HomeMy WebLinkAboutAgenda - 05-16-2006-5jORANGE COUNTY
BOARD OF COMMISSIONERS
ACTION AGENDA ITEM ABSTRACT
Meeting Date: May 16, 2006
Action Agenda
Item No.
SUBJECT: RFP Award —Contract for Conducting Analysis of Impediments to Fair Housing
Choice
DEPARTMENT: Human Rights and Relations/
Housing and Community
Development
Purchasing
ATTACHMENT(S):
(Under Separate Cover)
Proposal
Sample Study Report
PUBLIC HEARING
(Y /N) No
INFORMATION CONTACT:
Milan T. Pham, 960 -3877
Tara L. Fikes, 245 -2490
Pam .Jones, 245 -2652
PURPOSE: To authorize staff to contract with Donald B. Eager & Associates, LLC to conduct
an Analysis of Impediments to Fair Housing Choice study.
BACKGROUND: In 1995, the U.S. Department of Housing and Urban Development (HUD)
announced that entitlement communities — those communities that receive direct federal
funding from Community Development Block Grant (CDBG), HOME Investment Partnership
and Emergency Shelter Grant programs — are required to conduct a study of existing barriers to
housing choice. The required study is referred to as the "Analysis of Impediments" (AI) and is
part of entitlement communities' consolidated planning process.
In early 2006 as part of HUD's increased focus on fair housing enforcement, HUD required all
agencies representing entitlement communities and any corresponding Fair Housing Assistance
Programs (FHAP), such as the Department of Human Rights & Relations, to attend a day long
fair housing and analysis of impediments meeting. At that meeting, HUD informed entitlement
agencies that the Fair Housing Enforcement Organization (FHEO) at HUD would be monitoring
their efforts at affirmatively furthering fair housing through updated analysis of impediments and
records of efforts taken to reduce or eliminate identified impediments.
Analysis of Impediments
The purpose of the Al is to examine how state and local laws and private public and non-
profit sector regulations, administrative policies, procedures, and practices impact the
location, availability and accessibility of housing in a given area. The AI is not a Fair
Housing Plan rather it examines the current state of fair housing choice and identifies
specific barriers that need to be addressed if future fair housing initiatives are to be
successful.
Orange County
Orange County's Al will include an analysis of pertinent census data, prior and current activities
to promote fair housing, private market issues that impact sale and rental of housing such as
business location, Home Mortgage Disclosure Act (HMDA) data analysis and a review of public
policies which affect the provision of fair housing. The consultant will supplement
housing /economic data collection and analysis with stakeholder and advocate surveys,
discussion, and field visits to elucidate concerns, opinions, and observations. Al will address
data and findings strategic to all municipalities and the unincorporated areas of the County.
2006 Al RFP Process
Orange County Purchasing Department released a request for proposals to six prospective
firms and advertised the proposal on its website. Two proposals were received from the
following firms:
• Donald B Eager & Associates of Lancaster, Ohio
• J -Quad & Associates, LTD of Dallas, Texas
The Directors of Human Rights and Relations and Housing conducted a thorough review of the
two proposals. After reviewing the proposals, the group unanimously chose Eager and
Associates (Eager). Eager has conducted AI's in North Carolina and one of Eager's AI's
received a HUD Best Practice Award, Eager's timeline for completion was month shorter than
the other vendor. In 2003, Eager conducted an analysis of HMDA data for the county. Eager
and Associates total cost to conduct the study is $7,500 and includes all travel and lodging
expenses. Contacted references provided positive feedback regarding quality and timeliness of
Eager's work.
FINANCIAL IMPACT: The estimated value of this contract is approximately $7,500. The HUD
Partnership Initiative Grant received by the Human Rights and Relations Department completely
covers the cost of the contract.
RECOMMENDATIONS: The Manager recommends that the Board: 1) award a contract to
Donald B Eager & Associates of Lancaster, Ohio in the amount of $7,500 to conduct an
Analysis of Impediments to Fair Housing Choice study; and 2) authorize the County Manager to
execute the resulting agreement, contingent upon final review by staff and the County Attorney.
E4
ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE
ORANGE COUNTY, NORTH CAROLINA
SCOPE OF SERVICES
Approach and Services to be Performed
In 1996, Donald B. Eager and Associates, conducted an Analysis of Impediments for the
Cuyahoga County Entitlement Group, a multi - jurisdictional public organization representing
seven entitlement communities surrounding and including Cleveland, Ohio, This was one
of the first multi - jurisdictional A.I.'s conducted by a single organization in the country, and
one that was rife with challenges, not the least of which was the status of two of the
jurisdictions as former defendants in landmark fair housing litigation filed by the United
States Department of Justice Moreover, the Cuyahoga Metropolitan Housing Authority,
the predominant assisted housing provider in the region, was operating under a federal
court consent decree dictating remedial action for fair housing violations
Notwithstanding these difficulties, Donald B.
multi - jurisdictional Analysis of Impediments
Practices Award in 1999'
Eager & Associates conducted a six -month
that was ultimately awarded a HUD Best
Since 1996, Donald B, Eager & Associates have conducted additional multi - jurisdictional
Analyses of Impediments in Cincinnati /Hamilton County, Ohio; Kettering /Montgomery
County, Ohio (1999 & 2004/5); Hamilton /Butler County, Ohio, and
Greensboro /Burlington /High Point North Carolina. They have also conducted numerous
A.l.'s throughout the country, from Santa Fe, New Mexico to Albany, Georgia. During the
conduct of each of these studies, Donald B. Eager & Associates has continued to evolve
the firms's craft, incorporating valuable lessons learned along the way. Today, Donald B.
Eager & Associates are considered among the pre- eminent experts in the country
regarding the conduct of the Analysis of Impediments both in small and large jurisdictions
The firm's approach to the conduct of Orange County's Analysis of Impediments will
incorporate the lessons learned from years of A. I. experience around the country. We
have learned that the A.I. must be a collaborative effort of the consultant actually doing the
work and the community, relying upon their individual and collective experience in the
region to assure that the project includes all possible information and approaches.
'Building a Better Tomorrow: 1999 HUD Best Practices, pg 105 (U.S. Department of Housing and
Urban Development)
0
40j, Orange County, North Carolina
0 =° Proposal - Analysis of Impediments to Fair Housing Choice
1. IDENTIFICATION OF FAIR HOUSING CONCERNS & PROBLEMS
o Consultantwill collectand reviewlocal lenders' Community Reinvestment Act (CRA)
material. This will be used to discover the banks' market areas and their compliance
with federal fair lending laws and regulations.
o Consultant will also collect and review data from local lenders' Home Mortgage
Disclosure Act (HMDA) reports. These reports outline the type, number, dollar
amount, denial rate and other important information of loans made by lenders. This
is a detailed analysis of local lending patterns in the community.
o Consultant will review and prepare recommendations regarding fair housing
compliance of local zoning regulations, occupancy regulations, etc. This review will
relate how these documents, rules and regulations apply to those issues contained
in state and federal fair housing regulations and their relationship to other fair
housing rules and regulations.
o Consultant will develop a procedure to discover the fair housing relationships in the
sale and rental markets of the community. This procedure will review the terms,
conditions and /or privileges of the sale or rental of a dwelling.
o Consultant will also develop a procedure that provides a complete analysis of
housing advertising practices in the community. This activity will involve a review
of housing advertising placed in local newspapers, home and apartment guides and
other advertising media
o Consultant will conduct a review of appraisal practices in the community, were
information is available. This will include an analysis also of Realtor activities
regarding fair housing activities and regulations. This analysis will include access
to multiple - listing service, broker organizations, or facilities relating to the business
of selling or renting dwellings within the community.
o Consultant will do a review of administrative policies concerning community
development and housing activities, site selection policies, local code requirements,
local zoning requirements and other housing related requirements.
o Consultant will review the nature and extent of fair housing complaints and /or suits
against the County Consultant will provide a database sorted by allegation,
protected class, and disposition of the complaint Data will be obtained from
information contained in case logs of authorized fair housing agencies in the County
Consultant will also utilize such information as is available from the U. S Department
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Orange County, North Carolina
ss.,�;i Proposal - Analysis of Impediments to Fair Housing Choice
of H D. and the state civil /human rights commission, and local fair housing
advocacy organizations or persons.
o Consultant will develop information on the nature and extent of incidents of racial
violence /hate crimes based on data obtained from sources outlined above
2. DEMOGRAPHIC DATA & INCOME CHARACTERISTICS & MAPS
o Consultant will review local housing and economic data to establish and show
current locations of low- moderate income populations, racial, national origin and
populations of other protected classes, housing quality and other issues needed as
part of the general analysis of lending activities This review will use existing data
available from the state, MSA, county and municipalities through their CHAS reports,
census data and other date sources This data will be used to develop a housing
profile of the area.
The data, too, will be used to develop demographic maps displaying particular
characteristics required of the analysis These characteristics will include:
Housing patterns of minorities,
Housing costs,
Vacancy rates,
Location of housing for the disabled,
Proposed housing for protected classes,
Locations of proposed housing and industrial /commercial development,
Areas of possible minority displacement,
Identification of the "central business district' concerning areas where largely
numbers of minorities live,
Mass transportation routes available.
Consultant will review 1990 & 2000 census data, community surveys, and other
relevant data to develop a database that provides a breakout, by number and
percentage, of the actual number of persons in the County jurisdiction by protected
class. Where possible consultant will use 1997, 2002 & 2007 Census estimates to
provide as complete assessment as possible Also, the analysis will include, where
possible, the relationship of the community to the MSA, county & surrounding
jurisdictions
o Income characteristics such as median income of households by protected class
where possible. In some cases this information has been difficult to obtain by
religion and disability Where it is available it has been cost prohibited. The
Orange County, North Carolina
r° Proposal - Analysis of Impediments to Fair Housing Choice
Consultant will make every effort to provide a complete economic profile of the
community, especially the protected classes for this Analysis
o Data for this section will be developed from the 1990 Census, community surveys,
Housing Assistance Plans, Consolidated Plan, FFIEC HMDA Reports, Peertrax LAIR
Program and Maptitude 4.5
3. EMPLOYMENT AND TRANSPORTATION PROFILE
o Listing of major employers by type and the number of people employed within the
jurisdiction by salary and racial groups. Identification of growth trends will be
included.
o Listing of major forms of transportation and identification of access to job centers in
the community.
4. IDENTIFICATION OF SPECIFIC IMPEDIMENTS TO FAIR HOUSING CHOICE
o A complete analysis will be made of the impediments to fair housing choice in the
following areas:
Sale and rental of housing
Provisions of brokerage services
Provision of financing assistance for housing
Provisions of homeowners insurance
Public policies and actions affecting fair housing
Administrative policies regarding CDBG and housing activities and their
relationship to fair housing and possible discriminatory practices,
Assistance in correcting past or present discriminatory practices by
developing an action plan for correction. Included in this process will be local
fair housing advocates and other groups with specific expertise in the area
that the discriminatory practice was determined.
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Orange County, North Carolina
°44.8 Proposal - Analysis of Impediments to Fair Housing Choice
5. PAST AND PRESENT FAIR HOUSING SERVICES ACTIVITIES AND ACTIONS
o An analysis will be made of existing groups and organizations and the programs that
they offer the community. This will include a survey questionnaire to ascertain the
concerns, observations and opinions of local advocacy /community organizations on
the state fo equal housing choice within the County.
o A review of past and present fair housing programs, activities, services, and actions
will be conducted. This activity will include the type and number of complaints, fair
housing education and outreach activities, lack of HUD charges, lack of suits filed
and any litigation currently involving the community and other components of the fair
housing program.
6. FINAL REPORT AND IDENTIFICATION OF SPECIFIC IMPEDIMENTS TO FAIR
HOUSING CHOICE
o Consultant will prepare a draft report to be submitted within thirty (30) days of the
execution of the contract. A final report will be submitted within sixty (60) days of
the draft report that will meet all of the requirements of the H U.D. required Fair
Housing Impediments Study including recommendations on strengthening the
community's Fair Housing Program and in addressing any issues raised by the
analysis. Included will be a Fair Housing Action Plan.
o Provide ongoing monthly reports for review and comment by the community.
Provide two final reports on the results of all activities undertaken as part of the
Fair Housing Impediments Study.
o Donald B. Eager & Associates, Inc will certify that all activities conducted as part
of this project will follow and include all activities and requirements of 24 CFR 904
Also, that all County requirements for this project are met
o All activities will be completed and final reports issued with in ninety (90) days of the
contracts execution.
8. OTHER SERVICES: OUTREACH /EDUCATION SERVICES
Donald B. Eager and Associates currently provides fair housing services including
education /training, outreach (materials /advertising) and enforcement to fifteen (15)
cities and counties in Ohio And serves on an advisory committee for the State of
Ohio on fair housing programs in the State.
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Orange County, North Carolina
Proposal - Analysis of Impediments to Fair Housing Choice
The consultant will conduct training to assist Community Development Staff, local
non - profit service agencies who are sub - recipients under the CDSG program in
identifying and responding to potential illegal housing practiced directed at client
populations.
Develop and distribute fair housing information for landlords in English and Spanish.
Work with the County to conduct two collaborative presentations and one training
session providing information on fair housing laws. Specifically: Presentation of the
report to the elected County officials, participating jurisdictions elected officials and
senior staff of all participating jurisdictions. Also, one additional training regarding
fair housing will be presented upon the County's request to additional attendee's as
determined by the County Presentations and training seminars will be developed
and organized with the County input and participation as necessary.
The total, inclusive budget for this project is projected to be $7,500.00, this is based on an
hourly rate of $55 00, and is a not to exceed amount. Orange County is a previous
contractor with Donald B. Eager & Associates and the hourly rate represents a discount of
$10.00 per hour.
This budget includes all cost associated with completing the project, including any travel,
materials, software, or other expenses. It also includes preparation of requested training
sessions as outlined in RFP. It is our policy to work with the community, if budgets need
to be negotiated Donald B. Eager & Associates will do all that it can to assure that we
provide our usual high quality of work within the designated budget of the County.
Due to the size of the AIFHC the budget is based on assistance from the County in
completing the project Assistance needed will include, provision of local data, current
Consolidated Plan, Zoning and Housing Codes, assistance in gathering any data that the
County might have that would be necessary to complete the project, assistance in
scheduling any local meetings and /or contacts, and other assistance as determined by the
County and Donald B Eager & Associates,
Those assigned to the project will include Donald B. Eager, who will be responsible for the
research and writing of the report, Linda S. Eager who will serve as project manager
assuring that all stated tasks are completed and on time, also Kim Griffith who will serve
as technical editor and researcher The hourly rate is the same for all staff involved in the
project
10. TIME OF COMPLETION
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Orange County, North Carolina
Proposal - Analysis of Impediments to Fair Housing Choice
The start date for this project shall be the immediately upon execution of the contract and
all documents shall be provided within ninety days of that execution. Donald B. Eager &
Associates will assure that all deadlines imposed by the County will be met. Donald B.
Eager & Associates assures that adequate staff and time will be assigned for prompt
completion of the project.
11. PAYMENT SCHEDULE
Upon execution of the contract a payment schedule will be developed based upon
completion schedules of the project.
12. DATA SOURCES
The following sources of data shall be used to complete the project (this is not a complete
list):
2000 Census and available yearly updates
County and local resources
Appropriate State organizations and agencies
Appropriate Federal agencies
Maptitude 6.5
Peertrax - Lending Data Program - Most current data 2004
13,
Donald B. Eager and Associates will submit monthly reports to the County detailing
activities completed to date. A draft will be submitted within thirty days of the execution of
the contract and a final report shall be presented for review and comment prior to final
submission.
14. CONSULTANT ABILITIES AND EXPERIENCE
Donald B. Eager has completed AIFHC across the United States, including every major
County in the State of Ohio. A list of those communities are included in the attached
corporate profile of Donald B. Eager & Associates, LLC. Below are listed three references
for completed AIFHC projects of similar size to Orange County. Additional areas where
A.1 's have been completed is listed in the attached corporate profile and experience
information.
John Minter, Dir. of Community Development - City of Murfreesboro, TN - 615 - 890 -4660
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to
111 W. Vine St, 37133 - Project completed in late 2005
Mary Jo Smith, Dir. Community Development - City of Lancaster, OH - 740- 687 -6663
111 S Broad St. Suite 211 - 43130
Elizabeth Rogers, CDBG Administrator- County of Cuyahoga Falls, Ohio - 330 - 971 -8140
2310 Second St. - 44222 - Project completed in March 2006
Donald B. Eager & Associates has previously worked with the Department of Human Rights
and Relations in completing a Fair Lending Analysis Contact person is Milan Pham,
Director, 919 -960 -3877.
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Donald B. Eager and Associates, LLC was officially incorporated in 1995, although the
company's was formed in 1991 and its collective fair housing /community planning
experience dates to 1977 when Donald Eager was a Planner for the Northeast Regional
Planning Agency in Ohio.
The company's staff has served as Directors of prestigious private fair housing
organizations and community development corporations. They have authored fair
housing statutes and regulations, litigated fair housing cases, and advised Governors
on fair housing /fair lending issues. They have trained non - profit organizations, city
officials, state agencies, and HUD Field and Executive Staff where they received the
highest rating of any training program in the agency's history,
Donald B. Eagerand Associates, LLC has conducted Fair Housing Impediments Analysis
in nine states and for over thirty jurisdictions. Many of these analyses have been for
the largest entitlement communities in the state. The company has helped set the
standard for conducting these analyses for local, state and federal agencies. By
developing a model that can be used in rural and urban communities, the Impediments
Analysis can be used with equal success for long and short term planning.
The company has developed a nationally recognized expertise in fair lending. It has
developed affirmative marketing agreements for mortgage lenders, provided training
on how to use lending data and prepared research on Home Mortgage Disclosure Act
data for states and local communities. Recently the company completed one of the
most comprehensive lending research projects ever undertaken in the State of Ohio.
Staff has also assisted state agencies and private non - profit fair housing
organizations in developing lending testing programs.
Staff has assisted many communities in developing sound, effective zoning regulations,
housing codes and implementation strategies. Staff has developed effective
community -based plans for the distribution of affordable housing and fair share plans.
They have worked with local communities in preparing community development efforts
in the area of housing and economic development. Staff has been responsible for the
design and implementation and coordination of numerous fair housing testing programs
in sales, rental, lending and insurance testing
a
The Company's staff has received numerous national and state awards and citations
for their remarkable accomplishments in the fair housing /fair lending field. Their
extensive
and diverse experience is recognized throughout the United States. In sum, Donald
B. Eager and Associates, LLC is a proven expert - in every significant sense of the
word.
Staff
Donald B. Eager, President
Linda S. Eager, Senior Associate
Kim Griffith, Contract Associate
Office
2102 Scenic Dr. NE - Suite 2
Lancaster, Ohio 43130
740 - 653 -2498
740 - 653 -2498 FAX
E MAIL - deager @dbeager.com
E MAIL - Iseager @greenapple.com
NATIONAL TOLL FREE 1- 800 - 850 -0467
www.dbeager.com (Currently being updated)
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Donald B. Eager and Associates, LLC is proud to offer the following range of expert
services:
Design and Implementation of Audit/Testing Programs (sales, rental, lending A insurance)
Tester Training, Education and Recruitment
Organization and Development of Private and Public Fair Housing Agencies
Fair Housing Training for Commissions & Boards
Fair Housing Continuing Education Courses for Real Estate Professionals
Design and Implementation of Education and Outreach Programs
Case Management and Evaluation
Administrative and Judicial Complaint Preparation and Oversight
Monitoring of Consent Decrees /Dispute Resolutions
i -
Conduct Analysis of Impediments to Fair Housing Choice
Assistance in Preparation of Consolidated/Comprehensive Plans
Design and Development of Fair Housing Action Plans
Drof ting of Fair Housing Legislation /Administrative Regulations
Assessment of Zoning /Building /Real Property Tax Regulations
Assistance in Achieving Substantial Equivalency
Comprehensive HMDA Analysis, with Overall Lending Review
CPA Evaluations, Training and Monitoring
ECOA Evaluations, Training and Monitoring
Design and Development of LMI Underwriting Guidelines Organization and
Development of Loan Counseling Programs
Design and Implementation of Audit/Testing Programs
Design and Implementation of HO Insurance Testing Programs
Evaluation and Analysis of HO Insurance Policies, Underwriting Criteria
Design, Implementation and Analysis of Lending Testing Programs for industry,
government and non- profits
M
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General Training in Non - Profit Real Estate Development
Assistance in the Creation of CDC's and CHDO's
Fair Housing Impact Analyses of Proposed Development Projects
Overall Project Development Assistance for LMI and Affordable Housing
Assistance in Preparation of Consolidated /Comprehensive Plans
Advice and Assistance to PHA's and Assisted Housing Projects
Design and Writing of Consolidate Plans
Design and Implementation of Area Wide Housing Opportunities Plans
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As Fair Housing Consultants, Donald R Eager d Associates, LLC, have provided
services to the following areas:
Arizona Attorney General's Office, AIFHC - Lending Only
Southern Arizona Fair Housing Center
Arizona Fair Housing Center
Arizona Association of Realtors
Kentucky Fair Housing Center
Minnesota Fair Housing Council
Savannah /Chatham Fair Housing Agency
North Dakota Fair Housing Council - AIFHC
Department of Housing & Urban Development
Ohio Community Reinvestment Coalition
The City of Texarkana, Arkansas - AIFHC
The City of Fort Smith -AIFHC
The City of Fort Smith Consolidated Plan
Arkansas Realtors Association
The City of Albany, Georgia - AIFHC
Human Relations Commission, State of Montana
North Dakota Regional Fair Housing Conference
North Dakota Bar Association, Conference for Lawyers,
City of Little Rock, Arkansas
The City of Little Rock Community Housing Resource Board
The Louisiana ACORN Fair Housing Organization
The New Mexico ACORN Fair Housing Organization
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The City of Santa Fe, New Mexico - AIFHC
Tierra Del Sol Housing Corporation
Housing Consortium- Cities of Greensboro, High Point and Burlington, Alamance
County and Guilford County, North Carolina - City and County consortium
for multi - jurisdictional Fair Housing Impediments Analysis
The City of Omaha Nebraska - AIFHC
The City of Bismarck, North Dakota - AIFHC
The City of Grand Forks, North Dakota - AIFHC
Donald B, Eager & Associates, LLC, has worked with over 50 cities and counties, from
small rural communities to large urban cities. The group manages over 15 fair housing
programs in the state, including education and outreach and enforcement, Staff
conducted AIFHC for the below listed urban areas, all a multi - jurisdictional project,
plus an additional AIFHC, in 35 cities and counties in Ohio. A list of some of the
AIFHC's completed is included below, multi jurisdictional areas are in Bold.
City of Cleveland /Cuyahoga County- Included 7 communities and Cuyahoga
County in a multi - jurisdictional AIFHC - Best Practice Award from HUD
Columbus /Franklin County - AIFHC
Cincinnati /Hamilton County - AIFHC
Montgomery County/ City of Kettering - AIFHC (2004/2005)
Greensboro HOME Consortium - Cities of Greensboro, High Point & Burlington
and the Counties of Alamance & Guilford, North Carolina
Buckeye Hills Planning Organization - Ohio counties of Washington, Morgan&
Noble
Santa Fe, New Mexico
Texarkana, Arkansas
Fort Smith, Arkansas
Albany, Georgia
Bismarck, North Dakota
Macon, Georgia (with Tanya, Inc.)
Grand Forks, North Dakota
Orange County, North Carolina
(Lending Analysis)
City of Greensboro, North
Carolina (lending Analysis)
Hamilton, Ohio
Elyria, Ohio
Lorain, Ohio
Bowling Green, Ohio
Lancaster, Ohio
Clermont County, Ohio
City of Fairfield, Ohio
City of Barberton, Ohio
City of Mobile, Alabama
(Lending Analysis)
North Ridgeville, Ohio
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Donald B. Eager & Associates currently has three continuing education courses
certified by the Ohio Division of Real Estate:
Fair Housing 2006 - 3Hours CE
Mortgage Lending and The Real Estate Professional - 3 Hours CE
Harvesting Wealth - An Introduction to Predatory Lending - 1 Hour CE
Donald B. Eager has been teaching real estate related courses for more than 20 years
and has been proven one of the outstanding trainers in the State. Combined with
other staff who assist in the various training the Company provides a class that is
informative and fun.
In 2005 the Company offered real estate courses in Ottawa County, City of Newark,
Clinton County /City of Wilmington, Knox County /City of Mt. Vernon, Ashtabula
County/City of Ashtabula, City of Conneaut, City of East Liverpool, City of East
Palestine /City of Salem, Jefferson County, and the City of Rittman.
In total the Company has conducted over 450 training seminars for real estate
professionals, lenders, community leaders and fair housing advocates.
Donald B. Eager & Associates, LLC, has been facilitating meetings, developing citizens'
participation programs and working with community -based organizations for twenty
years. As planners they have worked to organize public meetings for Community
Development programs, Group Homes, HOME and HOPWA projects, fair housing and
mediation.
Some of its earliest efforts were in gathering public assistance in placing low -
moderate income housing in communities that were resistant to such housing. Its
efforts in developing Area -wide Housing Opportunities Plans (AHOP) as means of
dispersing public housing were some of the first in Ohio. Staff has worked with many
organization's in putting together public outreach programs and in encouraging
participation from citizens in the planning process.
Donald B. Eager & Associates currently operates Ohio Formula and /or CHIP fair
housing programs in the following communities:
City of Ashtabula
City of Buycrus
Ashtabula County
City of Cuyahoga Falls
City of Conneaut
City of Wooster
Jefferson County
Hardin County
Wayne County (Cities of Orrville and Rittman)
Clinton County
City of East Liverpool
City of Wilmington
City of East Palestine
Knox County
City of Salem
City of Mt. Vernon
Madison County
The Fair Housing Programs for these jurisdictions include education, outreach and
enforcement.
For a complete listing of activities past and present in Ohio please call our national
toll -free number 1- 800 - 850 -0467 for a detailed list.
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ORANGE COUNTY, NORTH CAROLINA
PROPOSAL ACTIVITY TIME LINE
FIRM: DONALD B EAGER AND ASSOCIATES
2102 Scenic Dr NE
LANCASTER OHIO 43130
TOTAL BID: $7,500.00
TASK 1 - Examine Date Including Demographic, Income, Employment, etc.
MONTH MONTH
MONTH
JOB CATEGORY 1 2
3
Review of pertinent census demographics
regarding race, gender, national origin, etc.
Economic data from Census, Dept. Of Labor,
state and local resources, employment data,
locations of employment, general job types,
etc.
Transportation data from census, local
resources, mass transit routes, travel to
work, etc.
Review income, poverty data from local,
state, federal resources.
Review housing data, housing patterns,
developments, age & quality, location, costs,
etc.
Review the relationship between income on
ability to purchase homes and rent units in
County.
Review local reports and studies including
consolidated /comprehensive plans, housing
programs, community development
programs etc.
Develop maps of important data.
4q
TASK 2 — Prior and current activities that promote fair housing, etc.
MONTH MONTH
MONTH
JOB CATEGORY 1 2
3
Review local rules and regulations regarding
fair housing.
Conduct data review type, number an
disposition of fair housing complaints in the
County, where available.
Interview and work with local fair housing
office to ascertain any issues or problems for
the various regions, develop suggestions on
addressing those issues.
Review of Real Estate Practices where
possible to determine any adverse practices,
including appraisal's
Interview local public and private agencies,
members of the housing industry and others
to determine extent of housing /fair housing
issues in the County.
TASK 3 — Examine private market issues that relate in the sale or rental of housin , etc.
MONTH MONTH MONTH
JOB CATEGORY
1 2 3
Collect and Review data from lenders doing
business in the County regarding Home
Mortgage Disclosure Act data, This review
includes local lenders, lenders from outside
of the State, sub prime lenders. Mapping of
pertinent data such as applications, denials,
originations, etc. b various demographics.
Review, discuss and map by locations and
specific demographic issue the location of
banks check cashing stores, awn shops.
Review, discuss and map pertinent insurance
data that is available. Map by location
insurance offices offering homeowners
insurance b specific demographic issues.
Where possible review and discuss rental
property locations, costs of units, availability
of units etc.
Review of local advertising for homes for sale
and for rent. Including local newspapers,
rental /sales books and other similar
documents. Determine the type of ads from
display to classified, content of ad as it
relates to fair housing advertising regulations
aQ
TASK 4 — Review Public Policies and Actions Which Affect the Provision of Fair Housin .
JOB CATEGORY
MONTH
MONTH MONTH
JOB CATEGORY
1
2 3
Review local zoning code and their impact on
fair housing rules and regulations such as
family definitions, group homes, lot size,
development restrictions, affordable housing,
etc.
Review in detail any and all housing codes
and /or other regulations and codes that
pertain to housing, housing developments
such as subdivision regulations.
Review housing programs and community
development programs offered by the State
and its grantees for compliance w/ fair
housing rules and regulations and
compliance w/ accessibility guidelines.
Review of housing type offered by local
housing authorities and relevant practices.
Review of demographics regarding housing
authorities. Availability and type of housing,
location of housing and resident placements.
Review of reports and documents regarding
the housing authorities (5 e— Plans etc.
TASK 5 — Identify Impediments and Methods of Correction
JOB CATEGORY
MONTH
1
MONTH MONTH
2 3
Discussion of all impediments identified.
Development of an Action Plan to assist in
implementing a constructive response to
impediments determined. Organized by
priority, type of action to take and time frame
for completion.
Submission of General Draft Report
Submission Monthly Reports
Submission of Final Report
oil
City of Cuyahoga Falls, Ohio
88 n 88 Analysis of Impediments to Fair Housing Choice
1.0 INTRODUCTION 3
2,0 FAIR HOUSING AND THE COMMUNITY
3
2.1 Why Fair Housing is Important to the Community
4
2,2 The Analysis of Impediments to Fair Housing Choice (AI
5
3,0 HOUSING MARKET AND NEEDS ASSESSMENTS
5
3.1 Location and Size of the Community .. . ,
6
3 2 Population _
7
3,2 Minorities and Race _ _ ..
7
3.3 Gender _
11
3 4 Family Status .
12
3,5 Disability Status
13
3.6 Income Characteristics of Protected Classes _
15
3 7 Poverty and Minorities _
15
3,8 Poverty and Gender . , . _
16
3.9 Poverty Status by Family Type and Presence of Children
17
3.10 Persons Receiving Supplemental Security Income (SSI) and Public Assistance
17
4.0 ECONOMICS AND TRANSPORTATION .
18
4 1 Employment Status Profile
18
42 Occupation Profile
21
43 Industry Profile
22
4 4 Income and Wages Profile
24
5.0 - ADVERTISING IN THE CITY OF CUYAHOGA FALLS
26
Local Review of Advertising
29
6.0 - ZONING and HOUSING REGULATIONS. ..
30
6.1 Potential Impact of Zoning and Housing Regulations on Fair Housing . ..
30
6.1 Introduction
31
6 2 Local Review of Zoning Codes , . , _
33
7.0 HOME MORTGAGE LENDING ACTIVITY ..
33
71 Introduction to Lending In Cuyahoga Falls
35
7.3 Sub Prime Lending . _ .. , . _ ..
36
7.3 General Lending in Cuyahoga Falls
39
7,5 Applications By Loan Purpose , . , .
41
7.6 City of Cuyahoga Falls's Largest Lenders
43
7.7 Lending to Low and Moderate - Income Households ..
44
7 8 Lending By Race _
45
8.0 FAIR HOUSING ACTIVITIES .. , 47
9.0 IDENTIFICATION OF ISSUES _.. 48
9
of .1, City of Cuyahoga Falls, Ohio 1
1@0 Analysis of Impediments to Fair Housing Choice
1.0 INTRODUCTION
The City of Cuyahoga Falls has completed this Analysis of Impediments to Fair Housing
Choice (AI) as part of a comprehensive program developed by the Department of Housing
and Urban Development (HUD) to assure that communities are meeting requirements "to
affirmatively further fair housing" as set forth in the Community Development Block Grant
(CDBG) Program. The goal of this analysis is to identify impediments to fair housing and
provide recommendations that can be used to ameliorate any fair housing impediments.
This analysis was conducted for the City by Donald B Eager and Associates, LLC
(Consultant). The Consultant has used a variety of resources to prepare the analysis. A
list of these resources is included in Appendix 1.
Throughout this document we use a number of technical terms related to US Census data,
lending data and other information. To help the reader understand what these terms mean
we have included in Appendix 2 Glossary of Key Terms.
2.0 FAIR HOUSING AND THE COMMUNITY
Fair Housing means that all citizens and non citizens of the United States can live where
they want and can afford without regard to their race, color, national origin, sex, religion or
because of their disability or have children in the family (familial status). Fair Housing is
protected by federal, state and local laws in City of Cuyahoga Falls. Fair Housing law very
broadly covers appraisal, renting, sale /buying, financing and insuring of housing.
The consequence of housing discrimination includes: the denial of housing in the area of
choice; emotional harm and financial loss; denial of quality of an integrated community and
associations; denial of expanding job opportunities in the suburbs; lack of access to greater
choices of schools; negative attitudes toward the community; perpetuation of other housing
problems and the loss of cultural diversity. Housing discrimination is rarely blatant. It is
usually disguised and, more often than not, done with a smile and a handshake. It is
important that each community guarantee its current and future residents that they will be
able to live where they want and can afford.
Fair Housing is not only established by federal, state and local law, but through hundreds
of court cases on every level. The cost of maintaining an effective fair housing program
can be funded through state and federal resources including Community Development
Block Grant funds. Nondiscrimination in all aspects of housing - buying, selling, renting,
financing, insuring, developing and regulating - is an established benefit and an essential
foundation of the community.
0
City of Cuyahoga Falls, Ohio 2
88 n 88 Analysis of Impediments to Fair Housing Choice
2.1 Why Fair Housing is Important to the Community
Communities need to consider fair housing issues at least as importantly as economic and
other issues. It is important to encourage residents to actively support and work toward an
equal housing market, Housing discrimination tears at the very fabric, of the community.
It encourages an environment where disputes escalate, sends out a message of apathy,
leads to segregated neighborhoods, perpetuates other housing problems and causes
financial loss to the community through lost business opportunities. In assuring equal
housing, a community makes its development and growth more successful.
The perceptions that fair housing laws are meant for "Blacks and Hispanics" or other
minorities are misguided. Fair housing regulations protect every citizen and non - citizens
of the United States, no matter their race, color, national origin, sex, religion, familial status
(presence of children) or disability. These categories are known as protected classes.
Because a community has a small minority population, it does not mean that they do not
have impediments to fair housing within their community. A good way to recognize
impediments is to ask some simple questions:
✓ How does the rental market treat families with children, especially single parents?
✓ What access do individuals with physical or mental disabilities have to housing?
✓ Are regulations designed in a way that limit access to housing for protected classes?
✓ What image does the community convey to the outside world? Are the models used
to market the community representative of all races?
✓ Do some areas within the community have a reputation that would discourage low -
moderate income persons or protected classes from attempting to live there?
✓ With the pressure of a growing urban area, are minorities or low to moderate -
income persons unable to consider significant areas in their housing search because
there is no affordable housing?
✓ Are any potential home owners eliminating some affordable areas of the community
because they would not be able to refinance or obtain adequate home owner's
insurance?
✓ Are some affordable areas of the community eliminated because there is inadequate
access by public transportation?
It is important for the City of Cuyahoga Falls to consider fair housing law as a guaranteed
protection for all people. Only then can the community help its residents share in an
important part of the American Dream - living where they choose, without regard to factors
that may negatively impact upon them because of race, color, religion, national origin, sex,
familial status or disability.
2.2 The Analysis of Impediments to Fair Housing Choice (AI)
MA
City of Cuyahoga Falls, Ohio 3
A8 o AA Analysis of Impediments to Fair Housing Choice
The City of Cuyahoga Falls has already completed an important part of its review of the
"health" of the community through the development of its Consolidated Plan for Housing
Activities. The AI is the next logical step and part of the ongoing process of community
development. Its goal is to make recommendations on how to improve the current
situation. The recommendations will assist in developing a Fair Housing Action Plan that
will be a cooperative part of the Comprehensive Plan. It is a requirement of the Community
Development Block Grant Program that recipients undertake this review and it is one that
must be taken seriously,
The Al includes: a demographic and economic profile of the community; a review of
activities and issues concerning the local housing industry; a review of local lenders, zoning
and housing regulations; current fair housing programs; and, identification of impediments
to fair housing choice. The purpose of this analysis is to make the the City of Cuyahoga
Falls, as well as the public, aware of the fair housing issues that are facing their community
and to develop strategies to address those issues. This analysis also helps develop an
ongoing process for identifying fair housing concerns and problems in City of Cuyahoga
Falls. It is useful in developing a means to inform the citizens of the community about their
fair housing rights and responsibilities.
3.0 HOUSING MARKET AND NEEDS ASSESSMENTS See Maps 1 & 2
The strengths and weaknesses of a community are the culminations of years
of tradition, growth and change. The resulting conditions have implications for the housing
and community development needs of a community. The following report provides an
overview of significant conditions and trends. It helps to clarify the housing and community
development needs and the approaches the City will need to take in order to address those
needs,
Map 1 shows the City by jurisdiction. Map 2 shows the City by census tract. These are
included since much of the statistical analysis and review of income, demographic and
other vital data utilizes census tracts and is more helpful if the reader is familiar with the
layout of these tracts.
It should be noted that the boundaries for individual census tracts between the years 1990
and 2000 may differ as it relates to the City of Cuyahoga Falls. For the purposes of this
report, the breakdown of census tracts will show the City of of Cuyahoga Falls to consist
of (9) census tracts in 1990 and ten (10) census tracts in 2000, Although comparisons
were made againstthe same numbered censustracts and /or boundaries wherever possible
in order to preserve the integrity of this report, boundaries of some census tracts do
overlap. Also, the data may indicate that a category either is nonexistent or falls below the
threshold in terms of measurement.
3.1 Location and Size of the Community
M
City of Cuyahoga Falls, Ohio 4
88 Rug
Analysis of Impediments to Fair Housing Choice
The City of Cuyahoga Falls is located in the northwest portion of Summit County. Summit
County is located inthe northeastern portion of the State of Ohio where it is bordered by
Cuyahoga County to the north, Geauga County to the northeast, Portage County to the
east, Stark County to the south, Wayne County to the southwest and Medina County to the
west. The City was founded in 1812 by William Whetmore, was originally named
Manchester and, at the request of the Postmaster General, changed to its present name
after the Cuyahoga River which runs both north and south through the City. The City, the
second largest in Summit County, was the County seat in 1841 before being moved to
Akron which lies to the south. The City is comprised of 25.6 square miles with the
Cuyahoga Valley National Park to the northwest.'
The community was originally incorporated as a
town in 1836. In 1853, the village council, seeing
that the village and Cuyahoga Township occupied
the same territory, disbanded the community until
1868 when the incorporated Village of Cuyahoga
Falls municipal government resumed, By 1920,
the population exceeded 5,000 and automatically
became the City of Cuyahoga Falls. The City is
governed by a Mayor /City Council Charter form of
government adopted in November 1959 by the
voters and became effective January 1, 1960.2
Cuyahoga Falls is accessible from Akron and
Cleveland by major interstates, including 1 -271, 1 -480, 1 -80 (Ohio Turnpike), 1 -76, 1 -77
and State Route 8.3
Between 1825 and 1832, the Ohio Canal ran north and south from Lake Erie to the Ohio
River in Portsmouth while the Pennsylvania and Ohio Canal ran east and west, Both canals
became the stepping stone for the industrialization of northern Ohio due to its convenient
access to the Great Lakes. Eventually the Pennsylvania and Ohio Canal was replaced by
the train which ran along the same route The strategic location on the Cuyahoga River,
which was a great power source for the upcoming mills of the time, also allowed Cuyahoga
Falls to become an important stop on the underground railroad as well.'
In addition, on January 1, 1986, Cuyahoga Falls and Northampton Township became the
' http: / /en wikipedia org
2 www. cityofcf. corn
3 www.mapquestcom
http: / /www grc nasa.gov/W W W /K -12 /fenlewis /H istory .html
PM
City of Cuyahoga Falls, Ohio 5
88 o AA Analysis of Impediments to Fair Housing Choice
first two communities in the history of the State of Ohio to successfully merge by voter
approval. The relatively rural character of the former township has added a balance to the
more developed core of the old city.'
3.2 Population
Table 2 shows the population of the City of Cuyahoga Falls for 2000. Also shown are
the estimated populations for 2003 and 2008. Population estimates show a very slight
increase from 2003 to 2008.
Table 2: Population of Cuvahoqa Falls, 2000 - 2003 - 2008
LOCATION 2000 2003 2008 2003-2008
Annual Rate
City of Cuyahoga Falls 49,374 49,540 150J011 1 0.19%
Source: 2003 ES- RI -B--IS- - Business Information Solutions
3.2 Minorities and Race
The 2000 distribution by race within the City of Cuyahoga Falls is shown in
Table 3.
The minority (Blacks, Asian, American Indian and Hispanic) composition of individual
census tracts by race for the years 1990 and 2000 in the City of Cuyahoga Falls is shown
in Table 4 Corresponding maps are provided for comparison purposes.
Although the White population continues to be the dominant race category within the City
of Cuyahoga Falls, the minority population represents approximately 3.8% of the total
population in 2000. Blacks are by far the largest minority population at 1.9 %. However,
it should be noted that when there is discussion regarding a percentage increase or
decrease in the minority population, a comparison should be made to the actual number
of the population in question rather than the percentage increase itself. For example,
although a population of Blacks that number 10 in 1990 and increases to 20 in 2000 is a
100% increase and sounds high, however, it is only a growth of 10 persons.
5 http:Hdmoz org /Regional/ North_ America/ United_ States / Ohio /Localities /C /Cuyahoga_Falls
Al
City of Cuyahoga Falls, Ohio 6
88 ° B8 Analysis of Impediments to Fair Housing Choice
Table 3: Distribution by Race within the City of Cuyahoga Falls, 2000
LOCATION WHITE BLACK AMER. ASIAN HISPANIC %
INDIAN MIN.*
City of 95,8% 19% 0.2% 1.1% L 0.6% 3.8 %
Cuyahoga
Fails
Source: 2003 ESRI BIS - Business Information Solutions % Minority does not include "other race"
category
Table 4: Minority* Population by Census Tract, City of Cuyahoga Falls, 1990 -2000
CENSUS TRACT
1990
2000
% CHANGE
POPULATION
POPULATION
5080
186
412
121.5%
520101
197
325
651%
5201.02
110
359
2264%
5202.01 **
104
42
(59.6 %)
5202 02 **
NA
105
NA
5203
95
116
22.1%
5204
58
98
68.9%
5205
50
69
38.0%
5206
49
40
(18.3 %)
5329
427
610
42.8%
Source: U.S Census Bureau,
1990 Table DPI (STF1),
2000 Table QT -P# (SF1)
by Census Tract "other
race" category not included. **
These two tracts were split for the 2000 census, therefore
the number for
5202 01 in 1990 represents both tracts. The -59 6% decline in minorities is unreliable
due to the tract split.
In the City of Cuyahoga Falls, census tract 5329 had the largest minority population in 2000
with 623 persons (See Map 2 for tract reference) and the tract experienced a 42.8%
increase in minority population between 1990 and 2000. In contrast, census tracts 5080
and 5201.02 had minority populations of 412 and 359 in 2000 yet the percentage of
increase was 122.5% and 252.7 %, respectively.
Only one of the City's census tracts experienced a decrease in minority population between
1990 and 2000. Tract 5206, which is in the Cuyahoga River District, experienced a
decrease of 18.3% or nine persons during the period. Also, census tract 5202.01 showed
a significant decrease in minority population, but this was due to the fact theat between
r
City of Cuyahoga Falls, Ohio 7
88 u 88 Analysis of Impediments to Fair Housing Choice
1990 and 2000 the tract split and the decrease has more to do with the split than with
actual loss of minorities.
As can be seen on the maps, although almost all of the tracts within the city are
experiencing an increase in minority population, tract 5201 .02, which includes the Bailey -
Monroe Falls area and the State Portage Trail area, shows the greatest increase in minority
population between 1990 and 2000. This is followed by tract 5080, which includes the
Northhampton area, where the percentage of the minority population has increased by
between 1990 and 2000.6 This can possibly be attributed to the growth in minority
population in the adjoining tracts during the 10 -year period.
However, growth in minority population has not necessarily moved the minority population
to new tracts, as can be seen by comparing maps from 1990 to 2000, With the exception
of tract 5206, those tracts that were minority in 1990 have only increased in the percent
minority. According to the City tract 5329 has had the highest rate of new construction in
the community, In 2000 this tract, also know as the Northhampton District, had 5.6% of the
housing stock occupied by Blacks
It is also important that policies for the City of Cuyahoga Falls encourage development of
housing that would be affordable and that Not in My Backyard (NIMBY) issues do not
interfere with housing choice. While often NIMBY shows itself in opposition to commercial
development, especially large, box type stores. However, NIMBY is also a major road
block to housing development, from affordable /low- income housing to housing for the
disabled. It is the consultants experience that this form of NIMBY is far more prevalent that
opposition to commercial development.
NIMBY is the response that often comes when a developer or a community announces that
they will build a affordable, low- moderate income (LMI) or group homes in a neighborhood
or suburb. Residents in the neighborhood rise up to protest the perceived notions that such
a housing development or program will drastically hurt their property values, overcrowd the
neighborhood, cause an increase in crime and other concerns. NIMBY is a fear that what
they have will be destroyed by something or someone they do not know. It is especially
prevalent in the development of group homes for the disabled or individuals' recovery from
various addictions. This attitude can drastically impact the ability of local government to
plan and produce housing for those who cannot afford to buy or rent market rate housing
as the demand for such housing increases. While many communities, like Cuyahoga Falls,
do not build housing , they can impact housing that is built. (Appendix 5 includes a
document regarding NIMBY)
According to the City of Cuyahoga Falls FY2O04 -2008 Consolidated Plan, "there is not a
'City of Cuyahoga Falls Consolidated Plan, 2004 -2008
Q
City of Cuyahoga Falls, Ohio 8
00 0 00 Analysis of Impediments to Fair Housing Choice
large Black or Hispanic population in Cuyahoga Falls. White households make up 97.5%
of all households. Blacks make up 1.84% of the households and Hispanics make up less
than 1 % of total households. "'
Table 6 shows the population by race (excluding Whites) by census tracts for the City of
Cuyahoga Falls Table 4 compares the total minority population for 1990 and 2000, Table
6 indicates 2000 racial population.
Table 6: Composition of Census Tracts by Race in the City of Cuyahoga Falls
(excluding Whites), 2000 _
CENSUS TRACT BLACK ASIAN AMER. INDIAN HISPANIC
#__. % _.. # % # % # j %
5080 275 6.9 82 2.0 5 0.1 50 1.2
5201.01
5201.02
5202.01
5202.02
5203
5204
5205
5206
142
143
8
61
58
33
33
II
2.1
2.1
0.3
0.2
0.8
0.7
_.........
0.7
11M
5329 427 53
Source: U 5 Census Bureau, 2000 QT -P3
category
122
1.8
0
0,.0
138
20
5
0,1
20
0.7
1
0.0
22
0.4
0
0.0
35
0.5
0
0.0
25
0.5
0
0.0
13
! 03
0
0.0
14
03 '',
0
0.0
143
1.8 '',
0
0.0
61 0.9
..........
73 1.1
13 0.4
22 0.4
23 0,3
40 0.8
23 0.5
19 ! 0.5
40 ! 0.5 j
include "other race"
Tracts 5080 and 5329 had the highest percent of Black population ranging from 6.9% to
5.3 %, followed by Asians in tracts 5080 and 5201.02 at 2.0% and 5201.01 and 5329 at
1.8% and Hispanics in tracts 5080 and 5201.02 at 1.2% and 1.1 %, respectively. The only
racial category not to exceed 1.0% in all census tracts is that of the American Indian which
is no higher than .5 %.
Tables 7 shows the projected racial population for 2003 and 2008 the City of Cuyahoga
Falls by all races (total does not include 'other race" category) compared with the
population in 2000 The table indicates a slight increase in minority population and a
City of Cuyahoga Falls Consolidated Plan, 2004 -2008, p IX:22
U
City of Cuyahoga Falls, Ohio 9
BB�BI3 Analysis of Impediments to Fair Housing Choice
decrease in White population.
Table 7: Population by Race within the City of Cuyahoga Falls, 2000, 2003, 2008
YEAR
WHITE
BLACK
AMER.
ASIAN
HISPANIC
INDIAN
2000
95,8%
_
19%
_
0.2%
1.1%
0.6%
2003
953%
2A%
0.2%
I 1.2%
07%
2008
94.6%
2.4%
0.2%
1.5 %o
0.8%
Source ESRI BIS - Business Information Solutions -
3.3 Gender
This section will compare the male and female populations of the City of Cuyahoga Falls.
This is important in our overall review for the Al. The differences in population between
genders can be a red flag for other problems that might exist. For instance, female head
of households are one of the fastest growing poverty groups in the nation. If a high number
of females were present in a jurisdiction this would lead to a further examination of that
population. Generally it is found that the male and female populations are evenly split with
only a few percentage points dividing them. This is true in the City of Cuyahoga Falls as
can be seen in Table 8.
Table 8: Population of the City of Cuyahoga Falls by Gender, 2000
LOCATION MALE % TOTAL. I FEMALE % TOTAL TOTAL i
City of 23,428 47.5% 25,946 52,5% 49,374
Cuyahoga Falls
Source: U S Census Bureau, 2000 Table DP1 (SF1) by Census Tract
Table 8 indicates that in the total population of the City of Cuyahoga Falls, females slightly
outnumber males, It is typical for females to outnumber males in the general population,
after the age of 18 and particularly after the age of 65 due to the longer average life -span
of women.
3.4 Family Status
�,
City of Cuyahoga Fails, Ohio 10
88 0 88 Analysis of Impediments to Fair Housing Choice
Family status within the City of Cuyahoga Falls is shown in Table 9.8 This table indicates
family households type. It shows that within the City of Cuyahoga Falls that 48.3% consist
of married couples without children under the age of eighteen (18) and that 38.5% of these
have children under the age of eighteen (18). It also indicates that there are 10.1 % Female
head of households and 5.7% are Female head of households with children under the age
of eighteen (18). 9
Table 9: Household Type within the City of Cuyahoga Falls, 2000
The importance of this data is threefold - 1, Female head of households with children are
the fastest growing poverty population; 2, the impact that this population can have on the
need for affordable housing and; 3, single head of households with children tend to face
a higher percentage of housing discrimination complaints.
According to the Interagency Council on the Homeless, approximately 20 -25% of the
homeless are families with children, Single parents, usually female, head most homeless
families.70
Also, data from the Center on Urban Poverty and Social Change indicates that between
1989 (1990 reported) and 1999 (2000 reported) there has been a 12.3% decrease in
poverty among families with a female -head, no husband present and related children.
However, Harvard Professor Richard B. Freeman contends that "the impact of the recent
upswing in unemployment is cause for concern," He states that "the loss of full
employment —a return of unemployment to the mid- 1990's national rate of 6 %..,will increase
poverty substantively. Despite the welcome gains made by female- headed families with
° The table does not include information for non - family households which include persons who
live alone; don't live alone [but not married]; non - relatives that live together and persons that
live in institutions or other group quarters
'US Census Bureau, 2000 (SF1) Table P19 by Census Tract
0 City of Cuyahoga Falls Consolidated Plan, 2004 -2008, p IX:34
House-
Family
Non-
Married
Married
Female
Female
holds
House-
Family
Couple
With
Headed
With
holds
House-
Family
I CH <18
House -
!, CH <18
hold
hold
City of
Cuyahoga
y
21,655.
13,307
8,348
10,467
4,271
I 2,187
1,243
Falls
I
% of Total
100%
61.5%
38.5%
483%
i 197%
I 10 1%
57%
Households
Source: U.S Census
Bureau,
2000 Table
DP -1 Profile
of General Demographic
Characteristics(SF2'
The importance of this data is threefold - 1, Female head of households with children are
the fastest growing poverty population; 2, the impact that this population can have on the
need for affordable housing and; 3, single head of households with children tend to face
a higher percentage of housing discrimination complaints.
According to the Interagency Council on the Homeless, approximately 20 -25% of the
homeless are families with children, Single parents, usually female, head most homeless
families.70
Also, data from the Center on Urban Poverty and Social Change indicates that between
1989 (1990 reported) and 1999 (2000 reported) there has been a 12.3% decrease in
poverty among families with a female -head, no husband present and related children.
However, Harvard Professor Richard B. Freeman contends that "the impact of the recent
upswing in unemployment is cause for concern," He states that "the loss of full
employment —a return of unemployment to the mid- 1990's national rate of 6 %..,will increase
poverty substantively. Despite the welcome gains made by female- headed families with
° The table does not include information for non - family households which include persons who
live alone; don't live alone [but not married]; non - relatives that live together and persons that
live in institutions or other group quarters
'US Census Bureau, 2000 (SF1) Table P19 by Census Tract
0 City of Cuyahoga Falls Consolidated Plan, 2004 -2008, p IX:34
32
City of Cuyahoga Falls, Ohio t 1
AA o A8 Analysis of Impediments to Fair Housing Choice
children, there are still many of them living in poverty, and many whose new lives off
welfare and out of poverty might be short-lived if an economic downturn takes away their
jobs. ""
3.5 Disability Status
Tables 10 shows the disability status of the population within the City of I See Map 4
Cuyahoga Falls. These populations represents 15.7 % of the total population
of the City of Cuyahoga Falls. This information is important to this report as
it can become an issue for the City in the future due to the changes in federal and state
funding, budget cuts and other pressures being placed on the provision of services to
disabled persons,
Table 10: Disability Status by Age, City of Cuyahoga Falls, 2000
5 -20
21 -64 '',
65 AND
TOTAL
% OF TOTAL
OLDER
POPULATION*
With A Disability 707
4,072
2,987
I 7766
15.7%
Total Population 9,294
28,671
7,785
1 45,750
92.7%
of Total Age Group 7 6%
14.2 %0
3814%
1 16.900
Population
Source: U S Census Bureau, 2000 Table DPI,
QTP12 (SF1) by Census
Tract *Percent
of total civilian
population within the City of Cuyahoga Falls.
As individuals with disabilities age, there is a greater need for housing. As clients age, so
do their care givers, causing a decrease in their ability to provide support and assistance;
therefore, the need for housing alternatives rises. The people most in need are elderly
parents of disabled adult children between the ages of 25 and 60 years of age or alder who
still live at home, Other groups include: families with a single head of household, adults
and children who are non - ambulatory or multi - handicapped (with or without families) and
adults who are dually - diagnosed. Support services would include: flexible respite services
for elderly parents caring for their children at home, transportation for all segments of the
population and day care for children and adults while parents or care providers work.
In terms of fair housing, the lack of adequate safe and sanitary housing for persons with
disabilities is always a concern. While fair housing laws have strong language /coverage for
persons with disabilities and there is strong enforcement, many housing providers are at
best unaware or at worstjust don't care. It is imperative that single and multi - family housing
units be built in the City of Cuyahoga Falls that are accessible and that education and
112002 Center on Urban Poverty and Social Change Mandel School of Applied Social Sciences,
Case Western Reserve University; http: / /povertycenter cwru edu
a$
City of Cuyahoga Fails, Ohio 12
AA n 89 Analysis of Impediments to Fair Housing Choice
enforcement be done. Under the new zoning code the City is encouraging accessbible
housing. A pilot project, "Fresh Start ", will create a template to renovate existing housing
to meet ADA requirements. Also, the City is establishing a Community Reinvestment Area
to encourage new residential single and multi - family housing in the oldest planning area.
These programs combined with a local fair housing enforcement to record complaints from
disabled home seekers who are or have experienced discrimination in their search for
housing or from current landlords the ability to assure safe and sanitary housing grows
closer. Whether there is one complaint or one hundred, the problem is there.
Another symptom of the problem is the NIMBY response that new group homes, housing
for the disabled, etc. encounter when they try to build or convert housing for the disabled
This is especially true in suburban neighborhoods.
The Consolidated Plan states that "although the numbers of homeless individuals from
Cuyahoga Falls utilizing shelters could not be obtained, it is assumed the number is
minimal ,'"Z Although this may be the case, it should be noted that "within Summit County
there are a number of emergency shelters and transitional housing programs available for
the homeless in Cuyahoga Falls." However, locally, "there are no emergency shelters within
the Cuyahoga Falls' city limits" and "throughout Cuyahoga Falls, area churches and other
agencies provide a variety of emergency services to the homeless and those at risk of
being homeless. "t3 " In addition, "Cuyahoga Falls has one (1) transitional housing facility
with sixteen (16) units within the City's limits. "14 however, to the City's credit it is a
participant in the COC and has asked for HMIS information quarterly to track and evaluate
Homeless in the community.
It is imperative that the City of Cuyahoga Falls track the numbers of homeless due to the
fact that as funds from the State and Federal Government dwindle, non - profit housing
agencies, providers of housing services, public housing authorities and local jurisdictions
will increasingly feel the pressure of increasing needs and decreasing resources. This will
result in the reliance on creative funding, alternative financing and other innovations in
order to rehab or build new units and to maintain rental assistance for those in need.
3.6 Income Characteristics of Protected Classes
Tables 11 reflects the 2000 (In 1999 dollars) Median Household Income See Map 5
(MHI) for the census tracts for the City of Cuyahoga Falls by Race. The City
had 21,655 households in 2000. The MHI for the City of Cuyahoga Falls in
iZ City of Cuyahoga Falls Consolidated Plan, 2004 -2008, p. IX:34
" Ibid, p. IX:25
14 Ibid, p. IX:27
City of Cuyahoga Falls, Ohio 13
BB o AA Analysis of Impediments to Fair Housing Choice
2000 was reported to be $42,26315 which is a 36.7% increase from the $30,895 reported
in 1990.16 This is slightly lower than Summit County ($42,304), but higher than the State
of Ohio ($40,956) and the United States ($41,994). MHI is important because it can give
indications of the ability of members of certain races to purchase homes, to pay rent and
to prosper in the community.
Table 11: Median Household Income within the City of Cuyahoga Falls by Race, 2000
GEOGRAPHY
WHITE
BLACK
AMER.
ASIAN
HISPANIC
INDIAN
Cuyahoga
$42,694
$28,438
$65,625
$55,625
$22,143
Falls
__.
Summit
$45,349
$25,865
$37,794
$55,188
$39,591
County
State of Ohio
$42,835
$26,619
$30,982
$49,266
$33,133
United States
$44,687
$29,423
$30,599
1 $51,908
$33,678
Source: U.S.. Census
Bureau 2000 Summary
File 3 (SF
3)
However the MHI for Blacks in the City ($28,438) was higher than that of the County and
the State of Ohio, and less than a thousand dollars lower than the United States. American
Indians had the highest MHI in the City, over $65,000. This is somewhat insignificant when
you consider that the Cit only has a American Indian /Native American population of 99
persons. The Asian MHI is consistently higher for all geography's and for all races.
Hispanics MHI is the lowest in the City and in the comparison geography's,
3.7 Poverty and Minorities
The incidence of poverty by race within the City of Cuyahoga Falls is shown See Map 6
in Table 12. (Poverty is defined as households below 50% MHI) The percent
of the population living below poverty in the City of Cuyahoga Falls is 6.1 %.
Based on race American Indians /Native Americans have the highest poverty rate, 293%.
Whites by far had the lowest rate at 5 %. Blacks were over five times the poverty rate of
Whites, 267%. Of minorities asians had the lowest rate at 10.4% twice that of Whites.
Hispanics had a poverty rate of 11.9% slightly more than twice that of Whites.
Table 12: City of Cuyahoga Falls: Poverty Status by Race, 2000
15 U.S. Census Bureau, 2000 Table P53 (SF3) by Place
11 U.S. Census Bureau, 1990 Table P080A (SF3) by Place
95
City of Cuyahoga Falls, Ohio
14
B8 ° BB Analysis of impediments
to Fair Housing
Choice
WHITE
BLACK
AM.
ASIAN
HISPANIC
CITY
INDIAN
# At/Above
46,756
748
94
413
312
45,937
Poverty
# Below Poverty
2481
273
39
48
i 42
2,991
Total #
49,237
.1021
133
.461
354
48,928
% Below Poverty
5.0%
26.7%
29.3%
10.4%
11.9%
6.1%
by Race
Source: U.S. Census Bureau,
2000 Tables
P159A,B,C,D,H (SF3)
by Census
Tract *Total does not include
.'other race" category
3.8 Poverty and Gender
The incidence of poverty by Gender within the City of Cuyahoga Falls is shown in Table 13.
This table indicates that poverty affects females in the City of Cuyahoga Falls 3.0% more
than males. The fact that there is a higher incidence of poverty among females over males
statistically follows the national trend, In addition, within the City of Cuyahoga Falls, the
poverty rate for both males and females is approximately 6.0 %, where poverty status has
been determined.
Table 13: City of Cuyahoga Fails
11T1 V M
At/Above Poverty , 24,359
Below Poverty 1,144
Status by Gender*
FEMALES
25,869
2,101
Total 25,503 27,970
% Below Poverty 4.5 7.5
by Gender*
Source: U S Census Bureau, 2000 Table PCT49 (SF3) by Census Tract *Total
poverty status has been determined.
TOTAL*
50,228
3,245
53,473
6.0
alp
City of Cuyahoga Falls, Ohio 15
AA o BA Analysis of Impediments to Fair Housing Choice
3.9 Poverty Status by Family Type and Presence of Children
Tables 14 demonstrates the effects of poverty status on family type and
presence of children. Female head of households with children are by
far the largest poverty population in the City of Cuyahoga Falls,
Ile 14: Poverty Status by Family Type & Presence of Children, 2000_
FAMILY
AT /ABOVE
BELOW
TOTAL
POVERTY
POVERTY
Married, CH <18
4,701 (33.9 %)
85 (116 %)
4,786 (33.0%)
Married, No CH < 18
6,736 (48.6 %)
94(15.1%)
6,830 (47.2 %)
Male HH, CH < 18
353(2.5%)
9(1.4%)
362(2.5%)
Male HH, No CH< 18
269(1.9%)
10(1.6%)
279 (1.9 %)
Female HH, CH < 18 _.
1000(7.2%)
418(67.1%)
1,418 (9.8 %)
Female HH, No CH < 18
800(5.8%)
7(1.1%)
807(5,6%)
13,859 (99.9 %)
623 (99.9 %)
14,482 (100.0 %)
Source: U S. Census Bureau P90 (SF3) by Census Tract "Total
of population for whom poverty status has
been determined,
In the City of Cuyahoga Falls, 13.6% of married couples with children under the age of 18
live below poverty. Male head of households with children under the age of 18 have 1.1 %
living below poverty. More than 67% (67.1%) of female head of households with children
under the age of 18 live below poverty. For all households at or below poverty, 512
(82,2 %) have children under the age of 18.
3.10 Persons Receiving Supplemental Security Income (SSI) and Public
Assistance
Table 15 compares the percent of households earning social security, supplemental
security income and public assistance between the City, Summit County, State of Ohio and
the United States. This is 2000 data and many changes have been made in coverage for
SSI and public assistance, the numbers for 2005 may be lower due to these changes. "
The City had more households on social security (28.9 %) than the other comparison
geographies. However it was lower in the percent of households earning SSI (2.4 %) and
public assistance (2.2 %).
17 U. S. Census Bureau, 2000 Table P62 (SF3) by Census Tract
City of Cuyahoga Falls, Ohio 16
AA ° BB Analysis of Impediments to Fair Housing Choice
Table 15 - Percent of Households Earning Social Security, Supplemental Security
icome and Public Assistance - 2000
.._..._._.. .
GEOGRAPHY li
Social
Supplemental
Public
Security
Security Inc
Assistance
Cuyahoga
28.9%
2.4%
22%
Falls
Summit
267%
4.0%
3.7%
County
State of Ohio
°
26,4%
4.2%
3.2%
United States
25.7%
4.3%
3.4%
4.0 ECONOMICS AND TRANSPORTATION
This section will review various issues regarding the economic health of the area and the
transportation support for residents in the City of Cuyahoga Falls. There are a wide variety
of topics discussed from unemployment rates, to largest employers,
to income by job classification. The purpose of this section is to try
and get a sense of the economic structure in the City and how that
might apply to purchasing power of residents and affordability of
housing. If a community has a high unemployment rate it will mean
the possibility of foreclosures could go up, the ability to repair homes
is diminished, and the ability to afford and buy homes. If current
housing prices are high and not attainable by a majority of workers
in the City then this drives residents out of the City and reduces the
ability of the local jurisdiction to expand its tax base. However, the
housing market in Cuyahoga Falls remains strong and their has been little indication that
residents are moving out of the City.
4.1 Employment Status Profile
For the purpose of this report, the labor force includes all people classified in the civilian
labor force plus members of the U.S. Armed Forces (people on active duty with the United
States Army, Air Force, Navy, Marine Corps, or Coast Guard), The civilian labor force
consists of people classified as employed or unemployed(but actively seeking
employment). When considering the labor force of the City of Cuyahoga Falls (persons
over 16 years age and including the military), data from the U. S. Census Bureau and
American FactFinder -Ohio 2000, indicates the City has 63.5% of their population in the
City of Cuyahoga Falls, Ohio 17
88 a 88 Analysis of Impediments to Fair Housing Choice
labor force .27 Table 16 shows the total civilian labor force in the City for the reporting year
of 2000. The City rate of 63.5% is slightly lower than the State of Ohio(64,8 %),28 and the
rate for the United States (63.9 %).29
It should also be noted that the data indicates that the difference in the number and
percentage of the civilian labor force of persons over 16 years of age and excluding the
military is either nonexistent or falls below the threshold in terms of measurement.
Table 16: Total Civilian Labor Force Participation Rates and Number, 2000
ECONOMIC CHARACTERISTICS
Total Civilian Labor Force
CITY of CUYAHOGA FALLS
63.5% 34,299
Source: U.S. Census Bureau, 2000 Table P43 (SF3) Employment Status by Sex by Census Tract
The City of Cuyahoga Falls Local Area Unemployment Statistics (LAUS) for the last five
(5) years are shown in Table 17.
The most recent 2004 unemployment rate in the City of Cuyahoga was higher than the
annual average of 3.42% for the previous five years. The annual average unemployment
rate in the City during the last five years was as low as 2.8% in 2000. During the four (4)
years since the 2000 rate of 2.8 %, the unemployment rate has increased .3% in 2001,
increased 1,0% in 2002, neither increased or decreased in 2003 but has decreased .1 %
in 2004. Looking at the civilian labor force numbers, we see a different picture: 2001
showed an increase of .03 %, 2002 showed a increase of .04 %, 2003 an increase of 0.04%
and 2004 an increase of .04 %. Statewide, for 2004, the annual average unemployment
rate was 6.1 % while the U.S. unemployment rate for the same period was 5.5 %.30
27 U.S. Census Bureau, 2000, Table P43 (SF3) Employment Status by Sex by Census Tract
26 U.S. Census Bureau, 2000, Table P43 (SF3) Employment Status by Sex by State
29 U.S. Census Bureau, 2000, Table P43 (SF3) Employment Status by Sex by Nation
30 www bls,gov
W
City of Cuyahoga Falls, Ohio
8A Analysis of Impediments to Fair Housing Choice,
Table 17: City of Cuyahoga Falls -Local Area Unemployment Statistics (LAUS) 1999 -
2004
YEAR TOTAL CIVILIAN EMPLOYED UNEMPLOYED UNEMPLOYMENT
LABOR FORCE
RATE
2004 29,310 28,129 1,181 4.0
2003 29,024 27,827 1,197 41
27,582 1,173 4,1
2002 28,755
2001 28,691 27,798 893 3.1
2000 28,676 27,869 807 2.8
Source: U S Department of Labor, Bureau of Labor Statistics - Local Area Unemployment Statistics
Table 18 indicates the employment and unemployment data of the Labor Force. It shows
a lower unemployment rate, labor force rate, civilian labor force rate and employment rate
than the State of Ohio and the U.S.
Table 18: EmpIc
SUBJECT
In Labor Force
and Unemployment Data of
CITY of
CUYAHOGA FALLS
63,5%
Civilian Labor
Force
Employed
Unemployed
Source: U S Census Bureau, 2000 T
and Nation
54.2%
-abor Force Workers
OHIO NATION
64.8% 63.9%
647% 634%
52.5% 61.5% 597%
1.7% 3,2% 3.7%
QT-P24 (SF3) Employment Status by Sex by Census Tract, State
"a
City of Cuyahoga Falls, Ohio 19
Analysis of Impediments to Fair Housing Choice
4.2 Occupation Profile
When looking at Occupation, the City of Cuyahoga Falls shows high rates in two areas -
Management, Professional and Related Occupations and Sales and Office.
Table 19: Occupation of Employed Civilian POPL
SUBJECT
Management, Professional and Related Occup
Service
Sales and Office
Farming, Fishing and Forestry
Construction, Extraction and Maintenance
Production, Transportation and Material Moving
------ -- - -
Source: U S. Census Bureau, 2000 Table QT-P28 (SF3)
)n 16 and Over, 2000
City of Cuyahoga Falls
35.2%
13.3%
30,8%
7.3%
13.3%
In addition, females outnumber men in the employed civilian workforce 16 and over in the
two (2) occupation areas of Service and Sales and Office. Table 20 reflects the distribution
of the occupations in Table 20 by gender and by percent of the civilian workforce 16 and
over.
Table 20: Distribution of Occupations by Gender, 2000
SUBJECT
MALES
FEMALES
Management, Professional and
5,061
4,921
Related Occupations
17,9%
174%
Service
1,658
2,072
6.0%
7.3%
Sales and Office
3,131
5,602
11.0%
19.8%
Farming, Fishing and Forestry
23
0
.1%
0,0%
Construction, Extraction and
2,054
19
1 Maintenance
7,2%
.1%
Production, Transportation and
2,801
962
Material Moving
9.9%
3,4%
Source: U.S Census Bureau, 2000 Table QT-P27 (SF3)
At
City of Cuyahoga Falls, Ohio 20
BB o 88 Analysis of Impediments to Fair Housing Choice
4.3 Industry Profile
Industrial retention and expansion appears to be a top priority for the City of Cuyahoga
Falls, The City has been providing infrastructure and tax incentive programs which have
led to the creation of industry, particularly in the northeast quadrant of the city. Since the
creation of an Enterprise Zone and Community Reinvestment Area just five years ago, the
City of Cuyahoga Falls has realized new and transferred investment from new industrial
construction. The construction of four new industrial parks in the last three years has
resulted in nine manufacturing facilities locating here,
Table 21 shows the percentage of employees for each major industry group during 2000.
The largest percentage of employees are found in Education, Health and Social Services,
Manufacturing, Retail Trade and Arts, Entertainment, Recreation, Accommodation and
Food Services. Professional, Scientific, Management, Administrative and Waste
Management Services and Finance, Insurance and Real Estate.
Table 21: Industry Employee Percentage, 2000
SUBJECT
City of Cuyahoga Falls
Agriculture
0.1%**
Construction
6.0%
Manufacturing
16.9%
Wholesale Trade
44%
Retail Trade
13.7%
Transportation and Warehousing and
4.5%
! Utilities
Information
34%
Finance, Insurance and Real Estate
7.0%
Professional, Scientific, Management,
8.0%
Administrative and Waste Management
Services
Educational, Health and Social Services
18.5 %*
Arts, Entertainment, Recreation,
86%
Accommodation and Food Services
Other Services (Except Public
5.1%
Administration)
Public Administration
3.8%
Source: U S Census Bureau, 2000 Table DP -3 (SF3) Highest Lowest
As can be seen by Table 22, the Cuyahoga Falls area is home to numerous commercial,
&IN
OrA
` ..... City of Cuyahoga Falls, Ohio 21
AA o Q " a Analysis of Impediments to Fair Housing Choice
industrial and service oriented businesses as well as the 6,000 acre Cuyahoga Valley
National Recreation Area."
Table 22: Major Employers in the Cuyahoga Falls Area
EMPLOYER
EMPLOYEES
Line of Business
(as of May 2002)
(Full Time)
Cuyahoga Falls General Hospital
665
Hospital
Cuyahoga Falls School District
654
Education
GoJo Industries
534
Skin Care Products
City of Cuyahoga Falls
511
Government
SGS Tool Co.
333
Tool Manufacturer
Alsides, Inc.
300
Building Products Manufacturer
Arnerichem
289
Plastic Color Concentrates
Tamarkin Co. (Giant Eagle)
271
Retail/Groceries
Woodridge School District
257
Education
State of Ohio
243
Government
Pechiney Plastic Packaging
236
Flexible Packaging
Sheraton Suites
200
Lodging/Restaurant/Conference
Center
Ebsco Teleservices Inc
180
Telemarketing Service
Donaldson Co, Inc.
155
Filters & Filtration Systems
Ameritech
125
Communications Utility
Accuride
100
Aluminum Wheel Manufacturer
Schwebel Baking Co.
100
Baked Goods
Prospect Akromold, Inc
100
Steel Molds for Plastic Products
Julius Zorn Inc,
100
Manufacturer of Medical Supplies
Source: wwvv c1tyofcfcom
The table shows the twenty (20) employers which employ the most workers in the City of
43
City of Cuyahoga Fails, Ohio 22
AA o 99 Analysis of Impediments to Fair Housing Choice
Cuyahoga Falls area. Table 21 also lists their number of employees and their product or
service.
4.4 Income and Wages Profile
Communities across the country are recognizing the importance of affordable housing to
their future economic and social well - being. Economic growth is at risk when growth in jobs
and population are not matched by the growth in the supply of affordable housing. For
businesses, the ability to attract and retain labor depends partly on the availability of decent
and affordable housing.
Among the social concerns are basic issues of equity for low- moderate income working
families. In many communities, people who provide the bulk of vital services - teachers,
firefighters, police officers and laundry and restaurant workers - often themselves cannot
afford to live there. Yet, it is often in these communities where affordable housing for
working families is most needed and that the most opposition to such housing exists.
Moreover, a host of social problems can occur when working families face a shortage of
affordable housing. Family disruption, overcrowding and congestion degrade the quality
of life in the communities for all residents.
The Bureau of Labor Statistics publishes Metropolitan Area Occupational Employment and
Wage Estimates for metropolitan areas in the United States. Table 22 shows the
employment and wage estimates for 2003 for the Akron MSA which includes the City
Cuyahoga Falls. Specific data for the City is not available.
m
City of Cuyahoga Falls, Ohio
23
88 n 88 Analysis of Impediments to Fair Housing Choice
Table 22 - Metro Metropolitan Area Occupational and Wage Estimates -Akron MSA 2003
p p g
Occupation
Employment
Mean Hourly
Mean Annual
All Occupations
317,540
$16.83
$35,000
Management Occupations
14,330
$3147
$86,050
Business and Financial Operations
12,090
$2481
$51,610
Computer and Mathematical Science
6,510
$28.42
11
$59,110
Architecture and Engineering
5,850
$28.00
$58,150
Life, Physical, and Social Science
2,130
$2609
$54,260
Community and Social Services
y
3,520 �
$1869
$18,800
Legal
1,350
$4009
$83,400
Education, Training, and Library
16,640
$20.76
$43,180
Arts, Design, Entertainment, Sports, & Media
3,430
$16.83
$35,000
Healthcare Practitioner and Technical
15,860
$27.53
$57,250
Healthcare Support
8,530
$10,63
$22,100
Protective Service
6,450
$17.14
$35,640
Food Preparation and Serving Related
29,770
$7.94
$16,520
Building and Grounds Cleaning & Maintenance
10,080
$10,17
$21,160
Personal Care and Service
8,000
$838
$19,390
Sales and Related
31,110
$14.33
$29,840
Office and Administrative Support
55,450
$13.19
1 $27,450
Farming, Fishing, and Forestry
na
$1141
$23,740
Construction and Extraction
12,260
$18.13
$37,710
Installation, Maintenance, and Repair
11,510
$16.98
1 $35,310
Production
34,770
$14.48
$30,110
Transportation and Material Moving
24,680 1
$13.04
$27,130
The largest occupations (highlighted) are also some of the lowest paying occupations in
the area, Office and Administrative Support occupations was the largest occupation
section with over 55,000 employed. Mean income for this group is just over $13.00 an
hour. Individuals working in Production occupations were the second highest occupation
with over 34,500 workers making an average of $14.00 per hour.
45
City of Cuyahoga Falls, Ohio 24
AA ° 88 Analysis of Impediments to Fair Housing Choice
Table 23 shows the percentage of persons using six (6) methods to commute to work in
the geographic area The most commonly used method was car, truck or van -drove alone
(95.1%), followed by car, truck or van - car- pooled (6.9 %), those that worked at home
(2.2 %), public transportation- including taxicab (1,4 %), those that walked (1,0 %) and other
means (.3 %). The reported mean travel time to work (minutes) was 22.4 .32
Table 23: Commuting To Work, 2000
SUBJECT
State
Summit
City of
of
County
Cuyahoga
Ohio
Falls
Car, truck, or van - drove alone
82.7%
85.8%
95.1%
Car, truck, or van - car - pooled
9.3%
7.9%
6.9%
Public transportation - including cab
2.0%
1.6%
1.0%
Walked
2.3%
1.5%
1.4%
Other means
0.5% ',,
0.5%
0.3%
Worked at home
2.8%
2,5%
22%
Mean travel time to work (minutes)
22,9 "
22.4
224
Source: U S Census Bureau, 2000 Table QT -P23 (SF3) by Place
5.0 -ADVERTISING IN THE CITY OF CUYAHOGA FALLS
In simple terms, discriminatory real estate advertising is prohibited by the Fair Housing
Amendments Act (FHAA) of 1988. This means the law applies to classified advertising,
display advertising, inserts or any other types of real estate advertising that a newspaper
or magazine may publish. It also applies to any type of advertising or written material that
a real estate business may distribute or use, whether it is brochures, direct mailings, radio
or television advertising, multiple listing services (MLS), posters, billboards, application
forms or other documents, signs or videos.
In Section 804, the FHAA specifically states that it shall be unlawful to make, print, or
publish, or cause to be made, printed or published any notice, statement, or advertisement,
with respect to the sale or rental of a dwelling that indicates any preference, limitation, or
discrimination based on race, color, religion, sex, disability, familial status, or national
origin, or an intention to make any such preference, limitation, or discrimination.
11 U.S. Census Bureau, 2000 Table QT -P23 (SF3) by Place
City of Cuyahoga Falls, Ohio 25
Analysis of Impediments to Fair Housing Choice
Because housing is an integral part to the successful community care for many people with
mental disabilities, discrimination has been 8 major barrie[8f8CcRSStU8d8qU8tehOU6iPg,
ID8D effort tO eliminate such discrimination and tU support the right Uf people with a
disability to live in the community of their choice, Congress included in the FHAA
prohibitions against discrimination Of persons with aU1eDt8l disability iD the provision 0f
housing, ID addition, it also prohibited discrimination 0f families with children, The
provisions of the act also establish stronger administrative enforcement mechanisms and
provide for stiffer penalties tU expand coverage t8 include these specific classes iOaddition
to those protected classes initially covered.
In addition, there are special rules applicable t8 senior complexes and the advertising for
such senior complexes. The FHAA provides that housing for older persons includes three
categories of housing: (1) housing provided under a state or federal program that HUD
determines iS "specifically designed and operated t0 assist elderly pe[S0nS'';/2\housing
intended for and only occupied by persons who are 62V/ older; and (3) housing "intended
and operated for occupancy byat least one person 55 years 0f age Vr older per unit.''which
means that the housing must have 8t least 80 percent Vf its units occupied hy8t least one
person 55 years Uf age V[ older, must have facilities and services designed f0 meet the
needs of older persons and must adhere to the policies and procedures that demonstrate
3D intent fU provide housing for persons 550[ older. The FHA\ also provided for certain
"tr8OSiti0U`/ rules for existing complexes
Although the FH/\/\ does not address the issue 0f advertising for senior complexes, the
HUD regulations make clear that there iS8parallel exemption from the discriminatory
advertising provisions. Therefore, advertising for qualified "housing for older persons" under
the FHAA may make reference tO the age O[the desired residents.
/\dV8diSiDg guidelines have been the subject 0f great debate since they were enacted iD
1988. |8 order tU clarify the confusion over terms and phrases that were considered
violation 0f the regulations, the Housing and Urban Development (H\][)) agency issued
further guidelines that provide a more reasonable review method in orderto determine what
constitutes discriminatory advertising,
Originally, terms such aS "excellent Vi80/"."0/8lk`iUCl0S8f'."bGChelO[''V[''h8ChelO[ette"and
names such @S "The Baptist Home" could have been viewed 8S discriminatory. Currently,
when these are placed in their proper context, they are not "red-flagged" as discriminatory,
Besides words indicative nf race, color, religion, sex, disability, familial status, Ornational
origin, colloquialisms, or words or phrases used regionally or locally, which might imply or
suggest race, color, religion, sex, disability, familial status 0[ national origin should U8
avoided as well. ID addition, catch words and phrases such 3S «D8St[i[t8d". "8XClUSiY8",
"p[iV@tG*''iDt9grated'''''tK]diti8D8|". "board approval" U[ "membership approval" and symbols
Or logotypes which imply O[ suggest race, color, religion, sex, disability, familial status 8[
national origin should also b88V0id8Ur
M
City of Cuyahoga Falls, Ohio 26
88 a 88 Analysis of Impediments to Fair Housing Choice
It should also be noted that the liability does not exist only with publishers of any print
media or broadcasters of radio and television advertising for the sale or rental transaction
of a residential dwelling. It also includes persons or companies who conduct the sale or
rental transaction of a residential dwelling such as advertising agencies, sales firms, real
estate professionals and management companies. In addition, their clients can be held
liable as well Jury cases involving discriminatory real estate advertising in the Washington,
D.C. - Baltimore, Maryland area have resulted in jury awards of $850,000 and $2 million.
In addition, a successful plaintiff in a discriminatory advertising suit is generally entitled to
have the court order the defendant to pay the plaintiffs attorneys' fees, which can be
significant. It should also be noted that where the defendant has acted in reckless disregard
of the plaintiffs civil rights, punitive damage awards are also available under federal law,
(Smith v. Wade, 461 U.S. 30, 37 - in 1983)
Caution should be noted when describing either a geographical area or giving directions
as they can imply a discriminatory preference, limitation, or exclusion. These can include
the names of facilities which cater to a particular racial, national origin or religious group,
such as country club or private school designations. In addition, the names of facilities
which are used exclusively by one sex may indicate a preference.
All forms of print media should indicate that all housing advertised in their classified
sections abide by the FHAA. The HUD regulations contain a special provision applicable
to publishers, They provide that all publishers should publish at the beginning of their real
estate advertising section a notice including language to the following effect:
All real estate advertised herein is subject to the Federal Fair Housing Act, which makes
it illegal to advertise "any preference, limitation, or discrimination because of race, color,
religion, sex, disability, familial status, or national origin, or intention to make any such
preference, limitation, or discrimination." We will not knowingly accept any advertising for
real estate which is in violation of the law. All persons are hereby informed that all dwellings
advertised are available on an equal opportunity basis,
In addition, telephone numbers for local fair housing organizations or agencies which home
seekers may call for information if they feel that they have been the victim of housing
discrimination should be included in the publisher's notice.
In conjunction to the above disclaimer, all advertising for housing, including lending, should
include the "Equal Housing Opportunity" slogan or logo according to HUD regulations, The
logo is to be placed in all advertising that is larger than two (2) column inches and it should
be legible.
Finally, the use of human models in real estate related advertising are regulated by HUD.
Frequently, display advertising will include photos or drawings. Often, such advertising will
depict persons enjoying the amenities of the complex or the neighborhood to make the
6%
City of Cuyahoga Falls, Ohio 27
B8 0 9g Analysis of Impediments to Fair Housing Choice
housing seem appealing to potential home seekers. It is only common sense that a
message may be sent by the race, sex, age or family status of the persons in the
advertisements.
It is defined that "models should be clearly definable as reasonably representing majority
and minority groups... ". If models are used in photographs, drawings or other graphic
techniques, they should "indicate to the general public that the housing is.... (available)_.
to all without regard to race, color, religion, disability, familial status or national origin and
is not for the exclusive use of one such group." However, one of the changes that has been
seen since the fair housing advertising guidelines went into effect has been the decreasing
number of these types of ads by REALTORS®, landlords, management companies and
rental complexes.
5.1 Local Review of Advertising
As part of this analysis, the Consultant reviewed the real estate and apartment print
advertising placed in the Sunday real estate sections of The Akron Beacon Journal and
various home and apartment guides that are distributed around the City. Every effort was
made to only review those ads that directly related to the City of Cuyahoga Falls.
The Fair Housing Advertising Manual was used as a guide .33 This manual is one of the
various multimedia educational materials produced by the Fair Housing Council of Greater
Washington.
It should be noted that time constraints permitted only a limited review of local print
advertising. The review found no types of discriminatory advertising and there was no
advertising that was problematic in its phrasing or that would require notification.
In display ads it was noted that a number of real estate companies affiliated with nationally
recognized real estate firms did not show the Equal Housing Opportunity ( "EHO ") logotype
or the recommended HUD wording in their advertising. While this might be considered a
minor issue it can have an impact on housing choices. Home seekers who do not see the
equal housing logo or wording might wonder if they will be treated fairly in their housing
search. With the amount of education that real estate professionals go through they should
know better
There were "no- pets" ads found and while it is well within the rights of a landlord /owner to
bar pets from their units, it does raise the concern of companion /service animals used by
disabled individuals. The question becomes, "Will the no -pet policy include
33 Fair Housing Advertising Manual - Miller, Cassidy, Laroca & Lewin, 1996 - Guide to
Compliance with Real Estate Advertising Discrimination Laws for Washington D C. Area
Publishers and Advertisers
M.,
City of Cuyahoga Falls, Ohio 28
A8 o N88 Analysis of Impediments to Fair Housing Choice
companion /service animals or will an accommodation be made?" If a person who has a
companion /service animal is looking for an apartment, they will generally bypass "no -pet'
ads rather than hassle trying to work out the accommodation. The ideal situation would
be for those with this restriction to include in their advertising
" except companion animals."
Although there were a few "No Section 8" or "No HUD" advertising observed, it should be
noted that there is a concern when this statement is be found in rental advertising. Even
though the source of income and rental assistance are not protected under state or federal
fair housing law, those who receive assistance can include minorities, women with children
and other protected classes. As a matter of fact the majority of users of rental assistance
programs are female headed households. Therefore, this type of an ad would be a "red
flag to discriminatory practices In addition, although there were only a few ads that
discouraged Section 8 vouchers, there was no advertising found that welcomed it.
A list of questionable words, phrases and symbols that inadvertently appear in advertising
has been included in Appendix 2, Although this list may seem extensive at first glance, a
publisher who is sensitive to the requirements of the law will quickly develop a sense of the
type of advertisements which may raise a question under the law.
In short, the basic test for any advertiser should be: Would the ordinary reader construe the
advertising as sending a message of preference for or against a particular class of home
seeker?
While no overt examples of discriminatory advertising was found in our review it is
imperative that the City constantly monitor local publications so that any problems can be
found early and action taken immediately.
6.0 - ZONING and HOUSING REGULATIONS
Another aspect of discrimination necessary to discuss is barriers to fair housing resulting
from zoning and subdivision regulations. Whether certain zoning and subdivision controls
are, in fact, discriminatory is controversial. However, several cities have been successfully
sued by the federal government over the manner in which they were zoned.
6.1 Potential Impact of Zoning and Housing Regulations on Fair Housing
A view of representative studies of the nature of zoning discrimination shows that, as
observed by Professor Richard T. Lai, Arizona State University, in his paper The Effect
of Exclusionary Zoning on Affordable Housing, "If land -use zoning for the purpose of
promoting reason, order and beauty in urban growth management is one side of the coin,
so can it be said that exclusion of housing affordable to low and moderate income groups
50
City of Cuyahoga Falls, Ohio 29
8A o AB Analysis of Impediments to Fair Housing Choice
is the other ... as practiced, zoning and other land -use regulations can diminish the general
availability of good quality, low -cost dwellings...." " Concerning the adoption and
administration of building codes, Dr. Lai states "__local building codes also often serve an
Exclusionary function,.. (they) have become a considerable barrier to the potential
economics that could be realized through manufactured housing techniques. ".
6.2 Introduction
Not In My Backyard, Removing Barriers to Affordable Housing, was published by the
Advisory Commission on Regulatory Barriers and Affordable Housing. In the forward, then
HUD Secretary Jack Kemp wrote that "the Commission's disturbing conclusion is that
exclusionary, discriminatory and unnecessary regulations constitute formidable barriers to
affordable housing, .. "53 Notln My Backyard..., cites excessive subdivision standards, fees,
slow and burdensome permitting processes, applying building codes for new construction
to rehabilitation and NIMBY as among the most serious barriers.
The Advisory Commission concluded that states should take action to alleviate barriers to
affordable housing. "States are in a unique position, for both constitutional and practical
reasons, to deal with regulatory barriers to affordable housing. Constitutionally, all authority
exercised by units of local government over land use and development derives wholly from
the State.. which is therefore uniquely situated to undertake reform of the collage of local
regulations, as well as the State requirements that overlay them."
Patricia E. Salkin, Director of the Government Law Center, Albany Law School, offers a
balanced view of the theoretical degree to which land use and building controls add
housing cost in her April 1993 article in the publication, Land Use Law, Ms. Salkin correctly
speculates that "It is time to openly discuss and debate the Report (Not In MY Backyard...)
and perhaps launch an empirical study to refute or substantiate the document - just how
much do land -use regulations drive up the cost of housing? The real public policy issue
in the debate is this: What is the most constructive balance between the public interest in
affordable housing versus the public interests involved in land -use control ? "54
The Council of State Community Development Agencies (COSCDA), published Making
Housing Affordable: Breaking Down Regulatory Barriers - A Self - Assessment Guide for
States published in the late 1990's. The 'Guide' cites the common issues raised about
regulatory barriers and notes that: "...most states do not easily or readily intervene in local
land use matters. Few issues areas politically sensitive -and potentially damaging to state
elected officials - than local zoning, subdivision and building regulations. States can
"The Effects of Exclusionary Zoning on Affordable Housing, Richard T. Lai, 1991, p.3
57 Not In My Backyard, Removing Barriers to Affordable Housing, 1991, p. 2
" Land Use Law, Patricia E. Salkin, 1993, page 7
51
City of Cuyahoga Falls, Ohio 30
BB o AA Analysis of Impediments to Fair Housing Choice
assume a leadership role in advancing and encouraging thoughtful modification of land use
and development regulation. "55 While this lays the burden on the State, the City and
County should consider their role in assuring that they are not involved in promoting
barriers to equal housing, The Guide includes the following recommendations for
evaluating how regulatory barriers may be impediments and how they may be modified:
States should require that all communities have comprehensive plans which
include a housing element
States should establish mandatory, preemptive stateside building codes
3, Infrastructure needs should be tied to the capital improvement and housing
elements approved in the comprehensive plan
4. States should enact legislation mandating the circumstances and conditions
upon which local governments may impose impact fees. Such legislation
should allow exemptions or reduced fee schedules for lower income housing
5. States should take a leadership role in providing education and technical
assistance for local officials, developers, residents and other interested
parties in planning and regulatory issues
Four key areas were reviewed as part of the analysis. They were selected because of the
possible adverse effects they could have on families and persons with disabilities.
A. Definitions used for "families ", "group homes ", "dwelling unit'
B. Regulations (if any) regarding "group homes"
C. Ability for "group homes" or other similar type housing to be developed,
D. Unreasonable restrictions, costs on developing multi- family housing units,
such as lot size requirements, impact fees, setbacks.
Discriminatory zoning regarding group homes is probably one of the most litigated areas
of fair housing regulations. Across the country advocacy groups for the disabled are filing
complaints over restrictive zoning codes and in most cases these groups are prevailing.
Perhaps one of the most influential court rulings regarding zoning and group homes was
The City of Edmonds vs. Oxford House, Inc. This case also addresses the issue of the
definition of family contained in zoning regulations, The fundamental part of this case was
whether a definition of family that allowed for unlimited related individuals in a unit but
limited unrelated individuals to five or fewer was discriminatory .56
" Making Housing Affordable: Breaking Down Regulatory Barriers - A Self- Assessment Guide
for States, p 1
SG Court Mandates Redefinition of Family, Robert F. Manely, O.RC. Newsletter, December 10,
1995, p. 10 and 11
5A
City of Cuyahoga Falls, Ohio 31
88 0 88 Analysis of Impediments to Fair Housing Choice
The court said that this definition of family violates the federal fair housing regulations (42
USC 3604(f)(3)(b). The majority of the court found that the open -ended numerical potential
of a traditionally nuclear family is so much greater than the limit of five unrelated persons,
that the city was not making a reasonable accommodation for disabled individuals.
Considering the impact of the Fair Housing Amendments Act of 1988, the Uniform Federal
Accessibility Guidelines, Section 504 of the Rehabilitation Act of 1973 and the Americans
with Disabilities Act, entitlement grantees must exercise extraordinary diligence in their
efforts to conform their policies and procedures to the ever - evolving requirements of the
law. This is especially true with regard to zoning and building regulations, where
developers rely upon grantees to establish the boundaries within which they can operate.
As far as can be determined, the City of Cuyahoga Falls conducts their housing programs
in an affirmative manner and without restrictive policies that would adversely affect
members of the protected classes.
6.3 Local Review of Zoning Codes
The City of Cuyahoga Falls provided a number of documents regarding local zoning:
Sign & Landscaping Code 2003
Zoning Regulations July 2005
Planning and Zoning Code - Proposed - 2005
For the purpose of this report we focused our review on the new proposed planning and
zoning code, particularly the definitions and Chapter's 1131 and 1132. Our review of the
Sign and Landscaping code found no issues as they relate to housing or the provision of
housing that would be considered discriminatory.
In our limited review of the documents we could find no issues with lot sizes, setbacks, etc.
in the proposed planning and zone code that possibly would be discriminatory. Any
concerns that we did have since been addressed in the new codes.
7.0 HOME MORTGAGE LENDING ACTIVITY
The American dream is one of achieving self - sufficiency and success both economically
and personally. Home ownership is an element of economic and personal success.
Freedom to own a home is the right of all people and yet, housing discrimination has been
the hardest of the many civil rights issues to overcome.
At the heart of housing discrimination is the issue of mortgage lending. The issue of color,
race, national origin, sex, religion, familial status or disability can still shut the door to home
��
���
City of Cuyahoga Falls, Ohio 32
�nalysis of Im pediments to Fair Housing Choice
ownership. These discriminatory policies are holdovers from a past that would not allow
loans to people who would represent an "iDh8r[00DiOUS racial g[VUp' to neighborhoods
The policies Uflocal lenders, real estate agents and even the federal government (through
the Federal Housing Administration and Veterans Administration loan policies) assured that
our country would grow with segregated cities The most basic right Uf all Americans, t8
live where they want and can afford, was denied throughout the housing market, EVid8UC8
that mortgage lenders continue t8 use these protected classes t0 deny housing iSrevealed.
Research of the O0O|tg8g8 lending iDdUStp/ reV8@|S that lending di8C[i81iD8ti8U and
"redliOiUg" continue t0h8g serious and persistent obstacle tO home ownership. Since
passage 8fthe Home Mortgage Disclosure Act /UMD/\\ over twenty years ago, analyses
UfHM[]/\data hy community-based organizations, academic organizations, and Ce[fQiO
national origins face unequal access to housing credit. Current Studies consistently show
that the income, racial, and ethnic characteristics Uf@ neighborhood 0rindividual plays
significant role iD who receives loans and who does not.
Under the Fair Housing Act, it is unlawful for any person who engages in the business of
making or purchasing residential real estate loans, or in the selling, brokering, orappraising
Of residential real property, tO discriminate 0D the basis nf the factors listed above. The Act
CUDt8iAS both public and private 8Of0[C8Dl9Dt }A8Ch8niSDlS and violations may be
established by proof 0f disparate treatment O[ disparate impact.
Disparate treatment occurs when 8 lender treats @ credit applicant V[ borrower differently
based OD one Vf the prohibited characteristics during the lending p[nC8SG. For example,
requiring one applicant to make an appointment to discuss a loan application while allowing
another applicant tO "drop iU anytime" would be considered disparate treatment. Steering
some applicants into higher priced loan products is another example of disparate treatment,
8GiS selectively using income averaging tO improve deht't0-iDnnO1e ratios only for some
applicants, Finally, requiring G change iU loan terms if the marital status 8fthe b0[[0m/e[
changes during the life of the loan, when there is no evidence of unwillingness or inability
tV pay, would also be disparate treatment,
Disparate impact occurs when a lender applies 8 policy 0r practice equally t0 all credit
applicants, but the policy or practice has a disproportionately adverse impact on applicants
from a protected group. For example, 8D institution has established @lending policy that
prohibits mortgage loans below a certain dollar threshold, While this policy may have been
iD effect for some time and may be applied equally t0 all applicants, such R dollar limitation
may result iD discrimination against 8protected group, /\ group that may h8 more likely fV
pU[Ch@S8 h8UleS priced below this threshold would be prevented from obtaining home
[0Odg8g8lVaDSr Another example Of disparate impact iS the practice Ofusing gross income
in underwriting decisions, but failing t0 "gross up" non-taxable income Such 8practice
could have 8 disparate impact OU the elderly and individuals with disabilities
The Community Reinvestment Act (CR/\) was enacted @S Title VII 8fthe Housing and
Community Development Act 0f1977 CR/\ was designed tO encourage banks and other
54
City of Cuyahoga Falls, Ohio 33
B8 o BB Analysis of Impediments to Fair Housing Choice
financial institutions to help meet the credit needs of their local communities, including low -
moderate income neighborhoods. The Act requires that lenders accommodate the public
in the three tests of: credit; service; and, investment. The statute calls for regulatory
agencies to assess the records of financial institutions in meeting local credit needs. The
CRA specifically reaffirms that financial institutions should be encouraged to meet local
credit needs only in ways which are consistent with the safe and sound operation of such
institutions
Another important aspect of CRA for communities is that it give individuals, community
groups or local government the opportunity to intervene in the decision making process.
For instance, when a financial institution files an application to merge or acquire another
institution, opens or closes a branch or applies for new insurance, the community can offer
its assessment of the institution's community lending performance. Often by filing a CRA
protest or challenge, a group gains the leverage it needs to compel a lender to address
local banking needs and formulate a commitment to meet those needs.
Only through nondiscriminatory credit, service and investment can the lending industry
make the American dream of home ownership a reality.
The statistical databases used for the analysis were Peertrax HMDA Analyzer. Peertrax
is a data software program based on annual reports made by individual lenders to their
respective federal financial regulator agency. Maptitude mapping software was used for
any mapping portions of the report..
7.1 Introduction to Lending In Cuyahoga Falls
Important to a community's financial well being is home ownership rates. Access to
mortgage credit for expectant home buyers is expected to be there by the community.
Programs that offer home ownership must be available without regards to discrimination,
income or profession. To truly live up to fair housing law, all persons must have the ability
to live where they want and can afford.
Access to mortgage credit enables residents to own their homes, and access to home
improvement loans allows them to keep older houses in good condition. Access to
refinancing loans assures access to many of the dreams that all Americans have. All of
these help keep neighborhoods attractive and residents vested in their community .63
Inadequate lending performance results in various long term and far ranging community
problems. Disinvestment is probably the most devastating result. Disinvestment in
Cuyahoga Falls by lenders reduces housing finance options for borrowers and weakens
competition in the mortgage market for low and moderate income neighborhoods. High
mortgage costs, less favorable mortgage loan terms, deteriorating neighborhoods, reduced
63 Profile, Federal Reserve Bank of Cleveland, Fall 2000
155
City of Cuyahoga Falls, Ohio 34
88 o B8 Analysis of Impediments to Fair Housing Choice
opportunities for home ownership, reduced opportunities for home improvement and the
lack of affordable housing are only a few of the consequences of inadequate lending
performance. Financial decay in the business sector as well as the private sector is also
a result of disinvestment business relocation, closure and bankruptcy. Full service local
lenders, that have traditionally served residents and businesses, are the main cog in the
wheel that keep neighborhoods stable.
Significant changes are occurring in the lending market, not only in Cuyahoga Falls but
throughout the United States. The number and type of lenders have changed over the last
ten years. It is becoming a common occurrence to read about national lenders buying local
lenders. These national lending institutions are becoming increasingly more active locally.
The market share of national corporations is growing yearly. The "newest' issue to emerge
from the changes in the market is the substantial growth of the sub -prime market and the
impact that these lenders have on communities and neighborhoods. More and more we
are seeing local, commercial banks lose market share to lenders outside the City, with little
or no stake in it.
7.2 Sub Prime Lending
Each year, millions of consumers are targeted by sub prime lending institutions to secure
high cost mortgage and /or retail loans. Sub prime lenders specialize in offering credit to
consumers who may have credit blemishes or consumers with "B" or "C' credit, while
conventional lenders focus their marketing efforts on consumers with few or no blemishes
or those with "A" credit. With promises of easy payment plans, debt consolidation, and
quick approval, predatory lenders lure many consumers who have found it difficult or
impossible to access low -cost loans in the conventional market, as well as many
unassuming consumers who do, in fact, qualify for traditional loans, Recent studies by
Freddie Mac, the GSE (Government Sponsored Enterprise) that purchases mortgages from
lenders and packages them into securities that are in turn sold to investors, show that
between 25 -35% of consumers receiving high cost loans in the sub prime market qualifies
for conventional loans .64
What makes a sub prime lenders different from a predatory lender? While most sub prime
lenders serve a need by targeting borrowers with sub -par credit histories, some go too far.
Those that go too far are known as predatory lenders. Lending can become predatory
when lenders target specific populations - low income, minority, and /or elderly homeowners
- with high pressure marketing techniques, charge excessive fees, frequently refinance or
"flip" the loan, and often mislead the borrower. Communities within the Consortium are not
immune to this practice. In low and moderate income and minority neighborhoods
throughout the area one or two sub prime or predatory lenders often dominate the market,
while prime lenders have very small market shares or are not to be found.
"Information for this discussion provided by Miami Valley Fair Housing Center
NO
City of Cuyahoga Falls, Ohio 35
88 o A8 Analysis of Impediments to Fair Housing Choice
Since wealth for the vast majority of Americans is tied to property ownership, this system
is threatening to deprive many Americans of their wealth by robbing them of their home's
equity and, in some cases, foreclosing on the homes of people who cannot afford the
exorbitant interest rates and high points, It is estimated that approximately 25% of all sub
prime loans contain one or more terms that can be classified as predatory."
Mainstream financial institutions have excluded many of the groups targeted by predatory
lenders when they market loan products. Additionally, these unknowing consumers find
themselves in these devastating positions due to a lack of financial savvy. The lending
process is very complicated with numerous forms to be completed. Many consumers are
ill prepared to deal with the enormous volume of complicated paperwork that is given to
them during the loan process. Reports show that consumers do not understand the
process. Which is like the old analogy of a fox guarding the hen house, the very person
who is trying to make the loan is the one giving advice on the quality of the loan and what
the loan means.
Most predatory lenders, however, do not provide quality counseling for consumers seeking
their products and use the consumer's ignorance as a ripe opportunity to recap huge profits
from selling money in this industry. Recent studies show that subprime lenders are far
more profitable than their conventional counterparts. For instance, a small analysis of
seven national lenders reveals that the earnings -to -loan volume ratio for sub prime lenders
is substantially higher than that for conventional or prime lenders.
Many times, consumers are paying too much interest for credit they secure, and they are
purchasing credit life and disability insurance products for which they have little or no use.
Moreover, these loans are often secured with consumers property, and fair housing
organizations have received complaints from consumers who are about to lose their
homes because they cannot afford the high cost loan they obtained.
According to The Woodstock Institute, from 1993 to 1998, loans made by prime lenders
rose substantially slower than those by sub prime lenders, with 38% increase in home
purchase loans and a 2.5% increase in refinance loans, Corresponding increases among
sub prime lenders were 760% and 890% respectively. One possible reason for this
dramatic increase in loans made by sub prime lenders pertains to the increasingly
segmented system of consumerfinance with higherincome communities as the main target
of more highly regulated banks, thrifts (formerly called savings and loan ) and their affiliates
who seek to cross -sell account ans investment products. At the same time, lending to
lower income and minority communities is often viewed as an isolated line of business, in
which the focus is on the short -lived transaction and associated fees. Lenders active in
these communities tend to be mortgage and finance companies subject to substantially less
regulation than banks and thrifts,
"Council on Homelessness and Housing in Ohio - 2000
51
City of Cuyahoga Falls, Ohio 36
88 o AA Analysis of Impediments to Fair Housing Choice
There were at least 98 sub prime lenders active in the City mortgage market.. While most
stab prime lenders are designated as mortgage companies, some sub prime lenders are
affiliated with prime lenders and might be listed differently by regulators. These lenders
accepted 1,383 applications in 2002, of this total the sixteen largest lenders had more than
65% of the total market.
Table 24 shows a list of the thirty -six largest sub prime lenders in the City of Cuyahoga
Falls. These sub prime lenders are for all loan types and purposes. Ameriquest Mortgage
has the largest market share of 9.9% with Household Finance Corporation close behind
with 8.1 %. It should be noted that Household Finance and Beneficial Finance (the third
largest sub prime lender with 7.0% of the mortgage market) recently signed a letter of
agreement with the Ohio Attorney Generals Office regarding alleged predatory lending
practices. The agreement includes over 25 million dollars for past and current customers
as well as a change in their lending practices.
These two lenders controlled more than 10% of the sub prime market. In fact of the thirty
six largest lenders in the sub prime market sixteen lenders controlled more than 65% of that
market.
Figure 1 compares prime and sub prime lenders in the home mortgage market in the City.
Prime lenders had more than twice as many applications as sub prime lenders, 3,955 as
opposed to 1,383 originations were higher. When comparing originations prime lenders
originated more than 75% of their applications while sub prime lenders werejust under 50%
in originations. Denials were close with prime lenders denying 10.7% of their applications
and sub prime lenders denying 204%. One of the largest areas of difference were in
applications withdrawn by the borrower, prime lenders had 7% of their applications
withdrawn, while sub prime lenders had 21 % of their applications withdrawn.
While the presence of sub prime lenders is important in assuring that all households have
access to lending, it can be a concern when lenders who have no commitment to the
community are dominating the market.
As long as the market is dominated by out of town and state lenders it will be difficult to
encouragethem to be more responsiveto the community's needs. Local lenders participate
in the community in many ways, the arts, education and loan products that offer reasonable
options. They see that they have a commitment to the community and want to do what
they can to help, They benefits are two fold, they get high marks in their Community
Reinvestment Act reviews and encourage residents to become customers.
S13
City of Cuyahoga Falls, Ohio 37
gg o gg Analysis of Impediments to Fair Housing Choice
Figure 1: Prime & Sub Prime Mortgage Activity
2002
4000
3500
3000
2500
2000
1500
1000
500
Applications Originated Denied Withdrawn Approved Not Accept
® Prime Q Sub Prime
7.3 General Lending in Cuyahoga Falls
In Cuyahoga Falls in 2002 there were 240 lenders accepting one or more applications for
mortgage loans and there was a total of 5,373 applications. Of the 240 lenders thirteen
had 2% or more of the market for a total market share of 43.8°/x. That means that the
remaining 227 lenders had a total market share of 56.2%. Of the 36 largest lenders in
Cuyahoga Falls thirteen had 72.7% of the total mortgage market. Five of the thirteen
largest lenders were sub prime, the two largest lenders Countrywide Home Loans (6.6 %)
and ABN AMRO Mortgage Group (6.1 %) were sub prime. Table 25 shows the thirty six
largest lenders and their market share for the City.
The physical presence of financial institutions in communities facilitates relationships with
banks. There are eleven (11) depository institutions in the City of Cuyahoga Falls, nine
affiliated with large national institutions and two locally owned and operated. Location of
lenders is the primary concern for a community. Areas that are left without branches or
only access to ATM machines must find alternative sources for services (check cashing
business, finance companies), which can be more expense than traditional financial
institutions or credit unions. Table 26 lists the depository banks in the City, their 2002
market share for mortgage applications and numberof applications (all types and purpose),
"
City Cuyahoga f C hoga Falls, Ohio 38
777 777, 1
g , g Analysis of Impediments to Flair Housing Choice
Table 26 - Cuyahoga Falls Depository Institutions - Number of Branches - % Market
S_ hare of All Applications All
Loan Types - 2002
INSTITUTION
% Market # of Rank In %
Share Applications Market Share
2002 2002 2002
Key Bank
0.7% 38 36
Falls Bank
1, 1% 1 64 23
National City Bank
3,7% 201 3
North Akron Savings Bank
07% 41 30
Third Federal Savings & Loan
j
20% 110 13
Valley Savings Bank
0,9% 50 26
Bank One
2.8% 155 8
Charter One
3,6% 195 5
Fifth Third Bank
09% -52-
Firstmerit Bank
13% 72 21
US Bank
06% 35 43
Ohio Savings Bank
22% 1 119 11 1
Total Market Share - 20.5%
Total Applications -1,132
In 2002 lenders accepted 5,373
applications for mortgage loans This includes all loan
purposes and types. Table 27
shows action taken on those applications.
Table 27 - Action on ApI
Year Apps
1; Originated
2002 68.8%
Lions 2002
Apps
Approved
Not Accepted
7.2%
Apps Apps Closed for
Denied Withdrawn Incompleteness
13.2% 1 8,1% 2,7%
Of the 5,373 applications received in the City 13.2% or 710 applications were denied.
While 68,8% of the applications were originated.
Over 7% of applications were approved by the lender. Applications approved but not
accepted are those that the consumer or borrower turns down. Often this is because loan
terms change, interest rate increases, fee changes or other issues that make the loan
9 VD
City of Cuyahoga Falls, Ohio 39
gg n gg Analysis of Impediments to Fair Housing Choice
unacceptable to the borrower. Withdrawn applications (8.1 %) are those that the borrower
drops in the application process. There can be many reasons for this from changing their
minds on the loan or to changes in the terms of the applications. Incomplete applications
are often closed by the lender due to lack of information from the borrower.
Table 27A shows the reason for the denial. As would be expected credit history was by far
the greatest reason for applications being denied, 39.6°/x. The second largest reason was
debt to income ratio, 20.6 %.
Table 27A: Reasons for Denial of
Year Debt to
Employment Credit
Collateral Cash, Other
Income
History History
MPI or
Ratio
Bad Data
2002 20.6%
1.8% 39.6%
159% 9.4% 14.4%
7.4 Applications
By Loan Purpose
An indication of lending patterns in a community are the purpose that a mortgage loan is
going to be used for, such as home improvement, home purchase, refinancing or multi-
family. A strong community would like to see a healthy home buyers market for it shows
stability and a healthy housing market. Of course growth in the housing market can be a
double edged sword. First if the growth is in the high end of the market it ignores the need
for affordable, mid priced housing. Many times a community's growth will be due to the
development of "suburban" housing outside of a city. This "bedroom" growth often has the
result of inflating the housing market and provides little or no affordable housing.
Figure 3 shows how 5,373 applications were spread in terms of purpose for 2002,.
More than 68% of the applications were for refinancing. This was almost three times larger
than applications for home purchase and thirteen times greater than home improvement
Wf
City of Cuyahoga Falls, Ohio 40
B8 n 88 Analysis of Impediments to Fair Housing Choice
Figure 3: Loan Purpose 2002
70.0%
60.0%
50, 0%
400%
30.0%
20.0%
10.0%
0
I Home Improvement I Multi- Family
Home Purchase Refinancing
M
Figure 4: Action by Loan Purpose 2002
10000%_
80 00% _i z
0
I Denied i Withdrawn I
Originated App Not Accpt Closed
Conv Home Purchase ❑ Refinancing
0 Home Improvement
applications.
Home purchase
loans are a strong
indicator of how
many families are
able to purchase
single - family
housing in the City.
Part of the reason
for the high
refinancing rates
are due to lower
interest rates and
the increased in
the advertising for
this product. One
can hardly turn on
the radio or tv
without hearing an
ad for refinancing
Figure 4 shows
a c t i o n o n
applications by loan
purpose. Home
p u r c h a s e
applications had an
eight in ten chance
of being approved.
Home purchase
applications also
had the lowest
denial rate of the
three loan
purposes, with just
6% of the
applications being
denied.
Home improvement and refinancing loans should be the easiest loans to make. The lender
is dealing with a known borrower, who has equity in their home and has a commitment to
the dwelling, Of concern is the 35% denial rate in 2002 for home improvement.
Refinancing applications had a denial rate of 14.5 %. Both of these are high and might be
(o2
City of Cuyahoga Falls, Ohio 41
AA o AA Analysis of Impediments to Fair Housing Choice
due to the popularity of refinancing over the last few years or it could show the increase in
the sub prime market in the City which usually show higher denial rates than conventional
lenders.
Government backed applications (FHA/VA) accounted for 8.3% of total applications, Table
28 shows the breakout of applications by loan type (Conventional, FHA, VA). The
important factor of this table is the "not available" reporting percentages. The "not available
category" had over 1,609 applications, 34% of all applications received in the City. The
high numbers of applications with race "not available" is not limited to Cuyahoga Falls but
is a national problem.
According to Jason Dietrich, Office of the Comptroller of the Currency, "HMDA contains a
surprisingly high percentage of applications that lack race data and those percentages have
trended upward. "66 The FFIEC website highlights in its guide to HMDA reporting for 2003
the requirement, effective on January 1, 2003, to collect race and sex data on telephone
applications '67 This new requirement will allow more accurate monitoring of lending
institutions for fair lending compliance. But just as that new effort was recently put into
place, the regulatory agencies in late 2004 were considering changes to HMDA reporting
requirements that would make it difficult to continue to get HMDA data from a large
percentage of lenders in the Country. loans had the lowest rate of denials, with just over
5.3% in 1999 the highest year. It would be expected that these loans would have lower
rates since they are designed for those with credit problems and other lending issues.
7.5 City of Cuyahoga Falls's Largest Lenders
As mentioned earlier of the 251 lenders active in the Cuyahoga Falls in 2002 the majority
received 20 or less applications. For this report we considered all lenders who had 2% of
more of the lending market. Table 29 indicates the thirteen lenders that meet that criteria.
Sub prime lenders are highlighted. As discussed previously five of the thirteen largest
lenders are sub prime with a total market share of just over 20 %.
The two largest lenders were Countrywide Home Loans and ABN AMRO Mortgage
Company with 12.7% of the City mortgage market. Four of the largest lenders were had
a strong presence in the community through branch offices, National City (3.7 %), Charter
One (3..6 %), Bank One (2.8 %), Ohio Savings Bank (2.2 %), and Third Federal Savings and
Loan (2.0 %). Two of the local lenders also showed a presence with their affiliated
mortgage companies, National City Mortgage Company ( 3.7 %) and Firstmerit Mortgage
fie Dietrich, Jason, Missing Race Data in HMDA and the Implications for Monitoring of Fair
Lending Compliance ", March 2001
67 Federal Financial Institutions Examination Council's website www.ffiee.gov /hmda,
September 12, 2003
(03
City of Cuyahoga Falls, Ohio 42
B8 o B8 Analysis of Impediments to Fair Housing Choice
Corporation (2.9 %)
Sub prime lenders have a tenancy to come and go in the market, the number one lender
one year will not necessarily be the number one lender the next year or might not be in the
market at all. This is due to marketing, fluctuations in the lending market, interest rate
changes and corporate.
One area that changes often take place is in comparing lenders market share by all
applications and to a specific mortgage purpose such as conventional home purchase. The
focus of this report is on Conventional Home Purchase applications, originations and
denials. As noted above, the Federal Financial Institutions Examination Council's HMDA
data is compiled only for the census tracts contained within the City of Cuyahoga Falls
using Peertrax HMDA Analyzer. Data in all of the tables related to lending throughout this
analysis are compiled from this data unless otherwise noted.
Our concern with conventional home purchase is that this type of mortgage product puts
people in housing. It is a sign of the ongoing health of a community or neighborhood. We
want to consider not only the number of applications for conventional home purchase as
compared to say, refinancing (as discussed previously) but also in terms of originations and
denials.
Table 30 shows the thirty six largest lenders in terms of conventional home purchase
applications. Sub primes lenders are highlighted. Many of the largest lenders for all
applications were also in the largest lenders for conventional home purchase. Countrywide
Home Loans was the largest lender with 8.1 % of conventional home purchase applications.
National City Bank was second with 4.9% of the applications.
The discussion on the topics below are all for conventional home purchase unless
otherwise noted.
7.6 Lending to Low and Moderate - Income Households
Low and moderate - income households make up a portion of Cuyahoga Falls households.
For those households, access to credit for home loans is essential, as home ownership is
the primary way of increasing personal net worth and assets for man Americans, Median
household income in the City was $42,263 in 2000.
Nationally, growth in lending to low and moderate - income borrowers outpaced lending to
middle and upper- income borrowers, especially between 1993 and 1998. Home purchase
mortgages to low- income borrowers increased 75% during this period, but only 52% for
Upper-income borrowers.
Table 31 shows action taken on applications by applicant income (highlighted). Thirty -two
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City of Cuyahoga Falls, Ohio 43
88 o B8 Analysis of Impediments to Fair Housing Choice
percent of conventional home purchase applications were from those earning 80% of less
of median household income ($33,810). Of those applications submitted by low- moderate
income applicants 76% were originated and 9.5% were denied. Twelve percent of
conventional home purchase application recorded applicant income as not available.
Overall it would seem that lenders in Cuyahoga Falls and those from other areas do a good
job in receiving applications from low- moderate income borrowers and in originating those
applications.
In terms of origination those earning 120% or more of median income have the highest
origination rates (84.3 %) as would be expected. Middle income applicants (80% to 100%
of median income also showed strong originations (79 %).
7.7 Lending By Race
It would be expected that lenders, both local and otherwise, would receive applications from
minorities that was representative of their population in the community. In the City 95.8%
of the population is White, 1 9% is Black and other minorities are 1.9 %.
As would be expected Whites had by far the greatest percentage of applications in 2002,
76.3 %, Blacks had only 1.1 % of the applications and other minorities had 1 %. It should be
noted that 20% of applications were designated as race not available. (See previous Table
31)
Minorities as a group fared poorly, in 2002 combining for only 2.1 % of the applications from
Cuyahoga Falls. The point of interest is the percent of applications where race was not
available. This means that those taking the applications were unable to report the race of
Table 32 - Percent
Race
White
Black
Asian
Native American
Hispanic
Not Available
Home aurchase
2002
... _ .................
76.3%
.._....._..._.....
1.1%
0.6%
0.3%
01%
20.0%
('05
City of Cuyahoga Falls, Ohio 44
AA o 8A Analysis of Impediments to Fair Housing Choice
9 MOAB
the applicant. In most cases this means that the applications were taken over the phone
or on the internet since, which is one of the ways that sub prime lenders accept applications
However it is still a concern that the minority population is 4.6% of the total population and
yet only 2.1 % of conventional home purchase applications were from minorities in 2002.
Whites had an ration of applications to population of 1.2, while minorities had a rate of 2.1.
Even considering the fact that the minority population is small it would be expected that
applications would have been better
Table 33 shows how those applications fared. It is one thing to get in the door to make an
applications but what happens to that application after it was submitted.
Table 33 - Action on Applications By Race
In 2002 origination rates for Whites versus Blacks and other minorities is higher. Blacks
had more than 33% of their applications approved compared to 81.9% for Whites.
Considering the small number of Black applications it would have been hoped that
originations would be higher. When the number of applications is so small as to be
statistically non important then the decent rates of originations or denials means little.
Frankly, it would be expected that with the changes in today's lending market and the
awareness of lenders of fair lending issues and programs that the service to the minority
community in Summit County and in Cuyahoga Falls would have been better.
The City does have the ability to review Home Mortgage Disclosure Act data for all lenders
that are participating in mortgage lending in the City. They can do this by annual HMDA
reviews using available software such as was used for this report or looking up specific
lenders on the Federal Reserve's web site or even by requesting copies of local lenders
HMDA reports
By conducting such reviews the City can have a better awareness of the lending market,
2002
Race
Applications
Originations
Denials
Number Percent
Number Percent
Number
Percent
White
829 76.3%
679 81.9%
49
5.9%
Black
12 1.1%
4 33.3%
3
25.0%
Other Minorities
10 0.9%
6 60.0%
2
20.0%
Not Available
217 20.0%
180 I 82.9%
13
f 6.0%
In 2002 origination rates for Whites versus Blacks and other minorities is higher. Blacks
had more than 33% of their applications approved compared to 81.9% for Whites.
Considering the small number of Black applications it would have been hoped that
originations would be higher. When the number of applications is so small as to be
statistically non important then the decent rates of originations or denials means little.
Frankly, it would be expected that with the changes in today's lending market and the
awareness of lenders of fair lending issues and programs that the service to the minority
community in Summit County and in Cuyahoga Falls would have been better.
The City does have the ability to review Home Mortgage Disclosure Act data for all lenders
that are participating in mortgage lending in the City. They can do this by annual HMDA
reviews using available software such as was used for this report or looking up specific
lenders on the Federal Reserve's web site or even by requesting copies of local lenders
HMDA reports
By conducting such reviews the City can have a better awareness of the lending market,
4(P
City of Cuyahoga Falls, Ohio 45
88 o BB Analysis of Impediments to Fair Housing Choice
what products are being used, how minorities, low and moderate income households and
men and women are faring in the City lending market. They can also monitor how well
local lenders are doing, how the sub prime market is moving and other important
information.
8.0 Fair Housing Activities
The City of Cuyahoga Falls does not currently have a fair housing program. As of this
report they distribute no brochures or other information that would inform residents of their
fair housing rights and responsibilities. There are two private non - profit fair housing
agencies that service Summit County and offer assistance to residents of the City. Neither
organization responded to a request for type and number of fair housing complaints (if any)
that they have received regarding the City.
City of Cuyahoga Falls v. Buckeye Community Hope
Buckeye Community Hope Foundation (Buckeye) is a not -for profit corporation that
develops affordable housing through the use of low- income housing tax credits. In 1995,
Buckeye purchased land in the City of Cuyahoga Falls, with the intent of developing a
affordable housing complex. The site plan was approved by the city council in 1996, but
thereafterwas stayed pending a voter's referendum seeking to overturn the approval of the
plan. The referendum was later ruled to be in violation of the state constitution. Buckeye
brought a fair housing action against the City of Cuyahoga Falls, alleging that the City's
decision to allow the referendum to stay the effectiveness of the site plan violated its
federal constitutional and statutory rights. The district court granted summary judgment,
dismissing Buckeye's equal protection, substantive due process, and Fair Housing Act
(FHA) claims. The court of appeals reversed, holding that there were genuine issues of
material fact with regard to all three claims.
The Supreme Court, by a 9 -0 vote, reversed the Court of Appeals, finding that the city
could not be held liable for the racially discriminatory actions of its citizens, even if those
citizens were city officials were acting in their private capacities. The court seemed to place
particular emphasis upon the fact that the referendum vote had never become official
(because of the agreement to withhold certification of the vote), by which it held that there
had never been any "state action" upon which to find the city liable.
t' I
City of Cuyahoga Falls, Ohio 46
A8 o BA Analysis of Impediments to Fair Housing Choice
9.0 IDENTIFICATION OF ISSUES
The HUD Fair Housing Planning Guide and related regulations describe impediments to
fair housing choice as follows:
Impediments to fair housing choice are any actions, omissions, or decisions taken because
of race, color, religion, sex, disability, familial status or national origin which restrict housing
choices, or any actions, omissions, or decisions which have the effect of restricting housing
choices or the availability of housing choices on the basis of race, color, religion, sex,
disability, familial status or national origin. Policies, practices or procedures that appear
neutral on their face, but which operate to deny or adversely affect the provision of housing
to persons of a particular race, color, religion, sex, disability, familial status, or national
origin may constitute such impediments.
As stated above, impediments to equal housing choice may take the form of governmental
or private action, and may otherwise constitute facially neutral or innocent conduct. The
Fair Housing Act prohibits conduct that has the effect of discriminating against protected
groups, as well as intentional discrimination.
With these principles in mind, our Identification of impediments is limited to two broad
categories of current or potentially discriminatory circumstances we encountered during the
conduct of this Analysis. This does not mean that there are not other impediments to fair
housing choice. Due to the need to complete this Analysis in a very short time period it was
not possible to fully explore some areas as the City would want. However, the Consultants
did find that the City has a very positive attitude to assuring that Fair Housing Choice is a
practice that is supported and enforced.
One - Fair Housing - We would encourage the City to put fair housing information on their
web site, either under the community development departments or as a separate web
page. Also, continued consideration should be given to offer education in fair housing to
the real estate and rental industry, lenders, other housing providers and the general public,.
Effective education is an important component of a successful fair housing program,
Currently there is no fair housing activity in the City except what is being provided by two
county organizations. The City needs to consider providing a comprehensive fair housing
program for its residents, This is essential if the City hopes to maintain its eligibility for
federal CDBG funds.
Two - Lending - While the issue of predatory lending was included in the lending
discussions there was not information available regarding specific predatory lending
complaints, This does not lessen the concern, with the changes in population, the growth
City of Cuyahoga Falls, Ohio 47
A8 o AA Analysis of Impediments to Fair Housing Choice
of the housing industry and the aging population in the City it is important that the City take
systemic steps to work on the issue before it becomes a real problem. We would suggest
the City develop a predatory lending brochure that could be distributed to senior centers,
through local water bills, and at libraries through out the City. Also, seminars could be
developed that would educate the public on predatory lending, By coordinating this effort
with local advocacy organizations in the City a large step could be made in educating the
public regarding this growing issue.
Also there was concern raised in the lending section of this report that minorities are
basically a non - entity when it comes to applying for mortgage loans, Even considering that
there will be income and credit issues minorities are still under represented as a market.
Due to time and funding constraints a complete and detailed lending analysis was not
conducted. Since there seems to be issues regarding minority representation in the
mortgage market it is highly recommended that the City consider such an analysis to get
to determine the depth and scope of the problem.
Local lenders are applauded for the strong presence in the mortgage market and their
ability to compete with sub prime lenders. This is a good sign for the City in that those
lenders who have a stake in Cuyahoga Falls are supporting the mortgage market
However, as indicated the sub prime lender has made increasingly strong inroads to the
market in 2002. So local lenders will need to be even more supportive of the local
mortgage market.
69
City of Cuyahoga Falls, Ohio
88 n88 Analysis of Impediments to Fair Housing Choice
SOURCES
The following sources were used in completing this report:
1 The 2000 US Census
2. The 1990 US Census
1 American Fact Finder - US Census Bureau - www.factfiinder.census.gov
4. Cuyahoga Falls Ohio website
5. City of Cuyahoga Falls, Ohio Comprehensive Plan - 2002
6, Maptitude 4,6 - Geographic Information System - Caliper Corporation - including US
geographic files contained in the detailed 2000 and 1999 Census data from STF3A and
STF3B
7. OSU Online - Community GIS Information - Results for Cuyahoga Falls, Ohio
8, Ohio Data Users Center - County Profiles
9. Regulatory Barriers Clearinghouse - City of Cuyahoga Falls, Summit County, State of
Ohio
10. Realtor,com - Find a Neighborhood
11, Peertrax HMDA Analysis Software- Centrax Group - HMDA Loan Application Register
Aggregate Data files for 1996 - 2002 for Montgomery County, City of Kettering and City
of Dayton Census Tracts.
12. SBC Cuyahoga Falls & Surrounding Area - White and Yellow Pages - 2004
11 SuperPages Online - www.superpages,com
14. Employment and Training Institute, School of Continuing Education, University of
Wisconsin- Milwaukee - 2002
15. National Association of Home Builders - www.nagb.org
16. The Expanding Role of Sub Prime Lending - Ohio Community Reinvestment Project -
2003
17. An Overview of the Predatory Mortgage Lending Process, Elizabeth Renuart
18. Fannie Mae Foundation Research and Sources
19. Risk or Race? - Racial Disparities and the Sub Prime Market - Center for Community
Change - May 2002
20. Area Chamber of Commerce
21, Area Board of Realtors
22. www.lmistate.oh.us -Labor Market Info Center - Office of Workforce Development
23, U.S. Census Bureau County Business Patterns
24. www.CARR.Com - Affordable Housing Crisis? Fact or Fiction?
25. Center for Urban and Regional Policy at Northeastern University
26. Meeting Our Nation's Housing Challenge's - Congress of the United States 2002
27, Children's Defense Fund July 2004 Report of Impact of Regulations on Housing
28. Fair Housing Planning Guide, Vol 1, DHUD, OFHEO
29. City of Cuyahoga Falls Zoning Codes and Regulations 2000 and Proposed
City of Cuyahoga Falls, Ohio
Analysis of Impediments to Fair Housing Choice
UFO au 9
MAPS
ATTACHMENTS
1.
2,
3.
4.
5.
6.
7,
Cuyahoga Falls, Ohio
Cuyahoga Falls, Ohio by Census Tract
Percent Minority Population
Age 21-64 With a Disability
Median Household Income by Tract
Percent Families Below Poverty
Percent Families with Children Under the Age Of
18 Below Poverty
Sources
Glossary of Terms
Advertising Word and Phrase List
Getting to YIMBY: Lessons in Yes In My Back Yard
Peertrax Lending Tables/Data Source
Cuyahoga Falls ESRI BIS Data Sources
Census Data Sources/Sets
iE