152 (18.95%) 25 (3.12%) 41 (5.11%) 61 (7.60%) 4 (0.50%) 83 (10.35%) 89 (10.35%) 802 (27.93%) (13.34%)The most prevalent reason for loan application denials among the counties in South Florida in is the loan applicant’s debt to incomeratio, with the largest percentage of 2010 county-wide loan denials in five of the regions’ counties (Broward County, Indian RiverCounty, Monroe County, Palm Beach County & St. Lucie County) attributed to that reason. The second leading reason for loan denialsin South Florida was collateral, with the largest percentage of countywide loan denials in two of the regions’ counties, Miami-DadeCounty and Martin County, attributed to that reason. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 111. Disposition of Loans by Race Broward County Applicant Race Loan Originated Loan Denied Other Total In Broward County, Native Hawaiian American Indian or Alaska 40 (41.24%) 25 (25.77%) 32 (32.98%) 97 or Other Pacific Islander loan Native Asian 448 (55.24%) 171 (21.09%) 192 (23.67%) 811 applicants had the highest loan Black or African American 2166 (49.83%) 1259 (28.96%) 922 (21.21%) 4347 denial rates in 2010. White loan Native Hawaiian or Other 40 (42.55%) 34 (36.17%) 20 (21.28%) 94 applicants had the highest loan Pacific Islander origination rates in the county, White 9036 (59.48%) 3095 (20.37%) 3060 (20.14) 15191 outpacing second place Asians by Information not provided by 1165 (45.53%) 684 (26.72%) 710 (27.75%) 2559 4.24 percentage points. applicant in mail, Internet, or telephone application Not applicable 59 (66.29%) 9 (10.11%) 21 (23.60%) 89 Indian River County In Indian River County, White loan Applicant Race Loan Originated Loan Denied Other Total applicants had the highest loan American Indian or Alaska 4 (80%) 0 (0%) 1 (20%) 5 denial rates in 2010. American Native Indian or Alaska Native loan Asian 11 (68.75%) 0 (0 %) 5 (31.25%) 16 applicants had the highest loan Black or African American 41 (75.93%) 7 (12.96%) 6 (11.11%) 54 origination rates in the county, outpacing second place African Native Hawaiian or Other Pacific 0 0 0 0 American loan applicants by 4.07 Islander percentage points. White 982 (68.38%) 230 (16.02%) 224 (15.60%) 1436 Information not provided by 94 (58.75%) 24 (15%) 42 (26.25%) 160 applicant in mail, Internet, or telephone application Not applicable 1 0 (0%) 0 (0%) 1 (100%) CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 112. Martin County In Martin County, African AmericanApplicant Race Loan Originated Loan Denied Other Total loan applicants had the highest loanAmerican Indian or Alaska 2 (50%) 1 (25%) 1 (25%) 4 denial rates in 2010. Asian loanNative applicants had the highest loanAsian 13 (72.22%) 2 (11.11%) 3 (16.67%) 18 origination rates in the county,Black or African American 10 (50%) 6 (30%) 4 (20%) 20 outpacing second place White loan applicants by 5.05 percentageNative Hawaiian or Other 0 (0%) 0 (0%) 1 (100%) 1 points.Pacific IslanderWhite 1062 (67.17%) 222 (14.04%) 297 (18.79%) 1581Information not provided by 101 (58.05%) 32 (18.39%) 41 (23.56%) 174applicant in mail, Internet, ortelephone applicationNot applicable 5 (83.33%) 1 (16.67%) 0 (0%) 6 Miami-Dade CountyApplicant Race Loan Originated Loan Denied Other Total In Miami-Dade County, NativeAmerican Indian or Alaska 32 (36.78%) 22 (25.29%) 33 (37.93%) 87 Hawaiian or Other Pacific IslanderNative loan applicants had the highest loanAsian 199 (50.90%) 99 (25.32%) 93 (23.80%) 391 denial rates in 2010. Whites had the highest loan origination rates in theBlack or African American 941 (47.36%) 574 (28.90%) 472 (23.75%) 1987Native Hawaiian or Other 23 (32.85%) 38 (54.29%) 9 (12.86%) 70 county, outpacing second placePacific Islander Asian loan applicants by 1.95White 8546 (52.85%) 4064 (25.13%) 3561 (22.02%) 16171 percentage points.Information not provided by 840 (41.54%) 567 (28.04%) 615 (30.42%) 2022applicant in mail, Internet, ortelephone applicationNot applicable 226 (77.13%) 26 (8.87%) 41 293 (14%) CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 113. Monroe County In Monroe County, American Indian or AlaskaApplicant Race Loan Originated Loan Denied Other Total Native loan applicants had the highest loan denialAmerican Indian or Alaska 2 (50%) 1 (25%) 1 (25%) 4 rates in 2010, though this may be attributed moreNative to the low numbers of loan applicants from thisAsian 6 (85.71%) 1 (14.29%) 0 (0%) 7 racial category in the county than to any trueBlack or African American 5 (45.45%) 2 (18.18%) 4 (36.36%) 11 outcome disparity.Native Hawaiian or Other 1 (100%) 0 (0%) 0 (0%) 1 Native Hawaiian or Pacific Islander loan applicantsPacific Islander had the highest loan origination rates in theWhite 627 (61.35%) 218 (21.33%) 177 (17.32%) 1022 county, outpacing second place Asians by 14.29Information not provided 51 (43.97%) 20 (17.24%) 45 (38.79%) 116 percentage points. It is important to note that, likeby applicant in mail, the racial category in the county with the highestInternet, or telephoneapplication loan denial rates, the difference between theNot applicable 15 (83.33%) 0 3 (16.67%) 18 Native Hawaiian or Other Pacific Islander loan (0%) origination rate and that of all other rates may not indicate a disparity in that racial category favor due to its small applicant pool (1 applicant). Palm Beach CountyApplicant Race Loan Originated Loan Denied Other TotalAmerican Indian or Alaska 18 (40.90%) 13 (29.55%) 13 (29.55%) 44Native In Palm Beach County, American Indian or Alaskan Native loan applicants had the highestAsian 284 (57.84%) 94 (19.14%) 113 (23.01%) 491 loan denial rates in 2010. White loan applicantsBlack or African American 818 (51.97%) 444 (28.21%) 312 (19.82%) 1574 had the highest loan origination rates in theNative Hawaiian or Other 27 (52.94%) 12 (23.53%) 12 (23.53%) 51 county, outpacing second place Asians by 4.88Pacific Islander percentage points.White 7815 (62.72%) 2308 (18.52%) 2338 (18.76%) 12461Information not provided 752 (49.25%) 362 (23.71%) 413 (27.05%) 1527by applicant in mail,Internet, or telephoneapplication CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 114. Not applicable 51 (71.83%) 8 (11.27%) 12 (16.90%) 71 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 115. St. Lucie County In St. Lucie County, American Indian or AlaskaApplicant Race Loan Originated Loan Denied Other Total Native loan applicants had the highest loan denialAmerican Indian or Alaska 6 (42.86%) 4 (28.57%) 4 (28.57%) 14 rates in 2010. Native Hawaiian or Other PacificNative Islander loan applicants had the highest loanAsian 44 (61.97%) 17 (23.94%) 10 (14.08%) 71 origination rates in the county, outpacing secondBlack or African American 295 (59%) 116 (23.2%) 89 500 place Whites by 1.35 percentage points. (17.8%)Native Hawaiian or Other 9 (64.29%) 3 (21.43%) 2 (14.29%) 14Pacific IslanderWhite 2006 (62.94%) 553 (17.35%) 628 (19.71%) 3187Information not provided 203 (51.39%) 108 (27.34%) 84 (21.27%) 395by applicant in mail,Internet, or telephoneapplicationNot applicable 8 1 1 10 (80%) (10%) (10%) FloridaApplicant Race Loan Originated Loan Denied Other Total Statewide, Native Hawaiian or Other PacificAmerican Indian or Alaska 455 (46.19%) 244 (24.77%) 286 (29.04%) 985 Islander loan applicants had the highest loanNative denial rates in 2010. Whites had the highest loanAsian 3733 (59.20%) 1282 (20.33%) 1291 (20.47%) 6306 origination rates in the state, outpacing second place Asians by 4.46 percentage points.Black or African American 11349 (54.42%) 5621 (26.96%) 3881 (18.61%) 20851Native Hawaiian or Other 427 (53.58%) 225 (28.23%) 145 (18.19%) 797Pacific IslanderWhite 114938 (63.66%) 33104 (18.34%) 32496 (18%) 180538Information not provided 13239 (53.28%) 5579 (22.45%) 6032 (24.27%) 24850by applicant in mail,Internet, or telephoneapplicationNot applicable 790 (78.84%) 84 (8.38%) 128 (12.77%) 1002 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 116. Loan Dispositions by Hispanic/Non-Hispanic Ethnicity Broward County Hispanic or Latino loan applicants in Broward County Applicant Loan Application Other Total Ethnicity Originated Denied received loan denials at a higher rate than non-Hispanic Hispanic or 3014 1353 1105 5472 loan applicants, with the Hispanic or Latino loan denial rate Latino (55.08%) (24.73%) (20.19%) outpacing the non-Hispanic loan denial rate by 3.16 Not Hispanic or 8820 3303 3190 15313 Latino (57.60%) (21.57%) (20.83%) percentage points in 2010. Hispanics or Latino loan Information not 1059 612 641 2312 applicants in Broward received loan originations at a lower provided by (45.80%) (26.47%) (27.72%) rate than non-Hispanics, with the Hispanic loan origination applicant in mail, Internet, or rate falling 2.52 percentage points behind the non-Hispanic telephone loan origination rate in 2010. application Not applicable 61 9 21 91 (85.92%) (9.90%) (23.10%) Indian River County Applicant Loan Application Other Total Hispanic or Latino loan applicants in Indian River County Ethnicity Originated Denied received loan denials at a lower rate than non-Hispanic loan Hispanic or 73 14 13 100 Latino (73%) (14%) (13%) applicants, with the non-Hispanic loan denial rate outpacing Not Hispanic or 964 224 221 1409 the Hispanic loan denial rate by 1.9 percentage points in Latino (68.42%) (15.90%) (15.68%) 2010. Hispanic of Latino loan applicants in Indian River Information not provided by 95 (58.64%) 23 (14.20%) 44 (27.16%) 162 County received loan originations at a higher rate than non- applicant in Hispanic loan applicants, with the Hispanic loan origination mail, Internet, or telephone rate outpacing the non-Hispanic loan origination rate by application 4.58 percentage points in 2010. Not applicable 1 0 0 1 (100%) (0%) (0%) CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 117. Martin County Hispanic or Latino loan applicants in Martin County receivedApplicant Loan Application Other Total loan denials at a higher rate than non-Hispanics, with theEthnicity Originated Denied Hispanic or Latino loan denial rate outpacing the non-Hispanic or 45 19 9 73Latino (61.64%) (26.02%) (12.34%) Hispanic loan denial rate by 12.25 percentage points in 2010.Not Hispanic or 1042 213 292 1547 Hispanics in Martin County received loan originations at aLatino (67.37%) (13.77%) (18.88%) lower rate than non-Hispanics, with the Hispanic loanInformation notprovided by 101 (56.74%) 31 (17.42%) 46 (25.84%) 178 origination rate falling 5.73 percentage points behind theapplicant in non-Hispanic loan origination rate in 2010.mail, Internet, ortelephoneapplicationNot applicable 5 1 0 6 (83.34%) (16.67%) (0%) Miami-Dade County Hispanic or Latino loan applicants in Miami-Dade County received loan denials at a higher rate than non-Hispanics,Applicant Loan Application Other Total with the Hispanic loan denial rate outpacing the non-Ethnicity Originated Denied Hispanic loan denial rate by 1.85 percentage points in 2010.Hispanic or 6559 3339 2766 12664Latino (51.79%) (26.37%) (21.84%) Hispanic or Latino loan applicants in Miami-Dade CountyNot Hispanic or 3338 1571 1498 6407 received loan originations at a lower rate than non-Latino (52.09%) (24.52%) (23.38%) Hispanics, with the Hispanic loan origination rate falling 0.3Information not 683 453 518 1654 percentage points behind the non-Hispanic loan originationprovided by (41.29%) (27.39%) (31.32%)applicant in rate in 2010.mail, Internet, ortelephoneapplicationNot applicable 227 27 42 296 (76.69%) (9.12%) (14.19%) CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 118. Monroe County Hispanic or Latino loan applicants in Monroe CountyApplicant Ethnicity Loan Application Other Total received loan denials at a higher rate than non-Hispanics, Originated Denied with the Hispanic loan denial rate outpacing the non-Hispanic or Latino 84 34 23 141 (59.57%) (24.11%) (16.31%) Hispanic loan denial rate by 3.08 percentage points in 2010.Not Hispanic or 554 191 163 908 Hispanic or Latino loan applicants in Monroe CountyLatino (61.01%) (21.03%) (17.95%) received loan originations at a lower rate than non-Information notprovided by 54 (48.21%) 17 (15.18%) 41 (36.60%) 112 Hispanics, with the Hispanic loan origination rate falling 1.44applicant in mail, percentage points behind the non-Hispanic loan originationInternet, ortelephone rate in 2010.applicationNot applicable 15 0 3 18 (83.33%) (0%) (16.67%) Palm Beach County Applicant Loan Application Other Total Hispanic or Latino loan applicants in Palm Beach CountyEthnicity Originated Denied received loan denials at a higher rate than non-Hispanics,Hispanic or Latino 1268 578 414 2260 (56.10%) (25.58%) (18.32%) with the Hispanic loan denial rate outpacing the non-Not Hispanic or 7692 2300 2371 12363 Hispanic loan denial rate by 6.98 percentage points in 2010.Latino (62.22%) (18.60%) (19.18%) Hispanic or Latino loan applicants in Palm Beach CountyInformation notprovided by 754 (49.54%) 355 (23.32%) 413 (27.14%) 1522 received loan originations at a lower rate than non-applicant in mail, Hispanics, with the Hispanic loan origination rate falling 6.12Internet, ortelephone percentage points behind the non-Hispanic loan originationapplication rate in 2010.Not applicable 51 8 15 74 (68.91%) (1.35%) (20.27%) CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 119. St. Lucie County Hispanic or Latino loan applicants in St. Lucie CountyApplicant Ethnicity Loan Application Other Total received loan denials at a higher rate than non-Hispanic Originated Denied loan applicants, with the Hispanic loan denial rateHispanic or Latino 319 118 114 551 (57.89%) (21.42%) (20.69%) outpacing the non-Hispanic loan denial rate by 3.54 percentage points in 2010. Hispanics in St. Lucie CountyNot Hispanic or 2046 580 618 3244 received loan originations at a lower rate than non-Latino (63.07%) (17.88%) (19.05%) Hispanics, with the Hispanic loan origination rate falling 5.18Information not 198 103 85 386provided by (51.30%) (26.68%) (22.02%) percentage points behind the non-Hispanic loan originationapplicant in mail, rate in 2010.Internet, or telephoneapplicationNot applicable 8 1 1 10 (80%) (10%) (10%) Florida Hispanic or Latino loan applicants statewide received loanApplicant Ethnicity Loan Application Other Total denials at a higher rate than non-Hispanics, with the Hispanic Originated DeniedHispanic or Latino 21806 9727 7694 39227 loan denial rate outpacing the non-Hispanic loan denial rate (55.59%) (24.80%) (19.61%) by 6.73 percentage points in 2010. Hispanics in statewideNot Hispanic or 109580 30903 30565 171048 received loan originations at a lower rate than non-Latino (64.06%) (18.07%) (17.90%) Hispanics, with the Hispanic loan origination rate falling 8.47Information not 12749 5423 5868 24040 percentage points behind the non-Hispanic loan originationprovided by (55.03%) (22.56%) (24.41%) rate in 2010.applicant in mail,Internet, ortelephoneapplicationNot applicable 796 86 132 1004 (79.28%) (8.56%) (13.15%) CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 120. Loan Denial Disparities by Race and Ethnicity Loan Application Denial Disparities Across the Seven County South Florida Region By Race Across the seven-county South Florida Region, theApplicant Broward Indian Martin Miami- Monroe Palm St. LucieRace County River County Dade County Beach County applicant race with the largest loan application denial Disparity County Disparity County Disparity County Disparity disparity from that of whites are Native Hawaiian or Other Disparity Disparity Disparity Pacific Islander loan applicants in Miami-Dade County,American 1.27 N/V 1.78 1.01 1.17 1.59 1.64 who are 2.16 times more likely than a white applicant inIndian orAlaska that county to receive a home loan denial. African-Native Americans in Martin County had the second largestAsian 1.04 N/V 0.79 1.01 0.67 1.03 1.38 disparity, being 2.14 times more likely to receive a loanBlack or 1.42 0.8 2.14 1.15 0.85 1.52 1.34 denial than a white applicant. The applicant race withAfrican the lowest application denial disparity from that of whitesAmerican are Asian loan applicants in Monroe County, who are .67Native 1.78 N/V N/V 2.16 N/V 1.27 1.24 times more likely to receive a home loan than whites inHawaiianor Other Monroe County.PacificIslanderWhite N/A N/A N/A N/A N/A N/A N/A Across the seven-county South Florida region, the Loan Application Denial Disparities Across the Seven County South Florida county the highest disparity between Hispanic or Region By Hispanic/Non-Hispanic Ethnicity Latino and non-Hispanic loan applicants in 2010 was in Martin County, Florida. In Martin County, Broward Indian Martin Miami- Monroe Palm St. LucieApplicant County River County Dade County Beach County Hispanics were 1.89 times more likely to receive aEthnicity Disparity County Disparity County Disparity County Disparity loan denial in 2010. Disparity Disparity DisparityHispanic 1.15 0.88 1.89 1.08 1.15 1.38 1.2 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 121. Non- N/A N/A N/A N/A N/A N/A N/AHispanic CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 122. Subprime LendingAcross the seven-county South Florida region, only Miami-Dade County had a subprime/high cost loan origination ratehigher than the state average in 2010. The county with thelowest rate of subprime/high cost loans is Monroe County at1.54% of all its loans in 2010. Subprime/High Cost Loans in the Seven County Southeast Florida Region Compared to the State of FloridaCounty High Cost Non-High Cost or Total UnknownBroward County 334 11148 11482 (2.91%) (97.09%)Indian River County 19 826 845 (2.25%) (97.75%)Martin County 25 891 916 (2.73%) (97.27%)Miami-Dade County 410 8551 8961 (4.58%) (95.42%)Monroe County 5 320 325 (1.54%) (98.46%)Palm Beach County 201 7896 8097 (2.48%) (97.52%)St. Lucie County 51 1950 2001 (2.55%) (97.45%)Florida 4177 115111 119288 (3.50%) (96.50%) CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 123. Subprime Lending by Race Broward County African-American loan applicants had the highest rate ofRace High-Cost Non-High Cost Total or Unknown subprime/high cost loans in Broward County in the yearAmerican Indian or Alaska 0 37 37 2010 at 4.56% of all its racial category loan originations.Native (100%) Asian loan applicants had the lowest rate ofAsian 5 395 400 subprime/high cost loans in the county at 1.25% of all its (1.25%) (98.75%) racial category loan originations.Black or African American 94 1967 2061 (4.56%) (95.43%)Native Hawaiian or Other 1 34 35Pacific Islander (2.85%) (97.14%)White 221 7726 7947 (2.78%) (97.23%)Information not provided 13 988 1001by applicant in mail, (1.30%) (98.70%)Internet, or telephoneapplicationNot applicable 0 1 1 (0%) (100%) Indian River African-American loan applicants had the highest rateRace High-Cost Non-High Cost Total or Unknown of subprime/high cost loans in Indian River County in the year 2010 at 5.12% of all its racial category loanAmerican Indian or Alaska 0 3 3Native (0%) (100%) originations. Asian loan applicants had the lowest rate of subprime/high cost loans in the county at 1.25% of all itsAsian 0 8 8 (0%) (100%) racial category loan originations.Black or African American 2 37 39 (5.12%) (94.87%)White 15 715 730 (2.05%) (97.95%)Information not provided 2 63 65by applicant in mail, (3.07%) (96.92%)Internet, or telephoneapplication CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 124. Miami-Dade County American Indian or Alaskan Native loan applicants had theRace High-Cost Non-High Cost Total highest rate of subprime/high cost loans in Miami-Dade or Unknown County in the year 2010 at 14% of all its racial category loanAmerican Indian or Alaska 4 23 27Native (14.81%) (85.19%) originations. Native Hawaiian or Other Pacific Islander loanAsian 6 153 159 applicants had the lowest rates of subprime/high cost loans (3.77%) (96.23%) in the county at 0% of all its racial category loanBlack or African American 31 876 907 originations. (3.42%) (96.58)Native Hawaiian or Other 0 18 18Pacific Islander (0%) (100%)White 342 6799 7141 (4.79%) (95.21%)Information not provided 27 671 698by applicant in mail, (3.87%) (96.13%)Internet, or telephoneapplicationNot applicable 0 11 11 (0%) (100%) Monroe County White loan applicants had the highest rate ofRace High-Cost Non-High Cost Total subprime/high cost loans in Monroe County in the year or Unknown 2010 at 1.69% of all its racial category loan originations. ForAmerican Indian or Alaska 0 1 1 all other racial categories listed, none of their loanNative (0%) (100%) originations were high cost in 2010.Asian 0 3 3 (0%) (100%)Black or African American 0 4 4 (0%) (100%)Native Hawaiian or Other 0 1 1Pacific Islander (0%) (100%)White 5 291 296 (1.69%) (98.31%)Information not provided 0 20 20by applicant in mail, (0%) (100%)Internet, or telephoneapplication CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 125. Palm Beach County American Indian or Alaskan Native loan applicants had the Race High-Cost Non-High Cost Total highest rate of subprime/high cost loans in Palm Beach County or Unknown in the year 2010 at 7.14% of all its racial category loanAmerican Indian or Alaska 1 13 14 originations. Native Hawaiian or Other Pacific Islander loanNative (7.14%) (92.86%) applicants had the lowest rates of subprime/high cost loans in Asian 2 225 227 (.8%) (99.12%) the county at 0% of all its racial category loan originations.Black or African American 28 739 767 (3.65%) (96.34%)Native Hawaiian or Other 0 24 24Pacific Islander (0%) (100%)White 163 6313 6476 (2.57%) (97.48%)Information not provided 7 582 589by applicant in mail, (1.19%) (98.81%)Internet, or telephoneapplication St. Lucie County African American loan applicants had the highest rate ofRace High-Cost Non-High Cost Total or Unknown subprime/high cost loans in St. Lucie County in the year 2010 atAmerican Indian or Alaska 0 6 6 3.2% of all its racial category loan originations. Native HawaiianNative (0%) (100%) or Other Pacific Islander loan applicants had the lowest ratesAsian 0 33 33 of subprime/high cost loans in the county at 0% of all its racial (0%) (100%) category loan originations.Black or African American 8 242 250 (3.2%) (96.8%)Native Hawaiian or Other 0 8 8Pacific Islander (0%) (100%)White 39 1519 1558 (2.50%) (97.50%) CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 126. Information not provided 4 142 146by applicant in mail, (2.74%) (97.26%)Internet, or telephoneapplicationSubprime Lending by Hispanic/Non Hispanic Ethnicity Broward County In 2010, Hispanic or Latino loan applicants had a higherEthnicity High-Cost Non-High Total rate of high cost loan originations than non-Hispanic loan Cost or Unknown applicants in Broward County. The Hispanic loanHispanic or Latino 103 2599 2702 applicant high cost loan origination rate in 2010 was 1.02 (3.81%) (96.19%) percentage points higher than the non-Hispanic loanNot Hispanic or Latino 219 7638 7857 applicant high cost loan origination rate. (2.79%) (97.21%)Information not provided 12 908 920by applicant in mail, (1.30%) (98.70%)Internet, or telephoneapplicationNot Applicable 0 3 3 (0%) (100%) Indian River County In 2010, Hispanic or Latino loan applicants had aEthnicity High-Cost Non-High Total lower rate of high cost loan originations than non- Cost or Unknown Hispanic or Latino loan applicants in Indian RiverHispanic or Latino 1 63 64 County. The Hispanic applicant high cost loan (1.56%) (98.45%) origination rate in 2010 was 0.73 percentage pointsNot Hispanic or Latino 16 700 716 (2.29%) (97.77%) lower than the non-Hispanic or Latino loan applicant high cost loan origination rate.Information not provided by 2 63 65applicant in mail, Internet, or (3.07%) (96.92%)telephone application CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 127. Martin County In 2010, Hispanic or Latino loan applicants had a lowerEthnicity High-Cost Non-High Total rate of high cost loan originations than non-Hispanic or Cost or Unknown Latino loan applicants in Martin County. The Hispanic orHispanic or Latino 0 33 33 Latino loan applicant high cost loan origination rate in (0%) (100%) 2010 was 2.97 percentage points lower than the non-Not Hispanic or Latino 24 785 809 Hispanic or Latino loan applicant high cost loan (2.97%) (97.03%) origination rate.Information not provided 1 73 74by applicant in mail, (1.35%) (98.65%)Internet, or telephoneapplication Miami-Dade County In 2010, Hispanic or Latino loan applicants had aEthnicity High-Cost Non-High Total higher rate of high cost loan originations than non- Cost or Unknown Hispanic or Latino loan applicants in Miami-DadeHispanic or Latino 290 5273 5563 County. The Hispanic applicant high cost loan (5.21%) (94.79%) origination rate in 2010 was 1.53 percentage pointsNot Hispanic or Latino 104 2720 2824 higher than the non-Hispanic or Latino loan applicant (3.68%) (96.32%) high cost loan origination rate.Information not provided 16 546 562by applicant in mail, (2.85%) (97.15%)Internet, or telephone CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 128. applicationNot applicable 0 12 12 (0%) (100%) Monroe County In 2010, Hispanic or Latino loan applicants had aEthnicity High-Cost Non-High Total higher rate of high cost loan originations than non- Cost or Unknown Hispanic or Latino loan applicants in Monroe County.Hispanic or Latino 1 38 39 The Hispanic or Latino applicant high cost loan (2.56%) (97.44%) origination rate in 2010 was 1.04 percentage pointsNot Hispanic or Latino 4 260 264 (1.52%) (98.48%) higher than the non-Hispanic or Latino loan applicant high cost loan origination rate.Information not provided 0 22 22by applicant in mail, (0%) (100%)Internet, or telephoneapplication Palm Beach County In 2010, Hispanic or Latino loan applicants had a higherEthnicity High-Cost Non-High Total rate of high cost loan originations than non-Hispanic or Cost or Latino loan applicants in Palm Beach County. The UnknownHispanic or Latino 54 1120 1174 Hispanic or Latino loan applicant high cost loan (4.60%) (95.40%) origination rate in 2010 was 2.45 percentage pointsNot Hispanic or Latino 136 6196 6332 higher than the non-Hispanic or Latino loan applicant (2.15%) (97.85%)Information not provided 11 580 591 high cost loan origination rate.by applicant in mail, (1.86%) (98.14%)Internet, or telephoneapplication In 2010, Hispanic or Latino loan applicants had a lower CARRAS rate of high cost loan originations than non-Hispanic or COMMUNITY INVESTMENT, INC. Latino loan applicants in St. Lucie County. The Hispanic SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO in 2010 was 0.69 applicant high cost loan origination rate FAIR HOUSING DRAFT percentage points lower than the non-Hispanic or Latino loan applicant high cost loan origination rate.
  • 129. St. Lucie CountyEthnicity High-Cost Non-High Cost Total or UnknownHispanic or Latino 5 254 259 (1.93%) (98.07%)Not Hispanic or 42 1561 1603Latino (2.62%) (97.38%)Information not 4 135 139provided by (2.83%) (97.12%)applicant in mail,Internet, ortelephoneapplicationSubprime Lending Disparities by Race and Ethnicity High Cost Loan Disparity Across the Seven County South Florida Region By RaceApplicant Race Broward Indian Martin Miami- Monroe Palm St. Lucie County River County Dade County Beach County Disparity County Disparity County Disparity County Disparity Disparity Disparity DisparityAmerican Indian No High No High No High 3.09 No High 2.79 No Highor Alaska Native Cost Loans Cost Loans Cost Loans Cost Loans Cost LoansAsian 0.45 No High 3.73 ,78 No High 0.31 No High Cost Loans Cost Loans Cost LoansBlack or African 1.64 2.5 No High 0.71 No High 1.42 1.28American Cost Loans Cost LoansNative Hawaiian 1.03 Not Listed Not Listed No High No High No High No Highor Other Pacific Cost Loans Cost Loans Cost Loans Cost LoansIslanderWhite N/A N/A N/A N/A N/A N/A N/AThe applicant race with the greatest high cost loan rate disparity from that of Whites are Asian loan applicants in Martin County, whoare 3.73 times more likely to receive a high-cost loan origination than their white counterparts. Asian loan applicants in Palm BeachCounty have the lowest high cost loan rate disparity from that of White loan applicants. They are .31 times as likely as their White loanapplicant counterparts to receive a high-cost loan origination. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 130. High Cost Loan Disparity Across the Seven County South Florida Region by Hispanic EthnicityApplicant Broward Indian Martin Miami- Monroe Palm St. LucieEthnicity County River County Dade County Beach County Disparity County Disparity County Disparity County Disparity Disparity Disparity DisparityHispanic Ethnicity 1.37 0.69 No High 1.42 1.69 2.14 0.74 Cost LoansNon-Hispanic N/A N/A N/A N/A N/A N/A N/AEthnicityThe greatest high cost loan origination disparity between Hispanic or Latino loan applicants and non-Hispanic or Latino loan applicantsis in Palm Beach County, where Hispanics are 2.14 times more likely to receive a high cost loan than their non-Hispanic counterparts.4.3 Summary of the DataThere are disparities in loan origination rates and subprime lending rates across the seven South Florida counties. Though thesedisparities are seen across racial groups, the data suggests no racial group at a significant disparity or disadvantage across all sevencounties. The full range of racial and ethnic groups included in this analysis has either higher loan denial or subprime lending rates in thecounties analyzed.All but three of the analyzed South Florida counties have overall loan origination rates higher than the state of Florida rate, whichmeans that the counties with the higher rates, Broward, Monroe, Miami-Dade, Palm Beach & St. Lucie, have above average loanorigination rates for the state of Florida. Interestingly, only three of the region’s seven counties, Indian River, Martin and St. Lucie, haveloan denial rates below the state-wide rate. So, the region generally has a higher percentage of its loan applications that areoriginated but also a higher percentage of its loan originations that are denied than the state of Florida in general.The most prevalent reason for loan denials within the counties of the South Florida region was the applicant’s debt to income ratio, thereason accounting for largest percentage of loan denial in five of the region’s seven counties (Broward County, Indian River County,Monroe County, Palm Beach County, & St. Lucie County). The second most prevalent reason for loan denials in the region, whichaccounted for the majority of loan denials in two of the region’s counties (Miami-Dade County & Martin County), was the amount ofcollateral the loan applicant had. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 131. As stated earlier, loan dispositions based on race and the racial groups with the highest adverse dispositions varied across the region’sseven counties. In three of the region’s counties, American Indian or Alaska Native loan applicants had the highest loan denial rates(Monroe County, Palm Beach County and St. Lucie County). In two of the region’s counties, Native Hawaiian or Other Pacific Islanderloan applicants had the highest loan denial rates (Miami-Dade County and Broward County). White applicants had the highest loandenial rate in Indian River County and African Americans had the highest loan denial rate in Martin County.Hispanic applicants received loan denials at a higher rate than that of non-Hispanic applicants in six out of the seven South Floridacounties, with only Hispanic applicants in Indian River County having lower loan application rates than non-Hispanics.When examining the disparity between white applicants and applicants of other races across the seven counties, it was discoveredthat the largest disparity in loan denial rates from that of whites in the region were that of Native Hawaiian or Other Pacific Islanderapplicants in Miami-Dade County. The least disparity was that of Asian applicants in Monroe County. When examining the disparitybetween Hispanics and non-Hispanics in a similar manner, the largest disparity in loan denial rates between Hispanics and that of non-Hispanics was in Martin County.When examining subprime lending by race, no single race uniformly had the highest rates of subprime originations across all sevencounties. African Americans had the highest rates of subprime loan originations in three of the region’s counties (Broward, Indian Riverand St. Lucie County). American Indian or Alaska Natives had the highest rates of subprime loan originations in two of the region’scounties (Palm Beach and Miami-Dade). Whites had the highest rates of subprime loan originations in one of the region’s counties(Indian River County).Hispanics had higher rates of subprime loan origination in four of the region’s seven counties (Palm Beach County, Monroe County,Miami-Dade County and Broward County. In three of the region’s counties, Hispanics had lower rates of subprime loan origination (St.Lucie County, Martin County and Indian River County).When examining the disparity in the rate of subprime loan originations between white applicants and that of other races, the greatestdisparity was found among Asian applicants in Martin County. The greatest disparity in the rate of subprime originations betweenHispanics and that of non-Hispanics was found in Palm Beach County. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 132. CARRASCOMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 133. 5. Identified Impediments to fair housing5.1 Key Impediments Region-wide Number of South Florida Jurisdictions Citing Issue as an Impeidment to Fair Housing Choice 19 20 15 15 15 10 9 9 9 10 7 6 4 Number of South Florida 5 Jurisdictions Citing Issue as an Impeidment to Fair Housing Choice 0 Housing/Lending Lack of Fair and Equal Housing Market Shortage of Violations of Limited Funding to Predatory Lending Improvement of Zoning/Land Use Discrimination on Knowledge, Lending Disparities Segregation Affordable Housing Federal, State and Meet Need for the Housing the Basis of Race, Awarness of or Opportunities Local Fair Housing Affordable Housing Discrimination Color, National Education on Fair Laws Complaint Process Origin, Religion, Housing Protections Sex, Familial status and Disability (Protected Classes) CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 134. Impediment #1: Lack of Knowledge, Awareness of, or Education on Fair Housing ProtectionsThis impediment was found to be the most prevalent one within the seven county South Florida region, with 19 of the region’s 31examined AIs finding it to be an impediment to fair housing choice in their communities. The cities of Coconut Creek and Miramardiscuss this issue in detail in their AIs, stating that many potential homeowners lack the understanding of the path to homeownership.The city stated that a majority of loan denials were due to avoidable issues, such as incomplete loan applications, unverifiableinformation and collateral, among others (City of Coconut Creek, 2011; City of Miramar, 2011).Impediment #2: Fair and Equal Lending DisparitiesThis impediment was discussed in 15 of the region’s 31 examined AIs, making it the second most prevalent impediment in the region.The prevalence of this issue in the south Florida region is underlined in the subprime data discussed earlier in this analysis. The City ofMiami discusses the impediment in its AI, stating that African Americans and Hispanics tend to have higher loan application failurerates when HMDA lending data is analyzed by race and ethnicity (City of Miami, 2007).Impediment #3: Housing/Lending Discrimination on the Basis of Race, Color, National Origin, Religion, Sex, Familial Status and DisabilityThis impediment was discussed in 15 of the region’s 31 examined AIs, making this issue tied with fair and equal lending disparities as thesecond most prevalent issue throughout the region. The data gathered on the lending patterns of the seven observed south Floridacounties supports this finding, with the data indicating regular disparities on loan approvals and denials by race and by Hispanic/non-Hispanic ethnicity. The City of Fort Lauderdale’s AI discusses the impediment, stating that it occurs when, on the basis of a person beingpart of a protected class, lenders deny or alter services or access to housing through actions such as denying property insurance toapplicants, conducting property appraisals in a discriminatory manner or by setting different terms or privileges in the sale of a dwelling,among other actions (City of Fort Lauderdale, 2010).Impediment #4: Shortage of Affordable Housing OpportunitiesThis impediment was discussed in 10 of the region’s 31 examined AIs, making it the region’s fourth most prevalent impediment. The cityof Delray Beach discusses its particular situation under this impediment in detail, stating that it currently has 600 families on its waiting listfor its City of Delray Beach Housing Choice Vouchers. The waiting list, due to the high number of families on it, has been closed untilthe number of families on the waiting list decreases to 200. In addition, families in the city seeking housing assistance typically wait fourto five years before that assistance is received (City of Delray Beach, 2009).Impediment #5: Violations of Federal, State and Local Housing LawsThis impediment was discussed in nine of the region’s 31 examined AIs, making it tied with predatory lending as and Housing MarketSegregation as the fifth most prevalent impediment to fair housing choice in the region. The City of Hollywood, Florida discusses thisimpediment in its AI, stating that it will tackle the impediment through a public relations campaign to promote the knowledge of fair CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 135. housing laws and assistance programs through various forms of media and to provide information about fair housing and phonenumbers for assistance on the city’s website (City of Hollywood, 2010).Impediment #6: Housing Market SegregationThis impediment was discussed in nine of the region’s 31 examined AIs, making it the fifth most prevalent impediment to fair housingchoice in the region, tied with the violation of federal, state and local housing laws impediment and the predatory lendingimpediment. The City of North Miami Beach seeks to tackle this impediment head on, calling for activities that are geared towardcreating city neighborhoods that are more open and inclusive though affirmative training technical assistance to developers in the cityusing federal funding dollars to develop and redevelop housing as well as provide such training to city staff, community advocates,housing providers and area financial institutions (North Miami, 2011).Impediment #7: Predatory LendingThis impediment was discussed in nine of the region’s 31 examined AIs, making it tied for fifth most prevalent impediment in the region,tied with the housing market segregation impediment and the shortage of affordable housing opportunities impediment. The impactsof predatory lending, which was discussed earlier in the report, are described in detail in the City of Delray Beach AI, which states thatpredatory lending, due to its high costs, abusive practices, and hard requirements, has the potential to strip borrowers of home equity,ruin their credit records and increases the odds of home foreclosure. The city states that some of its census tracts are experiencing highlevels of abandonment due to pending foreclosures which may be attributed to predatory lending (City of Delray Beach, 2009).Impediment #8: Limited Funding to Meet Need for Affordable HousingThis impediment was discussed in seven of the region’s 31 examined AIs, making it the eighth most prevalent impediment in the region.The City of Miami discusses this impediment, stating that it stems to annual decreases of federal funding to support affordable housingcreation efforts. The city plans on overcoming this impediment by reducing the amount of federal subsidies per household through thetightening of bedroom restrictions and to attempt to accommodate as many Housing Opportunities for Persons with Aids (HOPWA)residents as it can in its Long-term Rental Assistance Program (City of Miami, 2007).Impediment #9: Zoning/Land UseThis impediment was discussed in six of the region’s 31 examined AIs, making it the ninth most prevalent impediment in the region. TheCity of Miramar, Florida discusses the impediment in detail in their AI. The city admits that its existing zoning, land use and future landuse regulation influence the number of housing options in their city and their quality. The city provides a way to work with the influence,stating that the more types of zoned housing districts that a jurisdiction has the more likely that it will be able to accommodate diversehousing types developable on varying lot sizes, lowering their cost and increasing their affordability. The city follows this approach,providing sixteen residential housing districts in their zoning code ranging from a rural district of one dwelling per many acres, to a CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 136. Residential-25 with 25 dwellings per acre. The city also moved to remove regulatory barriers to the construction of affordable housingbased in its zoning code and created a dense Traditional Neighborhood District along its State Road 7 Corridor (City of Miramar, 2011).Impediment #10: Improvement of the Housing Discrimination Complaint ProcessThis impediment was discussed in four of the region’s 31 examined AIs, making it the tenth most prevalent impediment in the region.Pembroke Pines, Florida discusses some of the issues under this impediment, stating that the complaint process is hampered byorganizational deficiencies and redundancy. Pembroke Pines elaborates on these points through illustrations, to include the fact thatthere are three entities (Broward County Civil Rights Division 4, U.S. HUD and HOPE, Inc.) who receive complaints of housingdiscrimination in the county and since housing complaints may be, and are at times, files in more than one of the entities, calculating atrue number or volume of housing discrimination incidents in the city is difficult, due to the numbers being skewed by redundancies.Another situation that the city details is the fact that Broward county, when they receive discrimination complaints, are not required tolist more than the name of the lender involved in the complaint and the basis of the complaint, but not the location of the complaint.Because of this, the assessment of location-based levels of housing discrimination is made more difficult (Broward County, 2011). CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 137. 5.2 Key Impediments by CountyBroward County Key Impediments in Broward County FloridaImpediment Housing/Lending Lack of Fair and Equal Housing Market Shortage of Violations of Limited Funding to Predatory Lending Improvement of Zoning/Land Use Discrimination on Knowledge, Lending Disparities Segregation Affordable Housing Federal, State and Meet Need for the Housing the Basis of Race, Awareness of, Opportunities Local Fair Housing Affordable Discrimination Color, National or Education Laws Housing Complaint Process Origin, Religion, on, Fair Sex, Familial status Housing and Disability Protections (Protected Classes)Number ofJurisdictions in 10 10 8 5 4 5 3 5 3 4Broward CountyCiting ImpedimentIn Their AIThe most cited impediments to fair housing choice in Broward County is the lack of knowledge, awareness of, or education on fairhousing protections impediment and the housing/lending discrimination on the basis of being a member of a protected classimpediment, with ten jurisdictions in the county citing each as impediments to fair housing choice.Indian River County Key Impediments in Indian River County FloridaImpediment Housing/Lending Lack of Fair and Equal Housing Market Shortage of Violations of Limited Funding to Predatory Lending Improvement of Zoning/Land Use Discrimination on Knowledge, Lending Disparities Segregation Affordable Housing Federal, State and Meet Need for the Housing the Basis of Race, Awareness of, or Opportunities Local Fair Housing Affordable Discrimination Color, National Education on, Laws Housing Complaint Process Origin, Religion, Fair Housing Sex, Familial status Protections and Disability (Protected Classes)Number of No Entitlement No Entitlement No Entitlement No Entitlement No Entitlement No Entitlement No Entitlement No Entitlement No Entitlement No EntitlementJurisdictions in Communities Communities Communities Communities Communities Communities Communities Communities Communities CommunitiesBroward CountyCiting ImpedimentIn Their AIIndian River County has no entitlement communities, thus, none of its jurisdictions have AI documents and impediment to fair housingchoice information available. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 138. Martin County Key Impediments in Martin County FloridaImpediment Housing/Lending Lack of Fair and Equal Housing Market Shortage of Violations of Limited Funding to Predatory Lending Improvement of Zoning/Land Use Discrimination on Knowledge, Lending Disparities Segregation Affordable Housing Federal, State and Meet Need for the Housing the Basis of Race, Awareness of, or Opportunities Local Fair Housing Affordable Housing Discrimination Color, National Education on, Fair Laws Complaint Process Origin, Religion, Housing Sex, Familial status Protections and Disability (Protected Classes)Number of No Entitlement No Entitlement No Entitlement No Entitlement No Entitlement No Entitlement No Entitlement No Entitlement No Entitlement No EntitlementJurisdictions inBroward County Communities Communities Communities Communities Communities Communities Communities Communities Communities CommunitiesCitingImpediment InTheir AIMartin County has no entitlement communities, thus, none of its jurisdictions have AI documents and impediment to fair housing choiceinformation available.Miami-Dade County Key Impediments in Miami-Dade County FloridaImpediment Housing/Lending Lack of Fair and Equal Housing Market Shortage of Violations of Limited Funding to Predatory Lending Improvement of Zoning/Land Use Discrimination on Knowledge, Lending Disparities Segregation Affordable Housing Federal, State and Meet Need for the Housing the Basis of Race, Awareness of, Opportunities Local Fair Housing Affordable Discrimination Color, National or Education Laws Housing Complaint Process Origin, Religion, on, Fair Sex, Familial status Housing and Disability Protections (Protected Classes)Number ofJurisdictions in 2 7 6 3 3 4 4 1 1 0Broward CountyCiting ImpedimentIn Their AIThe most cited impediment of fair housing choice in Miami-Dade County is a lack of knowledge, awareness of, or education on fairhousing protections, with seven jurisdictions within the county citing the issue as an impediment to fair housing choice. The second mostcited impediment in Miami-Dade County is fair and equal lending disparities, with six jurisdictions within the county citing it as animpediment to housing choice. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 139. Monroe County Key Impediments in Monroe County FloridaImpediment Housing/Lending Lack of Fair and Equal Housing Market Shortage of Violations of Limited Funding to Predatory Lending Improvement of the Zoning/Land Use Discrimination on Knowledge, Lending Disparities Segregation Affordable Housing Federal, State and Meet Need for Housing the Basis of Race, Awareness of, or Opportunities Local Fair Housing Affordable Housing Discrimination Color, National Education on, Fair Laws Complaint Process Origin, Religion, Housing Sex, Familial status Protections and Disability (Protected Classes)Number of No Entitlement No Entitlement No Entitlement No Entitlement No Entitlement No Entitlement No Entitlement No Entitlement No Entitlement No EntitlementJurisdictionsin Broward Communities Communities Communities Communities Communities Communities Communities Communities Communities CommunitiesCountyCitingImpedimentIn Their AIMonroe County has no entitlement jurisdictions, thus, none of its jurisdictions have AI documents and impediment to fair housing choiceinformation available.Palm Beach County Key Impediments in Palm Beach County FloridaImpediment Housing/Lending Lack of Fair and Equal Housing Market Shortage of Violations of Limited Funding to Predatory Lending Improvement of Zoning/Land Use Discrimination on Knowledge, Lending Disparities Segregation Affordable Housing Federal, State and Meet Need for the Housing the Basis of Race, Awareness of, Opportunities Local Fair Housing Affordable Discrimination Color, National or Education Laws Housing Complaint Process Origin, Religion, on, Fair Sex, Familial status Housing and Disability Protections (Protected Classes)Number ofJurisdictions in 1 1 0 0 1 0 0 3 0 2Broward CountyCiting ImpedimentIn Their AIThe most cited impediment of fair housing choice in Palm Beach County is predatory lending, with three jurisdictions within the countyciting the issue as an impediment to fair housing choice. The second most cited impediment in Palm Beach County is zoning/land use,with two jurisdictions within the county citing it as an impediment to housing choice. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 140. St. Lucie County Key Impediments in St. Lucie County FloridaImpediment Housing/Lending Lack of Fair and Equal Housing Market Shortage of Violations of Limited Funding to Predatory Lending Improvement of Zoning/Land Use Discrimination on Knowledge, Lending Disparities Segregation Affordable Housing Federal, State and Meet Need for the Housing the Basis of Race, Awareness of, Opportunities Local Fair Housing Affordable Discrimination Color, National or Education Laws Housing Complaint Process Origin, Religion, on, Fair Sex, Familial status Housing and Disability Protections (Protected Classes)Number ofJurisdictions in 2 1 1 1 2 0 0 0 0 0Broward CountyCiting ImpedimentIn Their AIThe most cited impediments of fair housing choice in St. Lucie County is housing/lending discrimination on the basis of being a memberof a protected class and a shortage of affordable housing opportunities, with two jurisdictions within the county citing each issue as animpediment to fair housing choice. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 141. 6. AppendixHUD PD&R Data Package- FOR BROWARD, MIAMI-DADE, & MONROE COUNTIES ONLYAnalyzing SegregationA primary metric for identifying segregation is the dissimilarity index. A dissimilarity index represents a summary measure of the extent towhich the distribution of any two groups (frequently racial or ethnic groups) differs across census tracts or block-groups. Anothercommon approach to measuring segregation is the isolation index, which compares a groups share of the overall population in ajurisdiction to the average neighborhood share for members of that group. South Florida Regional Planning Council (Broward, Miami-Dade, and Monroe Counties) Race/Ethnic Segregation Isolation Index Share of Population Dissimilarity Index (2010) Program Program Program Program Program Program Participant Participant Participant Participant Participant Participant Area Area Area Area Area Area (2000) (2010) (2000) (2010) (2000) (2010) (1) (2) (3) (4) (5) (6)Non-White/White 63% 72% 0.56 0.54 0.14 0.09Black-African American/White 19% 20% 0.72 0.68 0.38 0.34Hispanic/White 40% 48% 0.58 0.56 0.23 0.19Asian/White 2% 2% 0.36 0.37 0.01 0.02Pacific-Islander/White 0% 0% 0.49 0.52 0.02 0.03Native-American/White 0% 0% 0.65 0.70 0.00 0.00Note: The values in column (1) and (2) are the share of racial/ethnic groups in the participant geography in years 2000 and 2010, respectively. Columns (3) and (4)are the dissimilarity index for years 2000 and 2010. The index compares the spatial distribution of the two groups identified in the left-hand column, summarizingneighborhood differences over a larger geography (program participant geography or metro). Higher values of dissimilarity imply higher residential segregation.Column (5) is the isolation index calculated over the program participant geography for the year 2000, column (6) is the same for the year 2010. The isolation index CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 142. compares average neighborhood minority share for a minority person to the average minority share in the larger geography (program participant geography ormetro). Again, higher values imply higher levels of segregation. These indexes are calculated using block group 100% count data from the 2000 and 2010 DecennialCensus SF1.Racially/Ethnically-Concentrated Areas of PovertyTo assist communities in identifying racially/ethnically-concentrated areas of poverty (RCAPs/ECAPs), HUD PD&R has developed acensus tract based definition for RCAP/ECAPs. The definition involves a racial/ethnic concentration threshold and a poverty test. Theracial/ethnic concentration threshold is straightforward: RCAP/ECAPs must have a non-white population of 50 percent or more. Censustracts with this extreme poverty that satisfy the racial/ethnic concentration threshold are deemed RCAPs/ECAPs South Florida Regional Planning Council (Broward, Miami-Dade, and Monroe Counties) RCAP /ECAP - Race & Ethnicity Summary Program Participant Area Count Share (1) (2)RCAP/ECAP Tracts 34 3.8%In RCAP/ECAP Tracts:Total Population: 127,253 3.0%Non-White: 121,166 3.9%Black/African-American 63,959 7.3%Note: Column (1) is the number of RCAP/ECAP tracts, and the total of persons in those RCAP/ECAP tracts in the program participant area. Column (2) is the share oftracts designated as, and population groups living in, RCAP/ECAPs. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 143. Disparity in Access to Neighborhood Opportunity - All Persons South Florida Regional Planning Council (Broward, Miami-Dade, and Monroe Counties) Panel A - All Persons Disparities Asian Black Black - Native Pacific Hispanic Native Pacific Hispanic - All White /African Asian White Amer. - Isldr. - or Latino American Isldr. - White White Persons Persons American Persons [(3)- White White Persons Persons Persons [(4)-(2)] [(5)- Persons (2)] [(6)-(2)] [(7)-(2)] (2)] (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12)Opportunity Dimensions:Poverty Index 47 63 35 45 58 42 48 28 18 4 20 14School Proficiency Index 52 65 37 53 64 49 49 28 11 1 16 16Labor Market Engagement Index 51 66 33 50 63 44 51 33 16 3 22 16Job Access Index 48 50 44 46 49 49 48 7 5 2 2 2Transit Access Index 55 46 62 54 43 53 52 -17 -8 2 -7 -7Health Hazards Exposure Index 39 47 32 37 44 40 42 15 10 3 7 5Counts 4,293,858 816,041 781,303 1,700,000 78,769 7,067 1,150 Panel B: Persons in Poverty Disparities Poor Poor Poor Poor Poor Poor Poor Poor Asian Poor Poor Poor Black - Native Pacific All Poor Hispanic Native Pacific Hispanic - White Black Asian White Amer. - Isldr. - Persons or Latino American Isldr. - White White Persons Persons Persons [(3)- White White Persons Persons Persons [(4)-(2)] [(5)- (2)] [(6)-(2)] [(7)-(2)] (2)] (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12)Opportunity Dimensions:Poverty Index 33 50 23 32 51 0 0 27 18 -1 0 0School Proficiency Index 41 54 29 43 59 0 0 25 11 -4 0 0Labor Market Engagement Index 37 52 23 40 54 0 0 29 13 -2 0 0Job Access Index 48 54 45 47 53 0 0 9 7 1 0 0Transit Access Index 63 56 69 63 57 0 0 -13 -7 -1 0 0Health Hazards Exposure Index 35 43 31 35 39 0 0 12 7 4 0 0Counts 627,257 107,032 205,043 308,797 10,931 841 28 CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 144. Note: Columns (1)-(7) provided a weighted average neighborhood percentile ranking for each dimension (row) described in the left-hand column, weighted bycorresponding population group in each column header in Panel A. The percentiles are expressed as 100 centile buckets. Higher percentile values always reflectmore favorable average neighborhood characteristics irrespective of the dimension being an asset (proficient schools) or a stressor (poverty). Exposure weightedaverage are calculated of the program participant geography. Columns (8)-(12) are the differences across average neighborhood conditions between whites andthe column group indicated in the header. Positive values imply that whites are in a differentially higher ranking neighborhood on average than the particular groupfor the given dimension. Negative values imply the reverse, which the given racial/ethnic group is in a differentially higher ranking neighborhood relative to whitesalong the given dimension. Panel B repeats the analysis in Panel A, but focuses on the average neighborhood of persons in poverty (income< federal poverty line) .Disparities may differ due to rounding. Data for the opportunity dimensions are described in detail in the data documentation. Data on the populations in Panel A isfrom the 2010 Decennial Census SF1. Data on impoverished population in Panel B comes from the American Community Survey (ACS) 2006-2010 five year estimates.Population groups smaller than 250 people (in census 2010) or 1,000 people for ACS-sourced data are coded as zero. The higher minimum population threshold forthe ACS data is motivated by concerns about sampling error.HUD has developed a two-stage process for analyzing disparities in access to neighborhood opportunity. The first stageinvolves quantifying the degree to which a neighborhood offers features commonly associated with opportunity. This stageuses metrics that rank each neighborhood along a set of key dimensions. In the second stage, HUD combines thesedimension rankings with data on where people in particular subgroups live to develop a measure of that groups generalaccess or exposure to each opportunity dimension. These summary measures can then be compared across subgroups tocharacterize disparities in access to opportunity. HUD considers opportunity a multi-dimensional notion. To focus theanalysis, HUD developed methods to quantify a selected number of the important stressors and assets in everyneighborhood. These dimensions were selected because existing research suggests they have a bearing on a range ofindividual outcomes. In particular, HUD has selected six dimensions upon which to focus: • Neighborhood School Proficiency • Poverty • Labor Market Engagement • Job Accessibility • Health Hazards Exposure • Transit AccessInvariably, these dimensions do not capture everything that is important to the well being of individuals and families. Inquantifying indicators of neighborhood opportunity, HUD is not making a definitive assessment of ones life chances basedon geography. HUD is quantifying features of neighborhoods for the purpose of assessing whether significant disparities existin the spatial access or exposure of particular groups to these quality of life factors. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 145. While these important dimensions capture a number of key concepts identified by research as important to quality of life,the measures are not without limitations. PD&R constrained the scope of HUD-provided items to those that are closely linkedto neighborhood geographies and could be measured consistently at small area levels across the country. For example,HUDs measure of school performance only reacts to elementary school proficiency. It does not capture academicachievement for higher-grades of schooling, which is important to a communitys well being, but likely less geographically-tied to individual neighborhoods than elementary schools. Similarly, the health hazard exposure measure only capturesoutdoor toxins, missing in-door exposures. The national-availability restriction is a necessity given that all HUD programparticipants must complete an Assessment of Fair Housing. HUD realizes that there are other assets and stressors that arerelevant for opportunity, such as neighborhood crime or housing unit lead and radon levels. However, these lack consistentneighborhood-level data across all program participant geographies. As a consequence, HUD encourages programparticipants to supplement the data it provides with robust locally available data on these other assets and stressors, so thatthe analysis is as all encompassing as possible. CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 146. Disparity in Access to Neighborhood Opportunity - All Children South Florida Regional Planning Council (Broward, Miami-Dade, and Monroe Counties) Panel A - All Persons Disparities Black Asian Black Native Pacific Hispanic Native Pacific - Hispanic - All White /African Asian Amer. - Isldr. - or Latino American Isldr. White - White White Children Children American Children White White Children Children Children [(3)- [(4)-(2)] [(5)- Children [(6)-(2)] [(7)-(2)] (2)] (2)] (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12)Opportunity Dimensions:Poverty Index 54   57   30   45   70   45   0   27   12   -­‐13   12   0  School Proficiency Index 51   53   33   47   63   48   0   19   5   -­‐10   4   0  Labor Market Engagement Index 53   55   37   49   76   48   0   18   7   -­‐20   7   0  Job Access Index 48   47   58   52   52   50   0   -­‐11   -­‐5   -­‐6   -­‐4   0  Transit Access Index 10   10   10   10   10   10   0   0   0   0   0   0  Health Hazards Exposure Index 52   55   31   43   51   48   0   24   11   4   7   0  Counts 153,056   126,662   11,988   6,887   2,184   476   144             Panel B: Persons in Poverty Disparities Poor Poor Poor Poor Poor Poor Poor Black Poor Asian Poor Poor Poor Native Pacific All Poor Hispanic Native Pacific - Hispanic - White Black Asian Amer. - Isldr. - Children or Latino American Isldr. White - White White Children Children Children White White Children Children Children [(3)- [(4)-(2)] [(5)- [(6)-(2)] [(7)-(2)] (2)] (2)] (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12)Opportunity Dimensions:Poverty Index 31   36   13   34   0   0   0   23   3   0   0   0  School Proficiency Index 43   47   31   45   0   0   0   15   2   0   0   0  Labor Market Engagement Index 35   38   26   40   0   0   0   13   -­‐2   0   0   0   CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 147. Job Access Index 51   46   63   57   0   0   0   -­‐17   -­‐10   0   0   0  Transit Access Index 10   10   10   10   0   0   0   0   0   0   0   0  Health Hazards Exposure Index 44   52   25   34   0   0   0   26   18   0   0   0  Counts 27,055   18,007   6,090   2,804   92   8   0  Note: columns (1)-(7) provided a weighted average neighborhood percentile ranking for each dimension (row) described in the left-hand column, weighted bycorresponding population group in each column header in Panel A. The percentiles are expressed as 100 centile buckets. Higher percentile values always reflectmore favorable average neighborhood characteristics irrespective of the dimension being an asset (proficient schools) or a stressor (poverty). Exposure weightedaverage are calculated of the program participant geography. Columns (8)-(12) are the differences across average neighborhood conditions between whites andthe column group indicated in the header. Positive values imply that whites are in a differentially higher-ranking neighborhood on average than the particular groupfor the given dimension. Negative values imply the reverse, which the given racial/ethnic group is in a differentially higher ranking neighborhood relative to whitesalong the given dimension. Panel B repeats the analysis in Panel A, but focuses on the average neighborhood of children in poverty (income< federal poverty line) .Disparities may differ due to rounding. Data for the opportunity dimensions are described in detail in the data documentation. Data on the populations in Panel A isfrom the 2010 Decennial Census SF1. Data on impoverished population in Panel B comes from the American Community Survey (ACS) 2006-2010 five year estimates.Population groups smaller than 250 people (in census 2010) or 1,000 people for ACS-sourced data are coded as zero. The higher minimum population threshold forthe ACS data is motivated by concerns about sampling error.Identified Impediments to Fair Housing- Matrix Housing/Lendi ng   Discrimination   Lack  of   on  the  Basis  of   Knowledge,   Limited   Improvement   Race,  Color,   Shortage  of   Violations  of   Awareness  of   Fair  and  Equal   Housing   Funding  to   of  the  Housing   National   Affordable   Federal,  State   Predatory   Zoning/Land   County   Place   or  Education   Lending   Market   Meet  Need  for   Discrimination   Origin,   Housing   and  Local  Fair   Lending   Use   on  Fair   Disparities   Segregation   Affordable   Complaint   Religion,  Sex,   Opportunities   Housing  Laws   Housing   Housing   Process   Familial  status   Protections   and  Disability   (Protected   Classes)   Browar d       X   X   X       X   X               CountyBroward   ,  FL     Coconu t   X   X                       X   X   X   Creek,  Broward   FL     Coral   X   X   X       X                      Broward   Springs CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 148. ,  FL     Davie,   X   X                                  Broward   FL     Fort   Lauder X           X   X       X   X          Broward   dale,  FL     Hollyw     X   X           X                  Broward   ood,  FL     Lauder X   X   X   X                          Broward   hill,  FL     Margat                             X          Broward   e,  FL     Miram X   X                       X   X   X  Broward   ar,  FL     Pembr oke   X   X                       X   X   X   Pines,  Broward   FL     Plantat X       X       X   X                  Broward   ion,  FL     Pompa no       X   X   X       X   X           X   Beach,  Broward   FL     Sunrise X       X       X                      Broward   ,  FL     Tamara X   X   X   X       X                  Broward   c,  FL     No   Entitle No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement  Indian   ment   Communities   Communities   Communities   Communities   Communities   Communities   Communities   Communities   Communities   Communities  River   CommCounty   unities   Miami-­‐ Dade       X   X           X                  Miami   CountyDade   ,  FL  Miami   Hialeah     X   X           X   X              Dade   ,  FL     HomesMiami   tead,       X   X       X                      Dade   FL    Miami   Miami,   X   X   X       X       X   X   X      Dade   FL     Miami  Miami   Beach,       X   X   X       X   X              Dade   FL     Miami  Miami   Garden     X   X   X       X   X              Dade   s,  FL     CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT
  • 149. North  Miami   Miami,   X   X       X   X                      Dade   FL   No   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   Entitle Communities   Communities   Communities   Communities   Communities   Communities   Communities   Communities   Communities   Communities   ment   CommMartin   unities   No   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   No  Entitlement   Entitle Communities   Communities   Communities   Communities   Communities   Communities   Communities   Communities   Communities   Communities   ment   CommMonroe   unities   Palm  Palm   Beach                               X       X  Beach   County   Boca  Palm   Raton,   X                                      Beach   FL     Boynto n                               X          Palm   Beach,  Beach   FL     Delray  Palm   Beach,       X           X           X          Beach   FL    Palm   Welling                                        Beach   ton,  FL     West   Palm                                       X  Palm   Beach,  Beach   FL     Port  St.   Lucie,   X               X                      St.  Lucie   FL     Fort   Pierce,   X   X   X   X   X                      St.  Lucie   FL   CARRAS COMMUNITY INVESTMENT, INC. SEVEN50 REGIONAL ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING DRAFT