HomeMy WebLinkAboutExhibit 3ANALYSIS OF
IMPEDIM KNTS TO
FAIR HOUSING
CHOICE
CITY OF MIAMI
2005 - 2010
DRAFT
[:, C11Y QI Miami DemImollt GI
;Community
• , Development
TABLE OF CONTENTS
Introduction 1
Purpose 1
Methodology 2
Summary of the Conclusions and Recommendations 3
Jurisdictional Background Data 10
Social Trends 10
Housing 12
Economic Trends 22
Transportation 37
Other Relevant Siudies and Cig Initiatives 40
Legal Status Evaluation 46
Fair Rousing Complaints and Compliance 46
Discrimination Suits Filed 49
Current Programs 54
Programs 54
Activities 55
Impediments 62
Public Sector 62
Private Sector 64
Public and Private Sector 68
Other Impediments 71
Findings 72
Conclusions and Recommendations 74
Strategy to Maintain Records to Support the AFFH Certification74
Actions to Overcome the Impediments to Fair Housing Choice 76
Signature Page 85
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page ii
INTRODUCTION
EXECUTIVE SUMMARY OF THE ANALYSIS
PURPOSE
The Federal Fair Housing Act, Section 808(e)(5), requires the Secretary of the U.S. Department of
I -lousing and Urban Development (HUD) to administer housing and urban programs to a manner to
affirmatively further fair housing (AFFH). The extent of the AFFH obligation has never been
defined statutorily. However, HUD defines the following requirements]:
• Conduct an analysis to identify impediments to fair housing choice within the
jurisdiction;
• Take appropriate actions to overcome the effects of any impediments identified in
the analysis; and
• Maintain records reflecting the analysis and actions taken in this regard.
HUD interprets the objectives to "affirmatively further fair housing" to mean that the Jurisdiction
will2:
• Analyze and eliminate housing discrimination in the jurisdiction;
■ Promote fair housing for all persons;
■ Provide opportunities for inclusive patterns of housing occupancy regardless of
race, color, religion, sex, familial status (pregnancy family or individual in the
process of adopting or having legal custody of a child under the age of 18),
disability (having a record of such impairment, persons diagnosed as being HIV -
positive, and recovering substance abusers), and national origin;
■ Promote housing that is structurally accessible to, and useable by, all persons,
particularly persons with disabilities; and
• Foster compliance with nondiscrimination provisions of theTair Housing Act.
The Analysis of the Impediments to Fair Housing Choice (AI) is required of state and local
governments that receive federal funds from HUD, This primarily includes Community Block
Grants (CDBG) and HOME Investment Partnerships Program (HOME). AI is an assessment of
housing and housing related policies and practices in use throughout the Jurisdiction that
inadvertently or deliberately prevent its residents to choose where they live. The analysis includes a
discussion of the barriers to housing choice within the City of Miami, a plan of action to overcome
the identified impediments, and a strategy to maintain records and results of the actions taken.
Although the AFFH obligation arises in connection with the receipt of Federal funding, the
1 US Department of Housing and Urban Development, Office of Fair Mousing and Equal Opportunity, Fair Housing Guide. Section 1
2 Ibid.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 1
obligation extends to all housing and housing related activities in the City of Miami whether publicly
or privately funded.3 Factors that could restrict housing choice include, but are not limited to:
• Discrimination based on race, color, national origin, sex, religion, familial status and
dis ability;
• In addition to the federally protected classes Listed above, Miami -Dade County Code
Chapter 11A prohibits discrimination on the basis of race, color, religion, ancestry,
national origin, gender, pregnancy, age, disability, marital status, familial status, and
sexual orientation in housing, public accommodations, and employment other than
government employment;
• In 1998, the Human Rights Ordinance amended the Miami -Dade County Code by
prohibiting discrimination based on sexual orientation in housing, credit and
finance, public accommodations, and employment;
• Lack of affordable housing;
• Lack of housing that is accessible to the disabled;
• Lack of housing that is accessible to persons holding Section 8 vouchers due to
discrimination;
Location of jobs and availability of housing in the area;
• Lack of reasonable and accessible transportation services;
r Inability to obtain a mortgage; and
• Inability to obtain homeowner's insurance because of where the individual lives.
HUD recommends that the AI be updated every three to five years, or in accordance with the
timeframe of the Consolidated Plan. The City of Miami last conducted an AI in 2002. The City's
2004-2009 Consolidated Plan, a required five-year plan that describes a community's needs,
resources, priorities, and proposed activities to be undertaken with IIUD funding. The City of
Miami updated its Consolidated Plan in 2004 and is available to the public on the City of Miami
Department of Community Development website:
http: //ci.miami.f1,usM5mmunitydevelopment/ConPlan/index.htm
METHODOLOGY
WHO CONDUCTED THE ANALYSIS
The City of Miami Department of Community Development (CD) served as the lead agency in
coordinating all aspects of the AL CD retained the services of Civica Consulting Group, Inc. to
complete the AI report. The consultant was responsible for gathering information, conducting key
informant interviews, and writing the final document.
' US Department of Housing and Urban Development, Office of Fair Housing and Equal Opportunity, hair llnusin, Guide.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 2
PARTICIPANTS
Key informant interviews were conducted with city and county officials; as well as community
stakeholders and private organizations. The agencies involved in the interview process or that
provided valuable information are as follows:
• City of Miami Planning Department
• Fannie Mae
• Florida Justice Institute
• Housing Opportunities for Excellence, Inc.
■ Legal Services of Greater Miami, Inc.
• Miami -Dade County Affordable 1-lousing Foundation, Inc
• Miami -Dade County Equal Opportunity Board
■ Miami -Dade Neighborhood Housing Services
• Miami Dade Task Force on Urban Economic Revitalization
• National Community Reinvestment Coalition
• Northern Trust Bank of Florida
METHODOLOGY USED
The AI began with a review of social, economic, and housing data gathered from the 2000 Census
and from existing studies and reports: 2004-2009 City of Miami Consolidated Plan, Public Housing
Authority Plan, and the Brookings Institute's Growing the Middle Class: Connecting All Miami Residents to
Economic 0pportunily. Other reports cited in the Jurisdictional Background chapter include the Miami
Comprehensive Neighborhood Plan revised in 2004, as well as the 2005 Evaluation and Appraisal
Report (EAR) of the Miami Comprehensive Neighborhood Plan. Various recent newspaper articles
were also cited throughout the document.
The impediments in fair housing choice and the conclusions and recommendations were identified
through analyzing the data previously mentioned, as well as, by obtaining information through the
key informant interviews of the participants listed above. Home Mortgage Disclosure Act (HMDA)
data used to analyze impediments to fair housing in the home buyers market in the City of Miami
was provided by the National Community Reinvestment Coalition (NCRC).
SUMMARY OF THE CONCLUSIONS AND RECOMMENDATIONS
The following is a brief synopsis of the impediments identified and the recommendations suggested.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 3
Impediment FH1:
Lack of Inclusionary Zoning
Recommendations
FH 1.1 The Community Development Department will work together with the City of Miami
Planning Department's Miami 21 master plan in evaluating the strategies for inclusionary
zoning for the City of Miami.
FH 1.2 Request updates on new policies and identify opportunities for collaboration with the
Miami -Dade County Planning and Zoning Department and the Miami -Dade
Inclusionary Housing Task Force.
FH 1.3 Develop a coherent Citywide affordable housing policy that includes strategies to
integrate mix -income households
FI-1 1.4 Explore the possibility to adopt incentives to promote mixed -income housing
development, such as increasing the number of new units that can be built in a given
development in exchange for dedication of a certain percent of the units for low -and
moderate -income households.
Impediment FH2:
Scarcity of Developable Vacant Parcels
Recommendations
FH 2.1 Develop a formalized infill program in which the City would make available city -owned
parcels to developers through a Request for Proposal (RFQ) process.
FH 2.3 Include in the Infill Program a strategy to address the minimum square footage problem
through changes to regulations and the modification of the design of infill housing to fit
on smaller lots.
Impediment FH3:
High Rates of Segregation in Public Assisted Housing
Recommendations
FH 3.1 Continue to educate clients about the Fair Housing Act that allows clients to choose
where they want to live and place no limitations on that choice other than a rent cap (It
should be noted that all policies and procedures are consistent with the requirements of
Federal, State, and local law and HUD regulations and guidance).
FH 3.2 Provide technical assistance and training in affirmative marketing to recipients of City
administered federal funds. In particular, provide strategies that reach and appeal to all
segments of the community.
Impediment FH4:
Federally Funding Decreasing Annually for Public Housing Assistance
Recommendations
FH 4.1 Continue to attempt to accommodate as many HOPWA clients as possible.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 4
111 4.2 Possibly tighten restriction on the number of bedrooms allowed per household size to
reduce the amount of subsidy per household.
Impediment FH5:
Federally Funded Public Assisted Housing Clients May be Occasionally
Turned Downby Landlords DUE to prior Experiences with Assistance
Programs
Recommendation
RI-] 5.1 Provide information that demonstrates the City's successful history of timely payments
to other landlords. In addition, post on the City's website the problems standard
policies, changes to polices (i.e. the reduction in FMR coverage), and Frequently Asked
Questions (FAQs) by landlords.
Impediment FH6:
No Area -wide Cooperative Effort to Address Fair Housing Issues
Recommendations
FH 6.1 Identify fair housing activities and efforts that can be coordinated with the Miami -Dade
County Office of Equal Opportunity Board (MDCEOB).
FH 6.2 Develop a Memorandum of Understanding (MOU) with the MDCEOB to implement
the identified activities.
Impediment FH7:
Disparate Service/Under-service in Private Lending to Minorities
Recommendations
FH 7.1 Develop and implement steps to foster conventional lending and other banking services
in neighborhoods that appear to be underserved or to specific groups of citizens that
appear to be underserved, in particular in the African American neighborhoods.
FH 7.2 Target existing financial literacy programs (ACCESS Miami) in African American
neighborhoods. During outreach efforts, try to determine causes for the low percentage
of Black applicants for home loans.
FH 7.3 Regularly monitor reports of financial institutions subject to HMDA. Obtain reports
from banks and other financial institutions showing their investments in lower -income
neighborhoods; the data should indicate the location, race, and ethnicity of loan
recipients.
Impediment FH8:
Predatory Lending and Abuse of the Subprime Market
Recommendations
FH 8.1 Develop and implement financial literacy programs through the Mayor's ACCESS
Miami program. Ensure that programs are available in English, Spanish, and Creole.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 5
Fi l 8.2 Explore opportunities to collaborate and/or leverage funds for anti -predatory initiatives
with the County and other local agencies.
FH 8.3 Develop media campaign that will educate the City's residents about fair housing rights,
including the right to fair loans and the dangers of predatory lending.
Fl-i 8.4 Though the City does not underwrite predatory loans and has standards (based on debt
to income ratios) in place to deny loans that appear predatory, more specific policies are
needed that restrict interest rates, points charged on a loan, and disallows certain loan
products deemed unnecessary. A new anti -predatory underwriting policy for first term
mortgages that receive the City's assistance for down payments or closing costs should
include the following:
The term of the loan must be 30 years
— The interest rate must be fixed and cannot be more than 7.00 percent (review and
adjust for changes in interest rates periodically)
No adjusted rate mortgages
- No prepayment penalties
- Loan must be full documentation only. No stated income and/or assets loans.
The total percentage charged for Discount, Origination and Broker fees cannot
exceed 2 points.
- All other lending fees (example, application fees, processing fees, tax service fees,
administration fees, etc) must be reasonable. However, they cannot exceed $500 or
0.5 percent of the loan amount, whichever is greater.
Impediment FH9:
Lack of a Coherent Citywide Affordable Housing Policy
Recommendation
FH 9.1 Develop a clear affordable housing policy. The policy should include program strategies
that coordinate and integrate the use of the city's future affordable housing trust fund.
Impediment FH10:
Not Enough Affordable/Workforce Housing Units to Meet the Needs of City
Residents
Recommendaipons
FH 10.1 Continue to advocates on behalf of affordable housing developers streamlining the
application process, in the course of endorsing the following:
- Impact Fees;
- Streamlining the Administrative Process;
i. Community Development Department
ii. Building Department
iii. Planning Department
iv. Zoning Department
— Release of Liens.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 6
HI 10.2 Continue to implement the actions to increase affordable housing identified in the
2004- 2009 Consolidated Plan.
FH 10.3 Adopt a formal Infill Program.
PH 10.4 Establish an Affordable Housing Trust Fund.
FH 10.5 Identify opportunities for intergovernmental collaboration to address housing
affordability issues. In particular, examine the most effective manner to partner with
the County, State, and Federal to coordinate activities and leverage funding.
H 110,6 Require strong affirmative marketing programs for all affordable housing developments
using City administered Federal funds.
Impediment FH11:
Housing Discrimination on the Basis of Race, Color, National Origin,
Religion, Sex, Familial status, and Disability
Recommendations
FH 1 11.1 Develop a educational fair housing rights campaign for City residents that will help
them identify and challenge discrimination (see FH 15.1 for more details)
FH 11.2 Consolidate the fair housing complaint intake process and improve the monitoring
system (see FH 12 and FH 13 for more details)
FI 111.3 Conduct fair housing testing within the City of Miami (see FH 13 for more details)
FH 11.4 Ensure the continued availability of comprehensive fair housing enforcement by
entering into an agreement with MDCEOB,
FH 11.5 Provide fair housing education and training to housing providers to ensure compliance
with fair housing laws.
Impediment FH12:
Improve Monitoring of Housing Discrimination Complaints that Occur
within the City's Jurisdiction
Recommendations
FH 12.1 Establish an agreement with MDCEOB to provide fair housing complaint intake
training to the City of Miami to ensure that all the necessary information is acquired to
effectively conduct monitoring.
FH 12.2 Explore an agreement with the various fair housing agencies to provide the City of
Miami the information collected from the complaints; ideally complain data would be
reported on a quarterly basis.
Impediment FH13:
Housing Discrimination Complaint Intake Process is Fractured
Recommendation
FH 13.1 Centralize fair housing complaints that occur within the City by directing complaints to
311 CitiStats and/or the City's Hotline.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 7
Impediment FH14:
Improve the Amount of Fair Housing Testing within the City of Miami
Recommendations
FH 14.1 Enter into an agreement with a fair housing testing trainer to provide services to the
City of Miami and recruit new testers.
Fl H 14.2 Conduct random fair housing testing in the City.
FH 14.3 Conduct targeted fair housing testing based on the quarterly reports if trends (i.e.
geographic concentration of complaints by zip code) are identified in the monitoring
process.
Impediment FH15:
Lack of Public Awareness of Fair Housing Rights
Recommendation
FH 15.1 Implement a fair housing information campaign that specially targets City residents and
clearly informs the public about fair housing rights and the Miami -Dade County
Human Rights Ordinance.
— Develop marketing collateral (i.e. brochures, post cards, Public Service
Announcements (PSAs), web site) in English, Spanish, and Creole; all material
should specify where a resident should call to report a complaint. Use HUD
developed collateral (i.e. print, radio, and television ads).4
- Include fair housing information during the Section 8 and HOWA intake process
and at the time of recertification.
- Establish a mailing list of existing Section 8 and HOPWA clients and periodically
mail fair housing information.
- Identify where it is best to provide fair housing collateral (i.e. Neighborhood
Enhancement Team (NET) offices, public places such as libraries, and social
agencies such as the welfare office).
- Develop a media campaign using the.311 system
- Coordinate with local fair housing agencies (i.e. MDCEOB) to find opportunities
to leverage resources and organize outreach activities.
- Conduct an annual mass media campaign during the Fair Housing Month each
April.
FH 15.2 Continue to implement the Affirmative Fair Housing Marketing Plan; ensure that
outreach includes developers, realtors, landlords, financial institutions and the minority
community.
4 'l'o sec HUD developed collateral, please visit 3 ZUD's website at: http://www.hud.gov/offices/fheo/adcampaign.efm
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 8
Impediment FH16:
Mobility Impaired Individuals Lack Access to Housing with
Accommodations and Modifications for the Disabled
Recommendations
FI i 16.1 Incentivize local affordable housing developers to adopt the visitability standards by
providing bonus points on responses to Request for Proposals (RFPs) that meet the
criteria.
FH 16,2 Conduct random testing of the new housing developments to ensure that technical
requirements are in place for accessibility to buildings and facilities by individuals with
disabilities under the Americans with Disabilities Act (ADA) and the Fair Housing Act.
Impediment FH16:
Weak Participation in the Labor Market
Recommendations
FH 16,1 Continue to address the economic development component of fair housing through
the existing Minority Business Enterprise (MBE) Plan.
FH 16.2 Create job opportunities in financially distressed neighborhoods (as identified in the
2004-2009 Consolidated Plan).
FH 16.3 Develop business attraction and retention programs (as identified in the 2004-2009
Consolidated Plan).
Impediment FH17:
Spatial Mismatch -Homes/Jobs/Public Transportation
Recommendations
FH 17.1 Continue to address the economic development component of fair housing through
the existing Minority Business Enterprise (MBE) Plan.
FH 17,2 Encourage a transportation link with affordable housing by providing bonus points in
the RFPs for proposals that develop affordable housing opportunities near public
transportation
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 9
JURISDICTIONAL
BACKGROUND DATA
CONTEXT FOR A FAIR HOUSING DISCUSSION
Title VIII of the Civil Rights Act of 1968 (Fair Housing Act), as amended, prohibits discrimination in
the sale, rental, and financing of dwellings, and in other housing -related transactions, based on race,
color, national origin, religion, sex, familial status (including children under the age of 18 living with
parents of legal custodians, pregnant women, and people securing custody of children under the age
of 18), and handicap (disability), This section of the report provides a profile of the protected classes
in the City of Miami and other related general information.
SOCIAL TRENDS
One aspect of assessing fair housing involves determining the representation of protected classes in
the population and determining if any socio-economic disparities exist. Miami's residents are of an
unusually diverse ethnic and racial background, among the poorest in the nation, with a large share of
foreign born residents, and an increasing aging population of persons 65 and aver. In the following
sections, these and other social trends in the City of Miami will be reviewed.
Table 1: General Population Characteristics in the City of Miami, 2000
Total population
Male
Female
Median age
High school graduate or higher
Foreign Born
Speak a language other than English at home (5 years and older)
362,470 100.0
180,194 49.7
182,276 50.3
37.7 (X)
133,069 52.7
215,739 59.5
254,536 74.6
Source. US Census Bureau, 2000; (x) Not Applicable
RACE AND ETHNICITY
The 2000 Census indicated that the City of Miami's racial and —ethnic makeup is mostly non-White.
Miami ranks third .among the 100 largest cities in the U.S. in share of non -white population; 88
percent of the City of Miami is non -white.
Of the 100 largest cities in the U.S., the City of Miami ranked 4th in the largest share of
Hispanic/Latino population (65.8 percent) and 47th in the share of Black/African American
population (19.9 percent).
This growing diversity, both nationally and in the City of Miami, is largely due to the increase in
Hispanic and Latino populations. It is not that Miami has become more diverse; rather it has
become increasingly a city of immigrants from Latin America. The decline in the White population
has been evident since the 1970s. However, the 2000 Census revealed that the Black population has
seen a decline in absolute numbers in the City of Miami in the past ten years. The Hispanic
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 10
population grew by three percentage points during the 1990s, while the black population share
dropped by five percentage points. By 2000, 65 percent of Miami's population was Hispanic.
7 able 2: Population by Race and Ethnidty in the City of Miami, 1980 - 2000
Race/Ethnicity
Year Population % of Total
White, Non -Hispanic
1980 67,799 19.5
1990 44,091 12.3
2000 42,897 11.8
Black, Non -hispanic
1980 81,921 23.6
1990 88,763 24.8
2000 72,190 19.9
Other Races,
Non -I Iispanic
1980 2,960 0.9
1990 2,256 0.6
2000 9,032 2.5
Total Hispanic
(All Races)
1980 194,185 56.0
1990 223,438 62.3
2000 238,351 65.8
Source: US Census Bureau, 2000
SEGREGATION
According to the Brookings Institute, the segregation index in the City of Miami between Hispanics
and Blacks is one of the highest in the nation (ranked second in the United States). Demographic
patterns of income, race and ethnicity reveal great disparity and insular racial and ethnic enclaves.
The Black population is clustered north of downtown and the Hispanic population is concentrated in
the Southern and Western portions of the City. This polarization creates challenges for the City in
trying to integrate distressed communities into the broader economy as well as encourage fair
housing choice. (Please see the GIS maps, Percent of Hispanics by Census Tract and Percent Blacks
by Census Tract).
NATIONAL ORIGIN
According to the 2000 Census, the City of Miami currently has almost 60 percent of its residents
born in a foreign country and over 20 percent have arrived within the last five years. Miami has the
second highest share of foreign born residents among the 100 largest cities in the nation (Hialeah
tops the list). Approximately 74.6 percent of Miamians age five and over speak a language other than
English at home, compared to 17.9 percent at the national level. Less than half of Miami's foreign
born residents are naturalized citizens, even though most arrived before 1990.
PERSONS WITH DISABILITIES
The Fair Housing Act provides additional protection to those individuals that have a physical or
mental disability (including hearing, mobility and visual impairments, chronic alcoholism, chronic
mental illness, AIDS, AIDS Related Complex and mental retardation) that substantially limits one or
more major life activities. The Fair Housing Act has three broad purposes in relation to people with
disabilities: to end segregation of the housing available to people who have disabilities; to give people
with disabilities greater opportunity to choose where they want to live; and to assure that reasonable
accommodations be made to the individual needs of people with disabilities in securing and using
housing.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 11
Specifically, the Fair Housing Act establishes the following seven design requirements for all covered,
multifamily dwellings consisting for four or more units ready for first occupancy on or after March
13, 1991. Multi -story units are exempt from the design and construction requirements.
(1) Accessible Building Entrance on an Accessible Route.: Covered multifamily dwellings must have at
least one building entrance on an accessible route unless it is impractical to do so because of
terrain or unusual characteristics of the site. All such dwellings with a building entrance on
an accessible route must meet Requirements 2 through 7.
(2) Accessible and Usable Public and Common Use Areas: Public and common use areas must be
accessible to and usable by people with disabilities.
(3) Usable Doors: All doors designed to allow passage into and within all premises must be
sufficiently wide to allow passage by persons in wheelchairs.
(4) Accessible Route Into and Through the Covered Dwelling Unit: There must be an accessible route
into and through the dwelling units, providing access for people with disabilities.
(5) Light Switches, Electrical Outlets, Thermostats, and Other Environmental Controls in Accessible
Locations: These features must be placed in accessible locations throughout the premises
within the dwelling unit.
(6) Reinforced Walls for Grab Bars: Bathroom walls must be reinforced to allow later installation of
grab bars around the toilet, tub, shower stall and shower seat.
(7) Usable Kitchen and Bathrooms: Dwelling units must contain usable kitchens and bathrooms
such that an individual in a wheelchair can maneuver about the space.
In the City of Miami, the data on number of households that include a person with a disability may
be understated because HUD and Public Housing Authorities (PHAs) are not permitted to ask about
the disability status of a household. However, it is estimated that 95,240 disabled persons live in the
City of Miami, 48 percent male and 52 percent female. This number represents 26 percent of the
total city population. Most disabled persons in the City of Miami, both male and female, are between
the ages of 21 and 64. This group also represents the largest proportion of disabled to total
population; the total of 61,270 people represents 30 percent of the total population in that age
cohort. Less than half of the disabled adult population is employed, while 62 percent of people with
no disability are employed. Only five percent of the total population is both disabled and elderly, but
32 percent of the disabled population is older than 65.
HOUSING
During the last decade, homeownership rates in Miami were among the lowest in the nation. Yet, it
is notable to consider that the City of Miami has been going through a transformation since the last
census in 2000. This should be kept in mind when reading this report, especially the housing section.
In the State of the City Address in May 2005, Mayor Diaz noted that there are currently 21 billion
dollars worth of major projects under construction or in the pipeline. These projects will bring
70,000 new residential units and inject million dollars worth of construction into the City of Miami.
The Mayor also cited efforts to make it possible for residents to achieve the dream of
homeownership. The City has attracted private development — nearly 17,000 affordable housing
units targeted at the working middle class and over the past three years have quadrupled the
investment and production of subsidized housing — 3,000 new units have been developed or are in
production for low income families.5
5 "The New Destiny Accomplishments," Mayor Manny Diaz — State of the City Address 2005. Wcbsite:
http://www.ci.miami.Fl.us/cros/Files/SOC_05_Accomp.pdf
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 12
HOUSING UNITS AND TENURE
According to the 2000 U.S. Census, there are a total of 148,388 housing units within the City of
Miami, with an increase of 3,838 housing units since 1990. The City's total housing inventory is
nearly split between single -fancily units (1 unit detached and attached) and multi -family units (5 units
and greater). Together, single-family detached (45,523 units) and 20+ multi -family structures (39,636
units) comprise 57.3 percent of the City's total hosing inventory.
Table 3: Housin8 Units and Tenure in the City of Miami, 2000
Housing Units
Total Housing Units 148,388 100.0
Occupied Housing Units 134,198 90.4
Vacant Units 14,190 9.6
Occupied Housing Units 134,198 100.0
Owner Occupied 46,836 34.9
Renter Occupied 87,362 65.1
Population in Group Quarters 11,611 8.7
Persons Per Household 2.61 (x)
Source: U.S. Census Bureau, Census 2000, Summary File 1; (x) Not Applicable
While the 2000 Census found that the City experienced an overall increase in housing units between
1990-2000, there were notable decreases in certain structure types. Of particular note was the loss of
multi family units in structures containing 5-9 units and 10-19 units. During this period, the City lost
581 units (4 percent decrease) in 5-9 unit structures and 2,028 units (14 percent decrease) in its 10-19
unit structures. Overall, the City experienced a 5 percent increase in multi -family units, due primarily
to market rate new construction in Downtown locations. The City's overall renter -occupied units
decreased by 1,152 units between 1980-1990 and grew by only 206 units between 1990-2000.
Approximately 35 percent of the City's housing stock is owner -occupied and 65 percent renter -
occupied. The owner occupancy rate is nearly 24 percent less than Miami -Dade County. The
homeownership rates in the City of Miami are very low especially when compared to the national rate
of 66.2 percent. According to the Brookings Institute, Black homeownership rates in the City of
Miami are among the lowest in the nation; the city's Black homeownership rate of 25.5 percent was
ranked low at 91' among the 100 largest U.S. cities.
AGE OF HOUSING STOCK
The majority (62 percent) of the City of Miami's housing stock was built prior to 1970.
Approximately 44 percent of the City's housing stock was built prior to 1960, as compared to only 27
percent for Miami -Dade County. Only about 8 percent of the City's housing stock has been built
since 1990 compared to 15 percent in the County. The 2004 -- 2005 Consolidated Plan found a
correlation between neighborhoods having the highest percentages of "unsafe structures" and those
neighborhoods having the highest percentages of older housing, e.g. Little Haiti, Model City and East
Little Havana. Deferred maintenance and costs associated with code violations will increase the
overall purchase price of homes in many of Miami's neighborhoods.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 13
Table 4: Years Structures Built in the City of Mianu, 2000
Years Structure Built
1939 or earlier 15,782 10.6
1940 to 1959 49,672 33.4
1960 to 1969 26,621 17.9
1970 to 1979 28,201 19.0
1980 to 1989 16,767 11.3
1990 to 1994 5,086 3.4
1995 to 1998 4,930 3.3
1999 to March 2000 1,495 1.0
Source U.S. Census Bureau, Census 2000 Summary File 3
FAMILIAL STATUS
According to the Fair Housing Act, unless a building or community qualifies as housing for older
persons, it may not discriminate based on familial status. Of the 134,198 households in the City of
Miami, 62.1 percent are family households with a noteworthy portion of married couple families
(36.6 percent). Also, it should be noted that another significant portion of the households in the City
are of female householders with no husband present (18.7 percent).
Table 5: households by Type in the City of Miami, 2000
Households
Total Households
1-Person Household
--Male Householder
--Female Householder
2 or More Person Household
--Family Households
Married -Couple Family
With Own Children < 18
No Own Children < 18
--Other Family
Male Householder, No Wife
With Own Children < 18
No Own Children < 18
Female Householder , No Husband
With Own Children .< 18
No Own Children < 18
--Nonfamily Households
Male Householder
Female Householder
134,198 100.0
40,834 30.4
20,274 15.1
20,560 15,3
93,364 69.6
83,281 62.1
49,139 36.6
19,741 14.7
29,398 21.9
34,142 25.4
9,113 6,8
3,179 2.4
5,934 4.4
25,029 18.7
12,357 9.2
12,672 9.4
10,083 7.5
6,360 4.7
3,723 2.8
Source: U.S Census Bureau, Census 2000, Summary File I.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 14
HOUSING MARKET
According to the City of Miami's State of the City Report 2005, there are currently 21 billion dollars
worth of major projects under construction or in the pipeline. These projects will bring 70,000 new
residential units (more than eight times the number built in the last decade) and inject millions of
dollars worth of construction into the City of Miami. The Urban Land Institute, Price Waterhouse
and Moody's have all recently rated the City of Miami's real estate market as one of the top Five in
the country for investment. The wave of development underway in Miami is unprecedented, bigger
than Hong Kong in the boom years of development.6 Not since the post -World War II housing
boom that multiplied Miami -Dade County's population fivefold (to more than one million people),
has the region experienced anything comparable; a feat that originally took almost 20 years.7
The following bullets help provide context to the real estate boom:
UNP1U'DEC NDTED REAL ESTATE BOOM
• Currently, 21 billion dollars worth of major projects are under construction or in the
pipeline in the City of Miami. These projects will bring 70,000 new residential units
(more than eight times the number built in the last decade) and inject millions of
dollars worth of construction into the City of Miami.8
■ A recent survey conducted by Merrill Lynch found that the greater Miami area has
the largest real estate bubble in the nation. It was reported that the gap between
prices and local incomes has grown faster in the Miami metropolitan area than in
any other city in the United States.9 In fact, home prices in Miami -Dade have risen
85 percent since the start of 2001, nearly double the national average; home prices in
the first quarter of 2005 were 21 percent higher than a year ago.10
• Among the projects is the tallest skyscraper in Florida, a 74-story spire higher than
any residential building south of Manhattan. In addition, almost four million square
feet of new retail space (nearly as much as two Aventura Malls) and parking for
more than 100,000 cars are in the works.[ 1
▪ The confluence of factors propelling this boom into a "critical combustion." 12
- Across the country, young people and so-called "empty -nesters" have been
returning to urban centers, in part because of long, wearing commutes from
outlying suburbs. At the same time, a dwindling supply of easily
developable land in western Miami -Dade County has prompted developers
to look eastward.
— A shortage of waterfront property elsewhere led developers to Miami's
acres and acres of vacant bayfront land.
6 "High-rises, high hopes." Miami Herald. Sunday, May 22, 2005.
7 Ibid.
Ibid,
9 "Miami housing 'bubble' biggest in the nation." Miami Herald, June 22, 2005
111 lbid.
11 "High-rises, high hopes" Miami Herald. Sunday, May 22, 2005.
12 Ibid.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 15
- Low interest rates have fueled record home -buying, while aging baby
boomers are increasingly seeking second homes in sunny or exotic places.
A cleaner local government has made Miami attractive to lenders and
investors who once thought the city too risky, unsafe or corrupt.
— The weak dollar has made Miami an alluring bargain for Europeans and
Latin Americans. And compared to other urban centers like New York
City, Miami remains cheap.
BOOM OR BUBBLE —WHAT ARE THE CONSEQUENCES?
• Serious concerns have been raised about the absence of a ready plan. How will the
city cope with thousands of expected new residents and the traffic they will
generate, given antiquated infrastructure, limited public transit and a shortage of
parks and open spaces? Will Miami residents, among the nation's poorest urban
dwellers, be displaced or priced out of new housing if the planned condos actually
are built, sold and occupied? 13
• Real estate analysts, bankers and even some developers fear the real estate boom is a
bubble fueled by speculators looking to resell condo units for a quick profit, and not
by true buyer demand. If developers build too much, and speculators can't find
buyers for resale, the boom could come to an end, leaving Miami littered with
vacant and bankrupted buildings or, worse, unfinished towers and bare lots. As
much as 85 percent of all condominium sales in downtown Miami are estimated to
be by investors and speculators.14
• Some skeptics, noting the high condo prices and the out-of-town provenance of
buyers, fear that instead of the diverse, working 24-hour downtown that city leaders
envision, the boom will instead create a seasonal playground for the rich,15
ATTAINABLE, HOUSING CRISIS
• In the last few years, housing has gone from expensive to out of reach, "Three years
ago we had an affordable housing problem. Today we have an attainable housing
crisis,"16
• As a result of the real estate boom, some fear that many of Miami's low-income
families will be forced into substandard housing or stressed housing, where multiple
families live under one roof.17
• Affordable housing has become an issue beyond just for lower -income communities
in Miami, but now increasingly a problem for working families and white-collar
professionals. Miami and the County have the potential of losing key professionals -
13 ]bid.
14 ibid.
15 Ibid.
16 "[dousing prices raise concerns." Miami Herald. May 27, 2005.
17 "Affordable housing too expensive to build." South Florida Business Journal. April 25, 2005
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 16
- teachers, nurses and policemen. Between 2000 and 2005, home prices rose about
140 percent in Miami -Dade, far outstripping gains in wages. 1B
■ History shows that a city has to maintain some sense of a middle-class character if it
wants to thrive. Yet there's relatively little in the new downtown priced for working
families. In fact, there is concern that there is a surplus of high -end units under
construction, and not enough units that would meet the needs of middle and low-
income families that make up the bulk of the labor force. 19
• Besides the subsidized affordable housing units, no new affordable housing supply
is expected. Though many believe that the overbuilding of condos will create new
rental inventory —current affordable housing developers warn that these units won't
benefit low-income households and that these units will not be future housing
stock.20
AFVORI)ABLL HOUSING TOO EXPENSIVE TO BUILD
■ Affordable housing in South Florida has become too expensive to build and the
area's affordable housing developers are leaving the sector.21
Cornerstone Group - No new affordable housing projects planned (It
should be noted that the Cornerstone Group is considered the 8th largest
multifamily developer in the country).
— Pinnacle Housing Group - New focus is in market -rate housing and
commercial development.
Carlisle Development Group - Has expanded into market -rate apartments
after a long tradition in developing low-income rental complexes.
■ The gulf between the costs of real property, construction and what people can
actually afford is "very serious." Without a return, developers feel that it shouldn't
be expected that the for -profits stay in this field. In February, Pinnacle Housing
Group returned tax credits for three projects citing that there was not enough profit
to move forward.22
■ Rising land prices are at the heart of the affordable housing crisis.
Sites that are appropriate and fit the numbers that make then feasible to develop
affordable housing are difficult to find. Cornerstone CEO said in a recent article
that Cornerstone "wouldn't have left if it still made sense." In addition to property
values increasing, the cost of labor, concrete and rebar rose as much as 30 to 40
percent,23
" Acquiring sites has become difficult for affordable housing builders who depend on
layers of government subsidy that can take years to secure. A representative from
the Carlisle Group said in the same article that companies like his never competed
IH "Housing prices raise concerns." Miami Herald. May 27, 2005.
19 Ibid.
211 "Affordable housing roo expensive to build." South Florida Business Journal. April 25, 2005.
21 "Affordable housing too expensive to build." South Florida Business journal. April 25, 2005.
22 "Affordable housing too expensive to build." South Florida Business Journal, April 25, 2005.
23 Ibid.
Page 17
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice
with high -end builders for land in the past. But now, everyone thinks his or her
property is worth more than before and that market -rate builders are willing to pay
for it. "I hate to say it. I don't see many positive signs out there for the [affordable
housing] industry at all," said the former Carlisle CFO.24
■ Affordable housing builders can't convert apartment units to condos nor can they
raise rates unless incomes go up across the board. Federal tax credits require that the
units stay affordable for 15 years. State requirements can bump those commitments
up to 50 years. "At a certain point, with rents flat, something's gotta give. There
must be much more subsidy or we have to charge more rent" said one of the
affordable housing developers.25
For -profit affordable housing builders can make more money flipping land,
For example, a community development corporation (CDC) bought land in Miami's
Allapattah neighborhood for $250,000 and spent three years trying to pull together
the financing. The project fell apart and the land sold for $1.9 million.
"Why take the risk and make 20 percent when you can make 100 percent or
more?"2r,
COPY OF MIAMI HOUSING MARKET
According to the National Association of Realtors, the current median sale price for a single-family
home in the Miami Metropolitan Area is $333,600. Despite the high prices, the City of Miami is
currently experiencing a surge in multi -family housing starts and new developments in the pipeline.
However, according to the City of Miami Consolidated Plan 2004 -2009, 76 percent of the 4,683
multi -family rental units under construction/lease-up and 73 percent of the rental units planned are
market rate developments with rents ranging from $934 to $3,320 per month. Tax Credit rental
developments begin as low as $504 per month, but comprise only 13 percent of the new rentals in
the City of Miami. It should also be noted that Tax Credit multi -family rentals have typically smaller
square footage than market rate units. The largest Tax Credit rental unit is 1,170 square feet
compared to 2,375 for market rate units.
According to the 2000 U.S. Census, gross rents in the City of Miami have increased by 32 percent
since 1990, The escalation in rent prices can be attributed to the overall increase in housing values in
the City, as reflected in current sale prices and restricted supply of housing to a .9 percent decline in
the City's vacancy rate between 1990 - 2000, This is exacerbated by a relatively tight 5.6 percent
vacancy rate in Miami -Dade as a whole.
COST -BURDENED HOUSEHOLDS
Cost -burdened and severely cost -burdened households are defined, respectively, as those spending
more than 30 or 50 percent of their household incomes on housing costs, including utilities.
According to the City of Miami Consolidated Plan 2004-2009, in 2000, 41 percent of households
were cost -burdened and 20 percent of households were severely cost -burdened in the City of Miami.
The majority of the cost burned households are renters and the trend is expected to continue; by the
year 2010, 23,424 renter households will be severely cost burned as opposed to 5,753 households
with homeowners.
24 rbid,
25 [bid,
26 Ibid.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 18
The ratio of median house value to median household income is very high in city of Miami, meaning
that housing is expensive to purchase. Likewise, though rent in Miami is relatively low when
compared to other large cities, rent burden for renters is high making housing unaffordable despite
the low rents. The following two figures demonstrate how wages for working families usually cannot
cover the expense of housing in Miami -Dade County, regardless of whether the family wishes to own
a home or rent. Due to the unprecedented rapid increase of the value of real estate in the City of
Miami, it is safe to infer that the income needed for both homeownership and rental costs may have
also increased in many of the city's real estate markets since 2003 —the year these figures were studied
(recent median single family home prices show more than a $100,000 increase in the past two years).
It is also safe to infer that wages have remained the same over the past few years. The end result is
an increased gap between wages and the cost of housing and, thus, resulting in a greater number of
cost -burdened households.
F:gure 1: Homeownership Market in the Miami MSA, 2003
Annual Income
Ncedrd
70,750
70,000
nn,nun
511,020
.n,non
30,202
2n,nnn
{noun
Figure 2: Rental Market in the Miami MSA, 2003
Police Officer
25.31
Source: Reproduced from 2000-2005 Center for
]lousing Policy "Paycheck to Paycheck"
Note: Data on the median -priced home in Miami
MSA ($227,000) are from the National Association
of Realtors' report on Existing Home Sales as of
12/31/2003. The annual income needed to qualify
for a mortgage was calculated using the average
prevailing interest rate, assumes a 10 percent
downpayment and the use of private mortgage
insurance, and includes principal, interest, taxes and
insurance. Wage data are from the U.S. Bureau of
Labor Statistics' Occupational Eamings Survey as of
11/30/2003.
Re
Source: Reproduced from 2000-2005 Center for
Housing Policy "Paycheck to Paycheck"
d///.00 ` Note; Rental data are from the U,S. Department of
/4' " Housing and Urban Development's report on Fair
Needed to Afford Market Rents for the year 2003 and are based on a
2 BR Nurae (i PN} survey of recently occupied units. The Hourly
Needed 1a Af!ord 1563 16.33 Wage Needed to Afford is the hourly wage that
must be earned so that this rent does not exceed
30 percent of income, a standard measure of
affordability. It is based on a concept developed
by the National Low Income Housing Coalition.
Wage data are from the U.S. Bureau of Labor
Statistics' Occupational Earnings Survey as of
11/30/2003.
2005 — 2010 City of Miami Analysis of impediments to Fair Housing Choice Page 19
PUBLIC AND SUBSIDIZED HOUSING
"file City has made significant strides in increasing the number of subsidized units. The City of
Miami has quadrupled its investment and quadrupled the production of affordable housing units
since 2002.27 The City has recaptured near $15 million from projects that were determined to have
"failed" and has reallocated these funds to viable affordable housing projects that are currently in
progress. Currently, 2,820 affordable units (both ownership and rental) have been recently completed
or in production today. Additionally, there are a total of 68 private workforce housing projects spread
throughout Miami's neighborhoods, including Allapattah (10 projects, 2300 units), Little Havana (29
projects, 7000 units), Coral Way (13 projects, 1400 units), Overtown (6 projects, 2500 units) and
Downtown (2 projects, 700 units) with more in the pipeline.
Miami -Dade Housing Agency (MDHA) is responsible for managing the majority of the public
housing units; however, a large portion of the County's inventory is located within the City limits.
MDI-LA provides federal -subsidies for 10,500 units of public housing, which it manages and
maintains, and for 17,700 units of private housing, which it inspects annually. It also provides limited
supportive services and programs to improve the quality of life and general environment of public
housing residents, and coordinates most of the County's affordable housing programs, including the
infill housing initiative. It should be noted that of the total number of public housing units, only 77
percent are occupied.
According to the 2003 Public Housing Authority Plan, Miami -Dade County has 44,091 families on
the public housing waiting list; the greatest rental needed is for the extremely low income (<=30
percent AMI). It is also evident that families with children comprise the largest percentage (48
percent) of households in need and that most households, including elderly and families are Hispanic
(52 percent) or Black (41 percent).
An analysis of the MDHA Public Housing Waiting List by U.S. Zip Code indicates that the largest
percentage of households, and particularly Waiting List "family households", are from
neighborhoods within the City of Miami that have been designated as Neighborhood Development
Zones (NDZs). The largest percentages are found in the Allapattah (16 percent) and Little
Haiti/Model City (10 percent) Zip Codes.
HOUSING NEED
In the last five years, the City of Miami's urban core has undergone a transformation that has had a
profound impact on the housing market. In fact, the 2004 — 2005 Consolidated Plan findings
indicated th-at the City of Miami is experiencing gentrification. This is evident by the dramatic
increase in real estate values, the shortage of affordable housing, and the growing interest of
investors in urban core communities, where many of the City's low income families reside. The
following is a summary of the key findings from the Consolidated Plan's General Housing Needs
Assessment and the Housing Market Study that illustrate the challenges that the City of Miami faces.
NEED FOR HOUSING ASSISTANCE
Almost half of all households in the City of Miami have incomes below 80 percent
of area median and thus qualify for housing assistance.
27 "Press release: Mayor Manny Dar highlights Miami's increased affordable housing production." March 2l, 2005. Website:
http://www.ci miarni.flus/cinqmayor/1438.htm
2005 — 2010 City of Miarni Analysis of Impediments to Fair Housing Choice Page 20
• The low to moderate income households found to have the greatest need for
housing assistance include small families, single person households, and special
needs populations --with the elderly, at 30 percent below the median income,
demonstrating the highest need. These households have a high cost burden,
overcrowding, and substandard living conditions.
• 35 percent of the households in the Neighborhood Development Zones (NDZs)28
earn less than $10,000 a year. The highest percent of households in this category are
in Overtown (41 percent), Model City (39 percent), Wynwood (39 percent) and
Allapattah (33 percent). This creates a mayor challenge for providing affordable
housing in NDZs.
AFFORDABILITY OF MULTI -FAMILY RENTAL
• 41 percent of the households in the City of Miami are cost burdened, and the
majority of those who are cost burdened (77 percent) are renters.
• 73 percent of the NDZs residents ate renters.
• Existing contract rents within NDZs are above the 30 percent threshold for
neighborhood residents and will likely increase, Lack of rental affordability is
greatest in Overtown (38 percent) and Wynwood (36 percent).
MULTI -FAMILY RENTAL CONSTRUCTION ACTIVITY
• The City of Miami's stock of affordable multi -family rental units are declining and
not being replaced with the new construction.
• Market rate and upscale rental units comprise 76 percent of all units under
construction/lease-up and 73 percent of all units currently planned.
I IOMEBUYIR AFFORDABILITY IN NEIGHBORHOOD DEVELOPMENT ZONES
• Significant single family home purchase affordability gaps exist in the NDZs. The
average gap of affordability is $43,895. The largest gaps occurring in Wynwood
($65,202), Little Havana ($64,676), and Coconut Grove ($57,233).
• There is a potential "affordable" condominium market emerging within several of
the NDZs. Condo sales activity in Little Havana and Overtown, in particular, show
starting and median sale prices within or near the affordability requirements of
households in these neighborhoods.
SPECIAL NEEDS POPULATIONS
▪ The City of Miami accounts for 42 percent of the homeless in Miami -Dade County.
Miami -Dade County ranked fourth nationally for the number of persons living with
HIV/AIDS,29 Residents living with HIV/AIDS are concentrated in Central Miami -
Dade County in areas comprised of low-income, predominately minority
neighborhoods, including Liberty City, Allapattah, Little Haiti and Overtown,
2H NDZs and Model Blocks will be defined later in the report under the section "Other relevant studies and city initiatives"
29 Centers for Disease Control and Prevention, Characteristics of Persons Living with AIDS and I-IIV, 2001, I-IIV/AIDS Surveillance
Supplemental Report, 2003; 9(No 2):10.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 21
■ The City of Miami has the third largest elderly population in the nation, representing
20 percent of the population in the City. Approximately 76 percent of low-income
elderly live in rented housing and 52 percent of these individuals have incomes
lower than 30 percent of MFI, while only 12 percent higher than 80 percent.
■ Approximately 26 percent of the population in the City of Miami is considered
disabled. This is higher than the number of elderly in the City, yet only 24 percent of
the disabled are seniors over the age of 65. Of the 4,076 assisted housing units in the
City of Miami, no more than 5 percent of the assisted units arc designated
exclusively for the disabled,
ECONOMIC TRENDS
The City of Miami's economic indicators are mixed -one area of concern is the wide disparities
between race and ethnic groups. According to the 2000 Census, Blacks have the lowest median
household income in the City of Miami while Whites have the lowest poverty rates.
Employment decentralization is another economic issue. According to the Brookings Institute
Center on Urban and Metropolitan Policy, most of the job growth has occurred outside the. City's
boundaries. Furthermore, the City's poor neighborhoods are located in job loss neighborhoods and
are isolated from job growth areas. The Brookings Institute also found that the City of Miami Blacks
and Hispanics are more likely than their suburban counterparts not to have access to a vehicle to take
them to suburban job growth areas. These and other relevant economic trends within the City of
Miami are discussed below.
Table 6' General Economic Characteristics in the City of Miami
Number Percent
In Labor Force (16 years and older) 147,356
Mean travel time to work in minutes (16 years and older) 28.1
Median Household Income (dollars) 23,483
Median family income (dollars) 27,225
Per capita income (dollars) 15,128
Families below poverty level 19,779
Individuals below poverty level 100,405
50.3
(X)
(X)
23.5
28.5
Source. U.S. Census Bureau, Summary File 1 (SF 1) and Summary File 3 (SF 3); (X) Not applicable.
INCOME AND POVERTY
The median income for the City of Miami in the 2000 Census was $23,483, $35,966 in Miami -Dade
County as a whole, and $39,749 in the County's suburbs —demonstrating the concentration low
income residents in the County are located in the City of Miami.
According to the Brookings Institute, the City of Miami has the lowest median household income
among the 100 largest cities in the nation, almost half the national median income of $41,994, While
20 percent of the nation's households make less than $18,000, 41 percent of Miami households are in
that category.
However, there is some evidence that change may be taking place with respect to income in the City
of Miami —this change may bring both negative and positive consequences. A comparison by
income brackets of 2000 and 1990 Census household income reveals that the City of Miami only lost
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 22
households with incomes of $24,999 or less; the greatest loss occurring with households with
incomes of less than $10,000, On the other hand, households with incomes of $75,000 or more
ballooned in the last decade. In particular households with incomes levels of $150,000 or more
experienced the greatest percent change (186.6 percent) and households with incomes between
$50,000 to $74,999 gained the most households (5,452).
Table 7: Household Income by Income Brackets, 2000: City of Miami
Income Bracket 1989 1999 Number Percent
Number Percent Number Percent Change, Change,
1989-1999 1989-1999
Households 130,250 100.0 134,344 100.0 4,094 3.1
Less than $10,000 41,798 32.1 32,558 24.2 -9,240 -22.1
$10,000 to $14,999 17,263 13.3 14,370 10.7 -2,893 -16.8
$15,000 to $24,999 25,450 19.5 23,087 17.2 -2,363 -9.3
$25,000 to $34,999 16,508 12.7 17,280 12.9 772 4.7
$35,000 to $49,999 13,766 10.6 17,036 12.7 3,270 23.8
$50,000 to $74,999 9,032 6.9 14,484 10.8 5,452 60.4
$75,000 to $99,999 3,108 2.4 6,458 4.8 3,350 107.8
$100,000 to $149,999 1,845 1.4 4,829 3.6 2,984 161.7
$150,000 or more 1,480 1.1 4,242 3.2 2,762 186.6
Source: 1990 and 2000 U.S. Bureau of the Census
Though the City of Miami's poverty rates have declined since 1993, it is still considered to have the
highest poverty rate among the nation's 100 largest cities. The 2000 Census also revealed that Whites
have the lowest poverty rates (14 percent) while blacks have the highest (41 percent); Miami ranks 1'
in black poverty rates in the nation. Twenty-seven percent of the Hispanic population lives below
the poverty line.
The elderly and children residents of the city also did not fare well. Approximately 29 percent
(17,683 individuals) of Miami's over 65 years of age population were in poverty at the time of the
2000 census; The City of Miami's elderly poverty rate is ranked number one among the 100 largest
cities in the nation.
LABOR FORCE
The economic well being of a community is largely determined by how well the residents are
connected to the labor market. According to the 2000 Census, the City of Miami has an 11.7 percent
unemployment rate -ranked 6th in the nation in unemployment. The City's average annual pay
increased by only nine percent, falling short of the nation's growth of 13 percent in the last 10 years.
Since 1990, the City of Miami's population 16 years of age and over not in the labor force grew by
almost 37,000 people, a 37 percent increase. The City of Miami ranked last in the nation in labor
force participation. The city's rate was 50.3 percent while the average amongst the large cities is 63.0
percent.
However, there are signs that the unemployment rate has significantly changed since the last census.
A recent Miami Herald article stated that unemployment in Miami -Dade County is at a 20-year low
of 4,3 percent.3° Together, the three counties (Miami -Dade, Broward, and Palm Beach), form the
31) "A burst of new jobs For the taking." Miami Herald. June 26, 2005.
2005 - 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 23
country's sixth -largest metropolitan area and in the last 12 months have generated 52,200 new jobs.31
The article also stated that South Florida is leading the state in new jobs, at a time when Florida is
leading the nation. Some of the trends that are driving the job growth here include: 1) A flood of
capital and people from outside the region; 2) Diversification of the area's economy, and 3) The
onward march of the real estate boom.32
WORK
Labor force issues and industry challenges and opportunities are important to understand together.
it is essential to have a perspective about the industries and occupations where the majority of a city's
residents have found employment. At the time of the 2000 Census, the majority of the City of
Miami's residents age 16 and over held sales and office occupations (26,2 percent), while the
education, health, and social services industry employed the most residents (15.0 percent) from the
City of Miami.
According to the Brookings Institute, Miami is a low -wage economy, which is decentralizing with
implications for minority and low-income residents. Most Miami area jobs are located within ten
miles of the central business district, but only 15 percent are located within three miles, In 1990,
over 66 percent of Miami city residents commuted to employment sites inside the City, by 2000 that
figure dropped to only 50 percent. The Brookings Institute found that there is a spatial mismatch
between areas of growing employment and neighborhoods of low-income, minority workers. While
Hispanics are more spatially dispersed than the black population, both groups reside in job loss areas.
However, it should be noted that the City has begun to significantly evolve since the last census on
which the Bookings Institute's study was based, Mayor Diaz recently stated in his 2005 State of the
City address that the City of Miami is now among the top 10 generators of new jobs and that
unemployment rates have significantly dropped in the past two years. The Mayor also restated his
commitment to job creation as one of his top priorities.
Table 8: Sample median hourly wages in the City of Miami
High wage:
Low wage:
Financial Managers: $33.02
Insurance Underwriters: $17.85
Accountants: $20.79
Lawyers: $48.04
Registered Nurses: $23.04
Librarians: $21.51
Cashier: $G.82
Retail: $7,90
Food Service: $6.98
Receptionist: $9.60
Production occupations (i.e. bakers, welders): $8,77
Construction occupations: $12.74
Source, Brookings Institute. Growing the -Middle Class: Connecting All Miami Residents to Economic Opportunity.
ACCESS TO CAPITAL AND THE FINANCING OF DWELLINGS
It is important to understand barriers, such as lack of access to capital, which may impact the local
economy and the financing of homeownership. According to the Brookings Institute's Growing the
Middle Class: Connecting All Miami Residents to Economic Opportunity, there are approximately 17,000
unbanked households in Miami and immigrants are more. likely to be unbanked than any other low
income resident.
The analysis in this section covers one year of lending data for the City of Miami. The data is based
on home purchase and home improvement/refinancing loans for single family homes reported in the
31 ibid.
32 Ibid.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 24
Home Mortgage Disclosure Act (HMDA) in 2003. HMDA was enacted by Congress in 1974 and
requires that certain financial institutions (banks, savings associations, credit unions, and other
mortgage lending institutions) make public information about their home loans by: 1) the applicant's
race and income, 2) the type, purpose, and amount of the loan, 3) the loan application decision, and
4) the census tract of the property to be financed. The HMDA that is analyzed below combines the
home purchase and refinance markets by census tract. The census tract locations for the 2003
HMDA data is based on the 2000 census; in total 71 census tracts were analyzed that are
predominantly within the boundaries of the City of Miami (see attachment 1 for a list of the census
tracts). The first HMDA table (Table 9) in this report contains the following general information:
loan purpose and type, applicant race, income, and sex, as well as census tract characteristics. This
information is presented by loan decision. The second and third HMDA tables (Tables 10 and 11)
present Federal Housing Administration (FHA) and subprime loans by race and ethnicity.
GENERAL HOME MORTGAGE- .DISCLOSURE ACT DATA
The following is a brief summary of the findings from the general HMDA data from Table 9:
• In 2003 there were a total of 27,512 loan applications totaling approximately
$4,364,064,000. The majority of these were: Refinance loans (62 percent), Hispanic
applicants (54 percent), Upper -income applicants (57 percent), and Male applicants
(41 percent). The high percentage of refinance loans is in line with the national
trend.
• Of all the applications, 52.37 percent were originated, 9.81 percent were approved
but not accepted, 23.40 percent were denied, and 14.42 percent were withdrawn or
incomplete. Of the loans that were originated (approximately $2,388,737,000), the
majority were:
1) Refinance loans (59 percent); 57 percent of the total dollars lent;
2) Hispanic applicants (57 percent); 52 percent of the total dollars lent;
3) Upper -income applicants (61 percent); 74 percent of the total dollars lent; and
4) Male applicants (41 percent); 43 percent of the total dollars lent.
a Of the denied loans, most (25 percent) were refinance loans. This pattern changes
when each loan type was analyzed separately .Though few applications were made
for home improvements, this type of loan sustained the greatest denial rates (50.0
percent); while 25.1 percent of the refinance loans and 17.9 of the conventional
purchase loans were denied.
✓ 69.0 percent of all the applications were by minorities, the majority of those by
Hispanics (54.3 percent) and followed by a significantly less number of Black
applicants (11.1 percent), It should be noted that, while Whites represent a smaller
population within the City, there were more Whites loan applicants (18.9 percent)
than Black applicants.
• With respect to loan decisions by race and ethnicity, Hispanic applicants had the
greatest numbers across all the loan decisions due to this group's large volume of
applications. However, a very different pattern emerges when the numbers are
analyzed individually by race and ethnicity. White applicants had a greater chance to
be approved for a loan (70 percent) and to originate a loan (62 percent) than
Hispanics (65 percent approval rate - 55 percent originated) and Blacks (53 percent
approval rate - 42 percent originated). White applicants were also less likely to be
denied a loan (17 percent) than Hispanics (22 percent) and Blacks (33 percent). The
percent of withdrawn applications and applications approved but not accepted were
proportional similar across the different racial and ethic groups. Please see Figure 3.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 25
Figure 3: Percentage of Loan Application Decisions by Race/Ethniciy in the Ciy of Miami, 2003
Source: HMDA
70 62 data provided by
NCRC and
60 - analyzed by Civica
Consulting Group,
50 inc.
40
Blade
Hispanic
■ Originated 0 Denied
White
■ The following is a breakdown of the percentage of dollars lent by the applicant's
race and ethnicity (the universe is loan originations): 52 percent Hispanic, 30
percent White, 9 percent to individuals that did not provide race information, 5
percent Black, and 4 percent to other races and ethnicities.
• Loan applications by income are as follows: 4.48 percent to low-income, 11.25
percent to moderate income, 19.75 percent to middle income, 56.63 percent to
upper -income, and 7.89 percent to individuals whose income was not available.
Please see Table 9 for a definition of the income levels.
• There are no surprises with respect the loan decisions by income of the applicant;
the higher the income, the greater chance for a loan origination. The percent of
withdrawn applications and applications approved but not accepted were
proportional similar across the different income groups. Please see Figure 4.
Figure 4: Percentage of Loan Application Decisions by Income in the City of Miami, 2003
]..ow
Moderate
Middle
• Originated A Denied
Upper
Not Available
Source: HMDA
data provided by
NCRC and
analyzed by Civica
Consulting Group,
Inc.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 26
Table 9: HMDA Mortoae Data in the City of Miami, 2003
Active Filters:
Purpose is Home Purchase or Home Improvement or Refinancing and (Aaion is Originated or Approved Not Accepted or Denied or Withdrawn or Closed Incomplete)
(1) Percent of Total Number ofAppEications (2) Percent of Total Number of Originations (3) Number of Denied Applications as a Percent of Number of Applications for Line Item
Loan Purpose and Type
Purchase - Conventional
Purchase - Government
Home Improvement
Refinance
Multi -Family
A licant Race
Amedcan Indian/Alaskan
Asian/Pacific Islander
Black
Hispanic
White
Other
Minority
Not Provided
Not A..licable
Applicant Income
Low (0-49% of Median)
Moderate (50-79% of Median)
Middle (80-119% of Median)
Upper (>=120% of Median)
Income Not Available
Total Applications (1)
Count
$ 0010's
9,151 33.26. 1,626,900
335 1.22 43,588
872 3.17 39,378
17,154 62.35 2,654,198
0 0.00
71
165
3,063
14,942
5,207
750
18,991
3,101
213
0.26
0.60
11.13
54.31
18.93
2.73
69.03
11.27
0.77
1,232 .4.48
3,096 11.25
5,434 19.75
15,579 56.63
2,171 7.89
0
9,865
26,866
279,975
2,226,475
1,148,146
115,743
2,658,924
497,863
59,131
84,526
269,894
596,314
3,048,420
364,910
Originated (2)
Count % $ 000's
5,397 37.46 984,656
208 1.44 26,359
265 1.84 13,547
8,538 59.26 1,364,175
0 0.00 0
26 0.18 4,744
93 0.65 15,095
1,299 9.02 112,358
8,276 57.44 1,253,149
3,200 22.21 712,639
206 1.43 33,683
9,900 68.71 1,419,029
1,132 7.86 212,815
176 1.22 44,254
461 3.20 22,852
1,311 9.10 108,262
2,632 18.27 295,187
8,775 60.90 1,762,844
1,229 8.53 199,592
Approved Not Accepted
Count % $ 0010's
933 34.56 161,568
19 0.70 2,454
104 3.85 4,676
1,644 60.89 249,444
0 0.00
6
19
331
1,491
460
50
1,897
334
0
0.22 436
0.70 2,733
12.26 31,114
55.22 216,836
17.04 106,126
1.85 7,968
70.26 259,087
1237 51,076
9 0.33 1,853
78
285
580
1,512
245
2.89 4,834
10.56 23,060
21.48 61,494
56.00 289,616
9.07 39,138
Denied (3)
Count % $ 001r
1,642 17.94 270,274
55 16.42 7,534
436 50.00 16,654
4,304 25.09 621,260
0 0.00
0
26 36.62 2,587
25 15.15 3,208
1,015 33.14 92,211
3,226 21.59 458,223
886 17.02 182,094
374 49.87 56,978
4,666 24.57 613,207
873 28.15 117,196
12 5.63 3,225
471 38.23 34,210
992 32.04 88,909
1,440 26.50 152,304
3,198 20.53 585,121
336 15.48 55,178
Withdrawn / Incomplete
Count % $ 000's
1,179 29.72 210,402
53 1.34 7,241
67 1.69 4,501
2,668 67.25 419,319
0 0.00
13
28
418
1,949
661
120
2,528
762
16
0
0.33 2,098
0.71 5,830
10.54 44,292
49.13 298,267
16.66 147,287
3.02 17,114
63.73 367,601
19.21 116,776
0.40 9,799
222 5.60 22,630
508 12.81 49,663
782 19.71 87,329
2,094 52.79 410,839
361 9.10 71,002
"rabic continued on the following page.
2005 - 2010 City of Miami Analysis of Impediments to Fair Housing Choice
Page 27
Table continued from the previous page
Total Applications (1)
Originated (2)
Approved Not Accepted
Denied (3)
Withdrawn / Incomplete
Count % $ 000's
Count
%
.$ 000's
Count
%
$ 000'5
Count
%
$ 000's ,
Count
'
$ OW's
Tract/BNA Characteristics
Substantially Minority
25,643
93.21
3,691,291
13,213
91.71
1,965,466
2,534
93.85
356,758
6,185
24.12
623,563
3,711
93.55
545,504
Not Substantially Minority
1,869
6.79
672,773
1,195
8.29
423,271
. 166
6.15
61,384
252
13.48
92,159
256
6.45
95,959
Low (0-49% of Median)
3,308
12.02
309,201
1,429
9.92
125,664
356
13.19
36,412
1,017
30.74
92,530
506
12.76
54,595
Moderate (50-79% of Median)
9,581
34.82
1,098,414
4,373
30.35
503,494
1,027
38.04
119,317
2,669
27.86
295,576
1,512
36.11
180,027
Middle (80-1196/0 of Median)
8,848
12.16
1,422,921
4,937
34.27
792,670
798
29.56
127,479
1,881
21.26
296,853
1,232
31.06
205,919
Upper (>=120°/ of Median)
5,775
20.99
1,533,528
3,669
25.47
966,909
519
19.22
134,934
870
15.06
230,763
717
18.07
200,922
Low/Mod and/or Sub Minority
25,643
93.21
3,691,291
13,213
91.71
1,965,466
2,534
93.85
356,758
6,185
24.12
823,563
3,711
93.55
545,504
All Other Census Tracts
1,869
6.79
672,773
1,195
8.29
423,271
166
6.15
61,384
252
13.48
92,159
256
6.45
95,959
Applicant Sex
Male
11,485
41.75
1,907,439
5,935
41.19
1,032,821
1,157
42.85
187,316
2,751
23.95
414,430
1,642
41.39
272,672
Female
8,329
30.27
1,153,495
4,393
30.49
615,111
841
31.15
121,447
2,007
24.10
258,799
1,088
27.43
158,138
Joint
5,651
20.541
952,220
3,266
22.67
572,920
490
18.15
79,280
1,135
20-08
171,235
760
19.16
128,785
Not Applicable
2,047
7.44
350,910
814
5.65
167,885
212
7.85
30,099
544
26.58
71,258
477
12.02
81,668
Total
27,512
100.00
4,364,064
14,408
100.00
2,388,737
2,700
100.00
418,142
6,437
23.40
915,722
3,967
100-00
64I,463
Source: National Community Reinvestment Coalition. Note: Validity Errors are included.
2005 - 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 28
11OMI? ivfOR'1'GAGI_. DISCLOSURE ACV hA'I'A - ELIA AND SUI3PRJME LOANS
In interviews with key informants, it was often stated that the problems of access to loans had greatly
improved for City of Miami residents. However, the key informants cited that the difficulty today
facing many City residents, especially minority and low-income individuals, is access to gualiI)!! loans.
It was suggested that many minorities and single women tend to be automatically stirred towards
more expensive FHA loans or subprime loans without consideration of their credit rating. There was
also great concern expressed about predatory lending. Unfortunately, no resource exists that would
allow for a comprehensive analysis of predatory lending practices in Miami. However, the HMDA
was filtered by FHA and subprime loans in order to determine if there arc indicators of unfair
lending practices as suggested by the key informants. The following is a discussion on the terms,
FHA, subprime, and predatory lending; then a summary of the findings from the HMDA data
analysis of FHA and subprime loans.
Federal I-fousin, Administration (FHA)
The Federal Housing Administration, a part of the US Department of Urban and Housing
Development (HUD), was established to improve housing standards and stabilize the mortgage
market by providing an adequate home financing system through insurance of mortgages. FHA
plays a critical role in financing for minority borrowers, first time home buyers, borrowers who have
troubled credit history, and borrowers who have little money to put down on a home.
Federal Housing Administration (FHA) Loans — An FHA loan is a loan that is insured 100
percent by the agency, thereby eliminating the lender's risk. However, qualified borrowers pay an
upfront insurance premium and a monthly premium. In most cases, the insurance cost to the
homeowner will drop off after five years or when the remaining balance on the loan is 78 percent of
the value of the property -whichever is longer.33
The following is a brief summary of the findings from the HMDA data in the City of Miami by FHA
loans from Table 10:
■ In . 2003 there were 754 FHA applications in the City of Miami totaling
approximately $89,528,000 in requested loans. Of these, about 60 percent of the
requests were originated for a total of $53,452,000 in FHA loans —only 2 percent of
the total dollars lent in 2003.
■ The City of Miami is a majority minority city, therefore, the high percentage of FHA
loans to minorities (85 percent) can be expected. Most of the originated loans were
—from substantially minority census tracts (99 percent) and in moderate income level
_.census tracts (57 percent).
Though the majority of the originated FHA loans were made to minorities, a
significant portion of those loans were made to Hispanics (68 percent) totaling
approximately $40,114,000 (75 percent) of the dollars. Black applicants comprised
13 percent of the originated loans for a total of $5,593,000 (10 percent). It is
interesting to note that when considering the total originated loans, Black applicants
were more likely to have an FHA originated loan than White applicants, while table
8 demonstrates that Whites were more likely than Black applicants to originate a
loan in general.
33 US HUD: www.hud.gov
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 29
■ When taking into consideration all the FHA loans that were approved, Black
applicants were most likely to not accept the FHA loan they were approved for (17
percent); Hispanics and Whites were 12 percent and 5 percent, respectively, likely
not to accept an approved loan. The non -acceptance rate of approved loans was
also evident when all loans were examined in table 9 and with subprime loans in
table 11.
■ As stated above in the definition of a FHA loan, these loans are designed to serve
mortgage clients with limited financial resources. Therefore, one would expect that
the majority of the FHA loans would be made to low and moderate income
individuals. However, an interesting pattern emerges when the FHA borrower is
analyzed by income. The following is the percent of originated loans made to
borrowers by income level:
39 percent — individuals for which income could not be determined;
25 percent — middle income;
22 percent upper income;
12 percent — moderate income; and
10 percent — low income.
Subprirrre Loans
The term subprime is often misused to refer to certain "predatory" or "abusive" lending practices;
however, some forms of subprime lending may be abusive or predatory. In 2001, the federal bank
regulatory agencies issued the "Examination Guidance for Subprime Lending Programs" to define
subprime loans, to clarify the difference between the appropriate use and abuse of subprime loans.
The following is a brief review of the definitions:34
Subprime lending — "Safe and sound" subprime loans are made to borrowers who typically have
weakened credit histories. Weakened credit histories are characterized by problems such as payment
delinquencies, charge -offs, judgments, and bankruptcies. Another measurement for subprime loans is
the borrower's reduced repayment capacity. This can be measured by credit scores, debt -to -income
ratios and other criteria indicating credit weaknesses. The regulatory agencies have made clear that
these measurements of subprime lending should only he applied at the time of origination or
purchase of the loan. The test applies only when the lender is making the loan decision. Responsible
subprime loans that are "appropriately underwritten, priced, and administered" can enhance credit
access for borrowers with special credit needs and still offer attractive returns to the banking
industry.
Predatory/"abusive subprime lending" — A predatory loan is one which simply takes advantage
of the borrower. The key element to determine whether lending is predatory is whether there is a
"commensurate exchange of value" in both directions between lender and borrower. The regulators
are using this value exchange concept to measure the motives of the lender. A common element in
examples of predatory lending is the fact that the loan is based what the lender can make from the
transaction without regard to the borrower's benefit. Thus, loans that are based on the value of the
collateral without taking into account whether the borrower can repay would be captured by this
34 "Examination Guidance for Subprime Lending Programs." The Office of the Comptroller of the Currency, the Federal Reserve Board,
the federal Deposit Insurance Corporation, and the Office of Thrift Supervision. January 2001.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 30
definition. Likewise, another common exploitation of the borrower is steering him or her to a
subprirne loan when he or she would have qualified for a prime loan.
The regulatory agencies have distilled examples and ideas about abusive lending down to three
principles:
• Making unaffordable loans based on the assets of the borrower rather than on the
borrowers ability to repay an obligation;
■ Inducing a borrower to refinance a loan repeatedly in order to charge high points
and fees each time the loan is refinanced, otherwise known as "loan flipping"; and
• Engaging in fraud or deception to conceal the true nature of the loan obligation or
ancillary products, from an unsuspecting or unsophisticated borrower.
In short, an abuse of a subprime loan is when a borrower is exploited when the cost of the loan is
unrelated to the risk. Some in the lending industry further differentiate predatory lending as a practice
that targets a certain population (i.e. the elderly, minorities).
The following is a brief summary of the findings from the HMDA data by subprime loans from
Table 11:
• In 2003, there were 8,684 subprime applications totaling $1,182,991 in requested
dollars. This is approximately 17 percent of the total dollars lent by the banking
institutions that year.
• Similar to all the other types of loans, the majority (74 percent) of the subprirne loan
applications were submitted by minorities; Hispanics constituted 51 percent of the
applicants, Blacks made up 17 percent, 15 percent were made by applicants in which
race or ethnicity was not available, and 11 percent of the applicants were White,
• A significant majority of the subprime loan applications were for refinance (67
percent of the applications). However, it is interesting to note that of the 5,809
refinance subprime loan applications, only 29 percent were originated.
• In general, the percent of originated subprime loans was low -only 35 percent were
originated.
■ 81 percent of the originated loans were to minorities of which Hispanics constituted
the most frequent type of borrower, The percent of originated loans by race and
ethnicity were as follows: 62 percent Hispanic (63 percent of the dollars lent), 17
percent Black (12 percent of the dollars lent), 10 percent White (13 percent of the
dollars lent).
a There are two particular trends to note: 1) When studying the total number of
approved loans (originated and approved but not accepted), Subprime loans
followed a similar trend as the FHA loans in which Black applicants were more
likely to receive a subprime loan than a White applicant, though white applicants
were more likely to receive a loan in general. 2) Though more Black applicants
received a subprirne loan than White applicants, White applicants were lent
approximately $3,968,000 more than Black applicants.
• When income patterns in subprime lending were analyzed they revealed surprising
results. 55 percent of the originated loans were made to upper -income applicants
which constituted approximately 66 percent of the total dollars lent with subprime
loans. Together upper- and nuddlie-income applicants (the top two income tiers)
made up 81 percent of the originated subprime loans and 86 percent of the total
2005 -- 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 31
dollars lent in the same caregory. Equally as surprising, though upper income
applicants had the greatest number of originated loans, only 9 percent of the total
originated loans were made in substantially upper income census tracts. The
majority (45 percent) of the subprime loans were made in substantially moderate -
income census tracts.
Conclusions
While HMDA is essential in understanding the mortgage climate in the City of Miami, it should be
noted that HMDA data does have its limitations. In particular, it does not take into consideration
how the loan the decisions were made (i.e. credit worthiness) nor is a lender required to report the
race, sex, and income data for loans that they purchase from another institution (i.e. mortgage
brokers). These and other issues must be taken into consideration when reaching assumptions about
the findings. However, the data does provide information about possible trends in the City's
mortgage climate. The 2003 HMDA data clearly shows a trend with respect to the lows numbers of
Black applicants and low- and moderate -income applicants; as well as the high levels of denials of
loans of Black and low income applicants. The data also revealed that there may be more questions
than answers:
(1) Why aren't more Black residents applying for loans?
(2) Why are Black applicants more likely to be denied a loan?
Why are White residents (the smallest population of the three in the City) more likely to
receive a loan?
(4) When applicants are analyzed individually by race and ethnicity, why are Black applicants
more likely not to accept a loan they have been approved for?
When the number of originated loans is analyzed, why do Black applicants receive more
FHA and subprime loans when White applicants have received more loans in general?
(6) If FHA loans were developed to serve mortgage clients with limited financial resources, then
why are the majority of the FHA loans originated (for which income could be determined)
made to middle- and upper -income applicants?
If more Black applicants originated subprime loans than Whites, why did White applicants
receive approximately $3,968,000 more than Black applicants? What does this mean?
(8) Why were so many (81 percent) of the originated subprime loans made to the upper- and
middle -income applicants? What does it mean that so many of the subprime loans made to
the top two income tiers originated in substantially moderate -income census tracts?
A more comprehensive analysis of the HMDA data and of the mortgage climate in general will be
necessary to answer these and other questions. To help decipher many of these questions, it is
recommended that: 1) home purchase and refinance markets be examined separately; and 2) that the
loans be analyzed by race/ethnicity and income (i.e. how many Black applicants received a subprime
loan by income).
(3)
(5)
(7)
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 32
Table 10: HMDA Mortgage Data by FHA loans in the City of Miami, 2003
Active Filters:
Loan Type is FHA and (Purpose it Home Purchase or Home Improvement or Refinancing) and (Action is Originated or Approved Not Accepted or Denied or Withdrawn or Closed Incomplete)
(1) Percent of Total Number ofApp&cations (2) Percent of Total Number of Originations (3) Number of Denied Applications as a Percent of Number of Applications for line Item
Total Applications (1)
Originated (2)
Approved Not Accepted
Denied (3)
Withdrawn/Incomplete
Count
%
$ 000's
Count
%
$ 000's
Count
%
$ 0100's
Count
%
a 000's
Count
%
$ 000's
Loan Purpose and Type
Purchase - Conventional
0
'0.00
0
0
0.00
0
0
0.00
0
0
0.00
0
0
0,00
0
Purchase - Government
317
4204
40,837
200
44.35
25,242
18
26.47
2,219
48
15.14
6,522
51
40.48
6,854
Home Improvement
1
0.13
82
0
0.00
0
1
1.47
82
0
0_00
0
0
0-00
0
Refinance
436
57.82
48,609
251
55.65
28,210
49
72.06
5,935
61
13.99
6,978
75
59527,486
Mu1ti-Family
0
0.00
0
0
0.00
0
0
0.00
0
0
0.00
0
0
0_00
0
Applicant Race
American Indian/Alaskan
1
0.13
135
0
0.00
0
0
0.00
0
0
0.00
0
1
0.79
135
Asian/Pacific Islander
3
0.40
282
2
0.44
209
0
0.00
0
0
0.00
0
1
0.79
73
Black
109
14.46
10,097
59
13.08
5,593
12
17.65
1,149
14
12.84
1,143
24
19.05
2,212
Hispanic
513
68.04
64,638
323
71.62
40,114
46
67.65
5,859
79
15.40
10,669
65
51.59
7,996
White
57
7.56
6,660
38
8.43
4,520
2
2.94
328
6
10.53
593
11
873
1,219
Other
12
1.59
1,140
8
1.77
779
0
0.00
0
2
16.67
139
2
1.59
277
Minority
638
84.62
76,292
392
86.92
46,695
58
85.29
7,008
95
14.89
11,951
93
73.81
10,638
Not Provided
59
7.82
6,576
21
4.66
2,237
8
11.76
900
8
13.56
956
22
17.46
2,483
Not A..licable
applicant Income
0
0.00
0
0
0.00
0
0
0.00
0
0
0.00
0
0
0.00
0
Low (0-49% of Median)
20
2.65
1,548
10
2.22
769
0
0.00
0
4
20.00
331
6
4.76
448
Moderate (50-79% of Median)
95
12.60
8,433
52
11.53
4,391
9
13.24
853
22
23-16
1,885
12
9.52
1,304
Middle (BO-119% of Median)
182
24.14
21,564
114
25.28
13,857
10
14.71
1,164
24
13.19
3,026
34
26-98
3,517
Upper (>=120% of Median)
170
22.55
25,552
99
21.95
14,950
11
16.18
1,681
35
20.59
5,429
25
19.84
3,492
Income Not Available
287
38.06
32,431
176
39.02
19,485
38
55.88
4,538
24
8.36
2,829
49
38-89
5,579
Table continued on the following page.
2005 - 2010 City of Miami Analysis of Impediments to Fair Housing Choice
Page 33
Table continued from the previous page.
Tract/BNA Characteristics
Total Applications (I)
Originated (2)
Approved Not Accepted
Denied (3)
Withdrawn /Incomplete
Count
%
.S 000's
Count
%
$ 000's
Count %
$ 000's
Count
%
$ 000's
Count
%
$ 000's
Substantially Minority
748
99.20
88,688
448
99.33
53,027
67
98.53
8,047
108
14.44
13,390
125
99.21
14,224
Not Substantially Minority
6
0.80
840
3
0.67
425
1
1.47
189
1
16.67
110
1
0-79
116
Low (0-49% of Median)
156
20.69
17,531
105
23.28
11,687
11
16.18
1,485
23
14.74
2,653
17
13.49
1,706
Moderate (50-79% of Median)
447
59.28
51,923
259
57.43
30,102
44
64.71
4,907
62
13.87
7,769
82
65.08
9,145
Middle (80-119% of Median)
137
18.17
18,444
78
17.29
10,579
12
17.65
1,655
22
16.06
2,910
25
19-84
3,300
Upper (>=120% of Median)
14
1.86
1,630
9
2.00
1,084
1
1.47
189
2
14.29
168
2
1-59
189
NA
0
0.00
0
0
0.00
0
0
0.00
0
0
0.00
0
0
0.00
0
Low/Mod and/or Sub Minority
748
99.20
88,688
448
99.33
53,027
67
98.53
8,047
108
14.44
13,390
125
99.21
14,224
All Other Census Tracts
6
0.80
840
3
0.67
425
1
1.47
189
1
16.67
110
1
0.79
116
Applicant Sex
Male
311
41.25
39,607
185
41.02
23,166
29
42.65
3,706
49
15.76
6,643
48
38.10
6,092
Female
223
29.58
25,284
144
31.93
16,780
15
22.06
1,684
33
14.80
3,465
31
24.60
3,355
Joint
176
23.34
19,759
109
24.17
12,187
16
23.53
1,946
25
14-20
3,202
26
20.63
2,424
Not Applicable
44
5_84
4,878
13
2.88
1,319
8
11.76
900
2
4.55
190
21
16.67
2,469
Total
754
100.00
89,528
451
100.00
53,452
68
100.00
8,236
109
14.46
13,500
126
100.00
14,340
Source: National Community Reinvestment Coalition. Note: Validity Errors are included.
2005 - 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 34
Table 11: HMDA Mortgage Data by SubPrime loans in the City of Miami, 2003
Active Filters:
Purpose is Home Purchase or Home Improvement or Refinancing and (Action is Originated or Approved Not Accepted or Denied or Withdrawn or Closed Incomplete). Lender Group is SubPrime Lenders 2003
(Included).
(1) Percent of Total Number ofAppkcations (2) Percent of Total Number of Originations (3) Number of Denied Appfications as a Percent of Number of Appktations for Line Item
Total Applications (1)
Originated (2)
Approved Not Accepted
Denied (3)
Withdrawn/Incomplete
Count
%
$ 000's
Count
%
$ 000's
Count
%
$ 000's
Count
°
$ 000's
Count
%
S 000's
Loan Purpose and Type
Purchase - Conventional
2,661
30.64
367,638
1,226
41.43
166,270
397
40.76
57,388
679
25.52
94,095
359
19.68
49,885
Purchase - Government
2
0.02
442
1
0.03
146
0
0.00
0
1
50.00
296
0
0.00
0
Home Improvement
212
2.44
7,413
39
1.32
1,285
23
2.36
864
117
55.19
3,580
33
1.81
1,684
Refinance
5,809
66.89
807,498
1,693
57.22
242,531
554
56.88
76,297
2,130
36.67
289,140
1,432
78.51
199,530
Multi-Famil
0
0.00
0
0
0.00
0
0
0.00
0
0
0.00
0
0
0.00
0
Applicant Racc
Amea can Indian/Alaskan
25
0.29
3,591
8
0.27
1,169
0
0.00
0
B
32.00
878
9
0.49
1,544
Asian/Pacific Islander
34
0.39
5,017
11
0.37
2,572
5
0.51
581
10
29.41
1,019
B
0.44
845
Black
1,515
17.45
147,500
489
76.53
47,704
186
19.10
17,711
562
37.10
53,183
278
15.24
28,902
Hispanic
4,453
51.28
627,922
1,836
62.05
259,224
533
54.72
75,727
1,266
28.43
178,136
818
44.85
114,835
White
921
10_61
166,135
288
9.73
51,672
91
9.34
17,827
316
34.31
52,523
226
12.39
44,113
Other
412
4.74
62,651
58
1.96
9,669
17
1.75
2,644
300
72.82
44,997
37
2.03
5,341
Minority
6,439
74.15
846,681
2,402
81.18
320,338
741
76.08
96,663
2,146
33.33
278,213
1,150
63.05
151.467
Not Provided
1,312
15.11
168,415
263
8.89
37,090
140
14.37
19,894
463
35.29
56,244
446
24.45
55,187
12
0.14
1,760
6
0.20
1,132
2
0.21
165
2
16.67
131
2
0_11
332
Not Ay.1icab1e
Applicant Income
Low (0-49% of Median)
417
4.80
37,007
57
1.93
4,135
26
2.67
1,772
188
45.08
15,659
146
8.00
15,441
Moderate (50-79% of Median)
1,286
14.81
120,132
349
11.79
29,158
110
11.29
8,921
496
38.57
49,476
331
18.15
32,577
Middle (80-119% of Median)
2,165
24.93
232,110
756
25.62
82,363
254
26.08
27,688
731
33.76
75,880
422
23.14
46,179
Upper (>=120% of Median)
4,402
50.69
727,825
1,634
55.22
268,916
508
52.16
84,678
1,411
32-05
231,445
849
46.55
142,786
Income Not Available
414
4 77
65,917
161
5.44
25,660
76
7.80
11,490
101
24.40
14,651
76
4.17
14,116
Table continued on the following page.
2005 - 2010 City of Miami Analysis of Impediments to Fair Housing Choice
Page 35
Table continued from the previous page_
Total Applications (1)
Originated
(2)
Approved Not Accepted
Denied (3)
Withdrawn / Incomplete
Count
%
$ 000's
Count
%
$ 000's
Counr
%
$ 000's
Counr
%
S 000's
Counr %
$ 000's
Tract/BNA Characteristics
Substantially Minority
8,429
97-06
1,098,453
2,883
97.43
383,010
953
97.84
127,324
2,858
33-91
366,151
1,735
95.12
221,968
Not Substantially Minority
255
2.94
84,538
76
2.57
27,222
21
2.16
7,225
69
27.06
20,960
89
4.88
29,131
Low (0-49% of Median)
1,457
16.78
137,249
431
14.57
40,346
197
20.23
20,059
545
37.41
51,364
264
15.57
25,480
Moderate (50-79% of Median)
3,931
45.27
458,363
1,330
44.95
157,556
458
47.02
56,321
1,340
34.09
155,814
803
44.02
88,672
Middle (80-119% of Median)
2,474
28.49
392,783
944
31.90
150,628
217
22.28
34,606
797
32.22
126,692
516
28.29
80,857
Upper (>=120% of Median)
827
9.47
194,596
254
8_58
61,702
102
10.47
23,563
245
29.81
53,241
221
12.12
56,090
NA
0
0.00
0
0
0.00
0
0
0.00
0
0
0-00
0
0
0.00
0
Low/Mod and/or Sub Minority
8,429
97.06
1,098,453
2,883
97.43
383,010
953
97.84
127,324
2,858
33.91
366,151
1,735
95.12
221,968
All Other Census Tracts
255
2.94
84,538
76
2.57
27,222
21
2.16
7,225
69
27.06
20,960
89
4.88
29,131
Applicant Sea
Male
3,745
43.13
523,431
1,308
44.20
182,177
448
46.00
63,150
1,257
33.56
172,674
732
40.13
105,430
Female
3,005
:34.60
401,045
1,102
37.24
150,365
351
36.04
47,845
1,004
33.41
129,162
548
30.04
73,673
Joint
1,405
• 16.18
195,69B
449
15.17
64,630
120
1232
16,691
466
33-17
62,992
370
20.29
51,385
Not Applicable
529
6.09
62,817
100
3.38
13,060
55
5.65
6,863
200
37.81
22,283
174
9.54
20,611
Total
8,684
100.00
1,182,991
2,959
100.00
410,232
_ 974
100.00
134,549
2,927
33.71
387,111
1,824
100.00
251,099
Source: National Community Reinvestment Coalition. Note. Validity Errors are included.
2005 - 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 36
TRANSPORTATION
MIAMI-DADE TRANSIT AGENCY
The Miami -Dade Transit Agency (MDT) responsible for planning for and providing all public transit
services in the county, including the City of Miami. The mission of the MDT's Office of Civil Rights
and Labor Relations is to ensure that Miami -Dade County citizens are provided equal treatment,
access, and opportunity in the delivery of all transit and transit related services. According to MDT,
all Miami -Dade Transit buses are wheelchair -accessible. Wheelchair lifts and low -floor buses arc
available in all metrobus routes; Senior citizens and people with disabilities regularly use Miami -Dade
Transit's Metrorail, metomover, and Paratransit services.
Individuals with a permanent physical disability, as classified by the Americans with Disabilities Act
(ADA), that prevent him or her from using regular transit services, may be eligible for Special
Transportation Services (STS). STS offers curb -to -curb taxi and wheelchair van service anywhere in
Miami -Dade County and in some parts of south Broward County. This service operates seven days a
week, 24 hours a day. Riders with a state -issued parking permit or license plate for people with
disabilities may park free in spaces designated for disabled riders. In addition, medicare recipients
qualify to ride at a reduced fare on Metrorail.
TRANSIT ORIENTED DEVELOPMENT
The City of Miami's land regulations (land use policy LU-1.1.10) encourages high -density
residential development and redevelopment in close proximity to Metrorail and Metromover stations
(consistent with the Station Area Design and Development Plan for each station)35. In 2004 it was
reported that Miami -Dade County had more than 1,000 housing units and 1.8 million square feet of
retail space next to the Metrorail stations that had been built, were under construction, or in the
planning stages.36 Due to the ever expanding real estate market, it is easy to assume that many more
housing developments along the Metrorail have been added in the past year. This is true in particular
in the Brickell Village area; however, it should be noted that many of these new developments are
luxury housing developments.
In 2002, developers and Miami -Dade Transit came together to build affordable housing for the first
time adjacent to Metrorail stations in the City of Miami. This is especially significant in the City of
Miami due to the lack of access to a vehicle and the isolation from the job growth areas experienced
by many of the City's low-income residents, as mentioned earlier in this report. The following section
provides a brief summary about MDT's tranir-oriented developments located within the City of
Miami.37 It should be crate that the City of Miami partnered in the development of the Allapattah
Garden Apartments and the Santa Clara Apartments Phase I and II. These developments are
adjacent to the Civic Center area, an important job center comprised ofi the Jackson Memorial
Medical Center (one of the largest employers in the County), Veteran Medical Administration Center,
Cedars Medical Center, the Richard Gerstein Justice Building, the Satte Attorney's Office, the Miami -
Dade Community College Medical Campus, the Linsey Hopkins Technical Education Center, the
20th Street Merchant Corridor, and Allpattah's Industrial District and Produce district.
35 City of Miami Planning Department. "Miami Comprehensive Neighborhood Plan." 2004.
36 "Homes, offices, retail expected to boost Metrorail ridership" Miami Today. 1/1/04.
37 Information provided in this section is referenced from the Miami -Dade County websitc:
http://www.miamidade.gov/transit/ioint_index.asp
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 37
STATION: ALLAPATTAH(NW 36TH STREET AT NW 12TH AVENUE)
Project: Allapattah Garden Apartments
Affordable rental housing complex
5-acre site
8 garden -style, 3-story buildings totaling 128 two and three bedrootn units
Clubhouse and tenant amenities
Surface parking
Resident programs and services, day care center
Developer: New Century Development Corporation and the Carlisle Group, LLC
How Initiated: In 1999, the Miami -Dade County Office of Community and Economic
Development acquired jurisdiction of the site from Miami -Dade Transit (MDT) with block
grants. Miarni-Dade County conveyed ownership of the site to New Century Development
Corporation Inc. for development of the improvements, Allapattah Garden Apartments.
Status: Groundbreaking, October 2002; completion, spring 2004.
STATION: COCONUT GROVE (US1 AND SW 27TH AVENUE)
Project: Coconut Grove Transit Village
Market rate rental apartment tower with perimeter townhomes, including parking facilities
Retail outparcel
Surface Metrorail parking
Developer: South Dixie/27 Inc.
How Initiated: Competitive request -for -proposal process
Status: Groundbreaking date to be announced.
STATION: OVERTOWN/ARENA (NW 6TH — 8TH STREETS AT NW FIRST COURT)
Project: Overtown Transit Village
17-story, 341,000 sq. ft, County office building
8 1/2 story, 588-space parking garage, including 4,000 sq. ft. of ground -floor retail space
Public park (site of future office building)
Developer: Overtown Partnership, Ltd. (Subtenant)
Tenant: St. Agnes Rainbow Village Development Corporation, Inc.
How Initiated: Following a non -responsive RFP process, Saint Agnes Rainbow Village, Ltd.,
a not -for -profit agency, submitted an unsolicited proposal on March 10, 2000.
Status: Groundbreaking, May 2004; 18-month construction began May 2004; scheduled for
completion December 2005.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 38
STATION: SANTA CLARA (NW 20TH STREET AND NW 12TH AVENUE)
Project: Santa Clara Apartments I and II
Phase I: 9-story, 208-unit affordable rental apartment building, surface parking
Phase II: 17-story, 204-unit affordable rental apartment building; five levels of parking with
ground floor dedicated to transit parking
Developer: Santa Clara Apartments, Ltd.
How Initiated: Competitive request -for -proposal process
Status: Phase I construction began September 2002 and was completed fall 2003. Phase II
construction began May 2004 and will be completed by December 2005.
MIAMI STREETCAR PROJECT38
In 2002 a countywide effort to address congestion culminated in the development of the "People's
Transportation Plan" (PTP). As a result of the PTP, the City of Miami found a need to evaluate the
physical and financial feasibility of a streetcar system, including but not limited to: connectivity to
other transit services, economic development opportunities, ridership, and traffic.
The study was completed this year and the City of Miami Commission approved a resolution on May
12, 2005, adopting the "City of Miami Initial Streetcar Corridor Feasibility Study, Final Report, April
2005." The Miami Streetcar Project seeks to establish a streetcar system in the downtown area to
serve as an urban transit circulator within a 6.75 mile (round trip) corridor. The streetcar is
envisioned to provide service connecting the following key destinations:
• Educational Centers, such as Miami Dade College;
• Entertainment venues, such as the Club and Entertainment District, Performing
Arts Center, Museum Park;
• Government Employment Centers, such as Downtown, Government Center,
Federal Cornplex, Courthouses;
• Retail and wholesale establishments, in Downtown, Bayview Market, Midtown
Miami, Design District; and
• The numerous single and multi -family residential properties.
The Miami Streetcar will also provide improved transit connectivity with the existing elevated
Metrorail and Metromover rail systems, eliminating thousands of daily automobile trips in
Downtown Miami. The project will include modern, electric streetcars running over a fixed rail line
within the street travel lanes. The service is expected to run at 10 minute intervals.
SMART COMMUTE INITIAVE39
Miami -Dade County has developed the Smart Commute Initiative that encourages residents to
purchase a home in Miaini-Dade County, including within the City of Miami, near public transit and
use rail or other local public transit to commute to work.
38 City of Miami. http://www.miamigay.com/MiamiStreetcar
39 Miami -Dade County. People's 'Transportation Plan. http://www.miamidade.gov/trafficrelief/smart_commute.asp
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 39
The Smart Commute Initiative addresses the link between housing affordability and transportation
costs, and recognizes that homeowners who spend less on commuting expenses (by reducing or
eliminating the expense and upkeep of .a personal vehicle) can put the potential savings toward the
purchase of a home. If home buyers choose a home near rail/people mover or bus service, the
Initiative allows lenders to add a portion of the potential commuting savings to their qualifying
income required for the loan which could increase home -buying power. The initiative provides
down payments as low as $500 or 1 percent of the loan amount, which ever is less, for eligible
borrowers, Borrowers under the Smart Commute Initiative will receive a free monthly transit pass
per household for a period not to exceed one-year.
MIAMI DOWNTOWN TRANSPORTATION MASTER PLAN44
Completed in 2003, the Miami Downtown Transportation Master Plan (DTMP) is a comprehensive
study of transportation options fox Downtown Miami. The study will serve as a guide for the City of
Miami and its transportation planning partners to plan for the City's future Downtown
transportation system, be a tool for city planners to use to evaluate project proposals at operational
levels of detail, and to allow periodic updates to the Transportation Master Plan as decisions affecting
Downtown Miami are made and new development occurs. In short, the DTMP is intended to be a
guide for implementing improvements to Downtown Miami's transportation system that will develop
an economically stronger, more sustainable, and much more livable city. The study was funded by
the City of Miami, the Miami -Dade Metropolitan Planning Organization (MPO), and the Florida
Department of Transportation (FDOT).
OTHER RELEVANT STUDIES AND CITY INITIATIVES
FEC CORRIDOR/MID-TOWN MIAMI 41
The Florida East Coast (FEC) Corridor is an inner-city area of the City of Miami consisting of over
2000 acres. This corridor is comprised of a mix of industrial, warehouse, commercial and residential
uses with a significant number of vacant parcels and underutilized buildings. The Corridor was the
subject of a redevelopment study, "FEC Corridor Strategic Redevelopment Plan," and was the
product of a one-year community planning process that focused on facilitating economic
revitalization opportunities within the corridor and its surrounding neighborhoods. The plan was
developed under the hospice of the City's Economic Development Department and was shaped by
certain "guiding principles" which included the:
1, Need to create a diverse and sustainable economy;
2. Vision of an urban -scale, mixed use redevelopment pattern;
3. Need for a balanced and integrated transportation system; and
4. Development of a spectrum of housing choice and opportunity.
In particular, the plan recommends five Housing Implementation Strategies and accompanying
action steps. The implementation strategies include: 1) Using the proposed zoning changes as a
"planning tool" for housing choice, 2) Removing existing barriers to infill housing development and
411 Miami -Dade MPO websitc: http://www.miannidade.gov/mpo/mpo7-study-mdtmp.htm
41 City of Miami Economic Development website: http://www.miamigov.com/economicdevelopment
2005 — 2010 City of -Miami Analysis of Impediments to Fair Housing Choice Page 40
housing rehabilitation, 3) Targeting existing community development and housing resources to the
FEC Corridor including the development of a Model Block program, and 4) Creating new housing
financing mechanisms.
The center piece of the FEC redevelopment plan was the Buena Vista Yards which consisted of 56
acres of vacant land that was formerly owned by the FEC Railway. The land was purchased in 2002
by developers who have worked closely with the City of Miami and Miami -Dade County to fund
public improvements. Once finished, the project will consist of two major components: The Shops
at Midtown (retail) and Midtown Miarni (residential), providing approximately 600,000 square feet of
retail space, 3,000 condo lofts and 350 apartment units. It will have an estimated development value
of $1,2 billion and will generate an estimated 1,700 permanent jobs.
2004 — 2009 CITY OF MIAMI CONSOLIDATED PLAN 42
The Five Year Consolidated Plan is the document submitted to the U.S. Department of Housing and
Urban Development (HUD) that serves as the planning tool for jurisdictions funded, under the
Community Planning and Development (CPD) formula to include grant programs. The formula
grant programs guided by the Consolidated Plan consist of the following: Community Development
Block Grant (CDBG), Home Investment Partnership (HOME), Housing Opportunities for Persons
with AIDS (I iOPWA) and the Emergency Shelter Grant (ESG) program.
The City of Miami 2004-2009 Consolidated Plan calls for a two tiered approach to community
development. Under this system, the City will target distressed neighborhoods within the jurisdiction
which are in most need of assistance, known as Neighborhood Development Zones (NDZs), The
NDZ concept is a comprehensive long-term approach to community revitalization that focuses on
community assets as a means of stimulating market driven redevelopment. It is a holistic approach
that calls for sustained, multiyear commitments from local governments, the private sector,
foundations, and community based organizations. The following is a list of the NDZs: Allapattah,
Coconut Grove, Edison/Little River/Little Haiti, East Little Havana, West Little Havana, Model
City, Overtown, and Wynwood.
Within each NDZ, the City will identify Model Blocks that are poised for revitalization. Model
Blocks are small geographic areas with no more than 1,000 housing units. Each Model Block is also
in close proximity to a commercial corridor (Community Business Corridor or CRCs). Over the
course of the next five years, the City will concentrate resources for housing, public infrastructure
improvements, slum and blight removal in these small geographic areas. The Community Business
Corridors will serve as target areas for economic development activities. The goal will be to provide a
visible and concentrated neighborhood revitalization initiative that can serve as a catalyst for private
investment and change in the Neighborhood Development Zones -Specifically, the City will seek to
accomplish the following in the Model Blocks-
■ Create physical improvements through infrastructure improvements, streetscape
improvements, code enforcement, and removal of slum and blight;
• Improve housing conditions by targeting rehabilitation and new construction
assistance in the Model Block area;
• Stimulate economic development through facade improvements and other forms of
targeted business assistance in the CBCs; and
42 City of Miami Community Development Department, "2004-2005 City of Miami Consolidated Plan." Website:
http:// tww,ci.ntiami.f1 us/communitydevelopment/ConPlan/index.htm
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 41
• Improve the living condition of residents in the Model Block by targeting social
service assistance
The Consolidated Plan identified that the top priority for the City of Miami within the next five years
will be to preserve affordable housing and stimulate neighborhood revitalization. Informed by the
Plan's findings in the Housing Needs Assessment and the Housing Market Analysis, the City has
adopted a four -tiered investment strategy that focuses on: 1) Preserving affordable rental housing for
those most in need of housing assistance; 2) Assisting existing homeowners to retain and maintain
their homes through rehab assistance; 3) Preserving affordable homeownership opportunities for
working families who may be eligible for homeownership but may be priced out of the market due to
the escalating cost of real estate; and 4) Stimulating affordable housing development through the
creation of a land acquisition program and other incentives.
ACCESS MIAMI
(ASSETS • CAPITAL • COMMUNITY • EDUCATION • SAVINGS • SUCCESS)
ACCESS Miami is a comprehensive, citywide initiative aimed at increasing residents' access to the
financial tools that are fundamental to economic prosperity and success. By increasing access to
educational and financial resources while harnessing the strength of community assets, City residents
will have increased opportunity to build wealth, improve financial literacy and save for the future.
ACCESS Miami incorporates resources from the public and private sectors, participation from
community -based organizations and dedication from the residents themselves. By focusing on asset
accumulation, access to capital and community -building, ACCESS Miami creates a comprehensive
financial growth strategy rooted in education and savings that promotes economic prosperity for all
City residents.
ACCESS Miami is an effort to consolidate the Mayor's Anti -Poverty initiative campaign efforts
under one umbrella. In September 2002, the Mayor launched a citywide Poverty Initiative campaign
allocating $2 million for poverty -reduction programs. This unprecedented use of general fund
resources was a direct attempt to help improve the standard of living for working families residing in
the City of Miami. The Goal's of the Mayor's Anti -Poverty Initiative are as follows:
• Economic development activities that generate living wage jobs and community
sustainability;
• Access to a variety of housing options that promote family and community stability;
• A comprehensive financial education system that prepares citizens for participation
in the economic and social fabric of the community; and
• Coordinate Community --based services that nurture and support young people and
their families.
MIAMI COMPREHENSIVE NEIGHBORHOOD PLAN 43
The City adopted the Miami Comprehensive Neighborhood Plan (MCNP) in 1989, a plan that
provides the goals, objectives, and polices for the City's existing and future development. The latest
version of the plan is dated 2004 and was revised by the City of Miami's Planning Department in the
2005 Evaluation and Appraisal Report (EAR). Below are the plan's goals as they relate to furthering
4.3 City of Miami Planning Department. "Miami Comprehensive Neighborhood Plan." August 2004 and "The 2005 Evaluation and
Appraisal Report of the Miami Comprehensive Plan." March 2005
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 42
fair housing choice (Changes to the goals identified in the EAR are made in the footnotes). See
Attachment 2 for a list of the goals and policies as they relate to furthering fair housing choice.
FUTURE LAND USL
■ Goal LU-1: Maintain a land use pattern that (1) protects and enhances the quality of
life in the city's residential neighborhoods; (2) fosters redevelopment and
revitalization of blighted or declining areas; (3) promotes and facilitates economic
development and the growth of job opportunities in the city; (4) fosters the growth
and development of downtown as a regional center of domestic and international
commerce, culture and entertainment; (5) promotes the efficient use of land and
minimizes land use conflicts; and (6) protects and conserves the city's significant
natural and coastal resources,44
• Goal LU -3: Encourage urban redevelopment in identified Urban Infill Areas and
Urban Redevelopment Areas.
!MOUSING
■ Goal HO-1: Increase the supply of safe, affordable and sanitary housing for low and
moderate income households and the elderly by alleviating shortages of low and
moderate income housing, rehabilitating older homes, maintaining, and revitalizing
residential neighborhoods.45
■ Goal HO-2: Achieve a livable city center with a variety of urban housing types for
persons of all income levels.46
TRANSPORTATION
• Goal TR-1: Maintain an effective and cost efficient traffic circulation network
within the City of Miami that provides transportation for all persons and facilitates
commercial activity, and which is consistent with, and furthers, neighborhood plans,
supports economic development, conserves energy, and protects and enhances the
natural environment.
The EAR is a state -mandated evaluation and update of the MCNP that is required every seven years.
It suggests how the MCNP should be revised to better address community objectives, changing
conditions and trends affecting the community, and to changes in state requirements regarding
growth management.
The City initiated its EAR process in 2004 with an extensive community involvement effort. Based
on input received via this process, the City of Miami identified four major issues: 1) The need for,
and impacts of, equitable redevelopment and development; 2) Preservation and enhancement of
natural, historic, archeological and recreational resources; 3) Neighborhood integrity; and 4)
44 EAR Recommendation LU-1. Amend Goal LU-1 to remove the word "residential" before "neighborhoods", and to call for protecting
the integrity and quality of the City's existing neighborhoods.
45 EAR Recommendation 110-1. Amend Goal I-IO-1 to also call for encouraging middle income housing, and for encourage a range of
housing types in all areas of the City to meet the needs of all income groups.
46 EAR Recommendation I-I0-19. Amend Goal HO-2 and Objective HO.2.1 to call for a variety of housing types for all income levels
provided in a wall:able, mixed -use urban environment.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 43
Transportation. Recommendations for issues one, two, and four in particular will impact the City's
mission to affirmatively furthering fair housing choice.
The EAR discussed many of the issues that have affected and continue to affect affirmatively
furthering fair housing choice in the City. In particular, that lack of affordable housing in the City of
Miami that has been exasperated in the past few years due to the unprecedented wave of
development and redevelopment that is rapidly changing the urban environment. The report
identified a number of factors which have contributed to this trend, including 1) the diminishing land
supply in the City, County and region, 2) the efforts to redirect growth and development to the urban
core, and 3) the development community's realization that there is a strong demand for alternatives
to suburban living. The trends discussed in the EAR that are relevant to the Al are summarized
below:
• The City has a limited stock of vacant and developable land (556acres). This stock
tends to be small scattered sites. Because of its substantially built -out status, the
City's greatest development potential will occur as mid to high rise redevelopment.
The EAR defines redevelopment as the "construction of a building or facility on a
parcel of land that was or is being utilized for another use, or for the same use but at
a different intensity. Redevelopment may also entail the adaptive reuse of an
existing building for a new purpose."
• The unprecedented scale of development has significant implications for the City's
population and quality of life. At the time the EAR was written, there were 28,813
large scale development projects of new residential units either under construction
or approved for development, with another 18,198 in the application process or in
the preliminary stages.
• To accommodate the heightened scale of development, a number of infrastructure
improvements and public service expansions will be necessary to maintain adopted
levels of service standards, including transportation improvements, the provision of
additional parks, and increased water and sewer capacity.
■ Mixed -use development patterns and increased transit services will be necessary to
accommodate increased transportation demand and reduce automobile dependence.
■ As housing costs rise in these redeveloped neighborhoods, the existing low and
moderate residents may no longer be able to afford their units, and are therefore
displaced.
• Transportation issues include, but were not limited to: the need for amenities to
attract more trips to alternative modes of transportation; better coordinate
transportation and land use needs, and transportation problems (i.e. congestion,
negative impacts on neighborhoods) need to be addressed. Policy changes are
recommended to create incentives to encourage the use of alternative modes of
transportation. The provision of an increased range of mobility alternatives would
increase the access of transportation disadvantaged persons and households to
employment and services, with associated positive economic and social benefits.
MIAMI 21
The City will be revamping its land use and zoning policies due to the dramatic transformation the
City is undergoing with respect to population growth and real estate development. The challenges
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 44
brought by this development were the impetus for the City to recently launch a new master planning
process dubbed "Miami 21." The City of Miami Planning Department will be responsible for
executing the initiative, According to the Planning Department, Miami 21 will be a smart growth
and holistic approach to land use and urban planning that will provide the City with a clear vision
and specific guidelines and regulations. "Miami 21 will take into account all of the integral factors
that will make each area within the City a unique, vibrant place to live, learn, work and play. Six
elements, in particular, will serve as the lynchpins in the development of the blueprint: Form -Based
Code, Economic Development, Transportation, Parks & Public Realm, Arts & Culture, and Historic
Preservation."47
With respect to affirmatively furthering fair housing choice, Miami 21 seeks to incentivize affordable
housing development by planning to:
1. Evaluate strategies such as infill planning and inclusionary zoning;
2. Encourage the development of a diverse housing mix (including affordable housing) that will
meet the housing demand of all residents;
3. Compliment current efforts to increase production of affordable housing units in the City of
Miami; and
4. Encourage the redevelopment and revitalization of previously underserved neighborhoods in
order to avoid gentrification.48
47 City of Miami Planning Department. "Miami 21" http://www.ci.miami.fl.us/planning/pages/miami21/
48 Ibid.
2005 -- 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 45
LEGAL STATUS EVALUATION
CURRENT FAIR HOUSING LEGAL STATUS EVALUATION
FAIR HOUSING COMPLAINTS AND COMPLIANCE
Two agencies, the Housing Opportunities for Excellence, Inc (HOPE) and the Miami -Dade County
Equal Opportunity Board, report they receive and process fair housing complaints in the City of
Miami. The local HUD office also processes fair housing complaints but could not provide statistics
before the publication of this report.
Since the last AI, the City of Miami Department of Community Development administered three six-
month contracts in 2002, 2003, and 2004 with HOPE to provide a citywide fair housing program.
HOPE is a private fair housing not -for -profit organization dedicated to eliminating housing
discrimination and promoting fair housing in South Florida, HOPE employs a three -tiered system of
private enforcement, education outreach and counseling to achieve its mission to affirmatively
further fair housing. Its programs are designed to ensure that residents, including those living in the
City of Miami, are offered the right to select housing of their choice without discrimination based on
race, religion, color, national origin, sex, disability, marital or familial status, or such other protected
classes as may be conferred by federal, state or local laws.
The Miami -Dade County Equal Opportunity Board (IVIDCEOB) is a quasi-judicial as well as an
advisory board charged with the enforcement of Miami -Dade County's (including all the
municipalities within the County) civil and human rights ordinance, Chapter 11A, of the Miami -Dade
County Code. The MDCEOB's mission is to combat discrimination in housing and other various
areas such as public accommodations, credit, and financing practices. The MDCEOB received fair
housing claims and provides enforcement by conducting investigations into allegations of housing
discrimination. An investigation may entail taking testimonies, inspecting documents, and site
visitations to the respondent's facilities. If discrimination was determined and a settlement cannot be
attained through mediation, then the chairperson, with the approval of a quorum of the members of
the board, issues an adjudicative final order including, but not limited to: 1) Taking affirmative action,
2) Requiring reasonable accommodations, 3) Awarding costs and attorney's fees to prevailing party;
and 4) Awarding other quantifiable relief to prevailing complainant for injures incurred as a result of
an act prohibited by Chapter 11A.
COMPLAINTS
In fiscal year 2003, HUD reported that individuals filed nearly 8,100 discrimination complaints,49
HUD estimates, however, that the number of complaints received comprise only a small percentage
of actual incidences of housing -related discrimination. Furthermore, HUD research suggests that
more than 80 percent of people discriminated against fail to report the incident. It is safe to assume
that fair housing complaints have also been underreported in the City of Miami (approximately a
total of 127 complaints were made in 2003 by City residents). The data below should serve as an
indicator of the types of discrimination that may be occurring in the City and, therefore, not be
considered a comprehensive analysis.
49 News release: "As US Marks 3(" Anniversary of Fair Housing Act, HUD Says I -lousing Discrimination is Underreported by Victims."
April 21, 2004. www.hud.gov
2005 -- 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 46
According to HOPE, there were a total of 107 fair housing inquiries made to their organization that
originated within the City of Miami between September 2003 and October 2004. Of the 107
inquiries, 51 (47 percent) filed a fair housing complaint. The basis upon which the complaints were
filed are as follows: race (56 percent), national origin (22 percent), disability (19 percent), and other (3
percent).
Figure 5: Total Complaints Filed with HOPE, 2003-2004 (Source: HOPE, Inc.)
National Origin
22%
Other
3%
Race
56%
It is difficult to compare the number of complaints reported in the last AI since a total was provided
for a 4-year period (1998-2002); the new statistics provided in this report if for one year (2002-2003).
However, a trend is still evident when past trends are analyzed. In particular, the data reveals that
discrimination on the basis of race remains the most common basis of housing discrimination
complained about in the City of Miami and is a patterns that is consistent nationally; 37.6 percent
from 1993-1995, 54.25 percent from 1998-2002, and 56 percent from 2003-2004. Of the data
collected by HOPE, the number of complaints of discrimination based on national origin (22
percent) and disability (19 percent) still are more significant in the City of Miami than complaints
filed by the other protected classes (i.e. familial status).
Due to the long-time trend of racial discrimination complaints, it is important to understand the
breakdown of the race and ethnicity of the individuals who filed the complaints with HOPE. It is
important to keep in mind that the following includes all individuals that filed a fair housing
complaint with HOPE, not just the ones that filed a racial discrimination compliant. Over a one-year
period, the majority of the fair housing complaints originated from Blacks (53 percent); Hispanics,
Whites, and Asians followed respectively with 28 percent, 16 percent, and 3 percent.
As stated earlier, MDCEOB also collects fair housing complaints. The data was provided by zip
codes from which the complaints originating in the City of Miami were gleaned by selecting the zip
codes that are wholly or mostly lie within the City's jurisdiction (For a list of the City's zip codes,
please sec Attachment 1). In total, there were 21 complaints from fiscal years 2003, 2004, and
partially from the current year, 2005; of these, the majority were reported in 2003 (10 complaints).
Though the total number of complaints for the three years is small, there are a few pockets of
concentration in zip codes 33138, 33136, and 33145; while a total of 9 zip codes did not report any
fair housing complaints.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 47
Disability, marital status (including familial status), and race were mentioned most often as the basis
of the complaint (6 times each). The issues most often complained about were the terms and
conditions (8 tunes), evictions (6 times), and harassment (4 times). In terms of the disposition of the
complaints, there are an equal number of open cases as those which no cause was found (6 times
each); Settleinents were also common either through mediation or the withdrawal of the complaint.
Table 12: Total Complaints Filed with MDCEOB, 2003 — 2005 (to date)
Zip FY
Code Year Basis Issue(s) Disposition
33125 2004 Income & Disabled Deiced Application Open
33125 2005 Income Rent Increase No Cause
33128 2003 Race & Disabled Eviction No Cause
33130 2003 Marital Status Terms & Conditions Withdrawal
33133 2005 Race Harassment Open
33134 2003 Religion Eviction Withdrawal
33134 2004 Familial Status Harassment Open
33136 2003 Race Terms & Conditions No Cause
33136 2003 Age & Disability Terms & Conditions FTC*
33136 2004 Retaliation Harassment Open
33137 2005 Disability, Age, Race, Income Eviction Open
33138 2003 National Origin Eviction No Cause
33138 2004 Disability Accommodation Settled/Mediation
33138 2004 Race & Marital Status Terms & Conditions Settled/Mediation
33138 2005 Race & Income Eviction Open
33142 2004 Retaliation Terms & Conditions WD/S**
33144 2003 National Origin Eviction FTC*
33145 2003 National Origin & Marital Status Harassment No Cause
33145 2003 Marital Status Terms & Conditions No Cause
33145 2004 Age & Marital Status Terms & Conditions Settled/Mediation
33150 2003 Disability Terms & Conditions WD/S**
Source: Based on data provided by the Miami -Dade County Equal Opportunity Board. Note: No complaints were
reported in Zip Codes: 33126, 33127, 33129, 33131, 33132, 33135, 33146, 33147, and 33149
*FTC -Failure to cooperate with investigation (charging party files case but fails to respond to agency requests)
* * WDIS-Charging party withdraws charge as a result of settlement
COMPLIANCE
The following section provides information outlining the actions taken since the last AI to address
the fair housing complaints identified in the City of Miami.
TESTING EVIDENCE
.NCE
The table below lists the test conducted by HOPE within the City of Miami. There were a total of
seven tests carried out from August 2003 to August 2004. Of these tests, the most common issue
was lending.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 48
Table 13: Fair Housing Tests Conducted in the Cite ofMiami, 2003 - 2004
Site Name
Airport Paradise
Miami Stadium
City National
Colonial Bank
Helm Bank
American Express Bank
Site Address
5180 NW 7th Street
2625 NW loth Avenue
25 West Flagler
1200 Brickell Avenue
1200 Brickell Avenue
1221 Brickell Avenue
Delta National Bank 1221 Brickell Avenue
Source, Information provided by HOPE, Inc.
EDUCATION AND OU'I'REACI-I
Issue Projected Basis
Rental
Rental
Lending
Lending
Lending
Lending
Lending
Familial Status
Familial Status
Disability
Disability
Disability
Disability
Disability
Date
August 2003
July 2003
August 2004
August 2004
August 2004
July 2004
August 2004
Tables 14 and 15 at the end of this chapter provide detailed information outlining the educational
and outreach activities taken to respond to the fair housing complaints filed by the City of Miami's
residents. The services previously funded by the contracts with HOPE include a citywide Fair
Housing and Education Initiative that is designed to inform the general public, community groups,
and special needs populations about the rights conferred by the federal, state, and local fair housing
laws. Fair housing workshops were developed that specialized in educating the residents about fair
housing laws, how to recognize discriminatory housing practices, and the resources available to them
to address the problems. The initiative benefits persons that are denied access to housing of their
choice due to race, color, religion, national origin, sex, disability, familial status, age, marital status, or
sexual orientation.
Specialized workshops for housing providers, including Community Development Block Grants
(CDBG)/Home Investment Partnerships Program (HOME) funded Community Development
Corpotations (CDCs) and Community Development Housing Organizations (CHDOs), have also
been provided through HOPE. The workshops promote compliance with fair housing laws and
affirmative marketing requirements. Through its past contracts with HOPE, the City of Miami has
also provided individualized technical assistance in affirmative marketing and the adoption of fair
housing policies to all of its CDBG/HOME funded CDCs and CHDOs. Past contracts with HOPE
have also funded an on -going media campaign for City residents. This campaign used Public Service
Announcements, feature articles and community affair programs. A quarterly fair housing newsletter
has been disseminated that highlights national, state, and local fair housing news.
DISCRIMINATION SUITS FILED
Upon consulting with HOPE, Legal Services of Greater Miami, Inc. (LSGMI)54, and the Florida
Justice Institute, Inc. (FJI)51, no fair housing cases could be identified that have been litigated in the
City of Miami since the last AI. None of the litigation cases listed in the pervious AI originated from
residents within the City's jurisdiction.
5° LSGMI is a non-profit corporation established to serve the legal needs of low-income persons in Miami -Dade County.
51 FJ1 is a non-profit corporation public law organization that specializes in human rights case and implements a [-lousing Discrimination
Project to combat discriminatory housing practices in Florida.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 49
Table 14: Fair Housing Education and Outreach Activities, 2004
MAY 2004 — SEPTEMBER 2004
Impediments & Goals
Fair Housing Activities
Action
Measurable Results
IMPEDIMENT 1: City officials may not be
sufficiently familiar with the fair housing
laws and how those laws affect (or should
affect) the performance of their duties.
GOAL 1: Ensure that City of Miami Staff is
sufficiently familiar with the fair housing
laws and how those laws affect (or should
affect) the performance of their duties.
IMPEDIMENT 2: Discrimination on the
basis of race/color, national origin, family
status and disability.
GOAL 2: Decrease in the level of illegal
housing discrimination in the City of Miami.
la) Identified categories of City
employees, including City officials, for
whom fair housing training should be
mandatory and provided optional fair
housing training for all remaining City
employees.
2a) Ptovided fair housing education and
training to housing providers to ensure
compliance with the fair housing laws.
2b) Provided fair housing education for
the community to help housing
consumers identify and challenge housing
discrimination.
2c) Disseminated a fair housing media
campaign utilizing PSA in local
TV/newspapers, local municipal TV
channels highlighting national, statewide,
and local fair housing news /information.
Created and disbursed promotional items
to advertise fair housing efforts
la) Provided training, on fair housing laws,
prohibited actions in an effort to provide
greater assistance to victims of
discrimination.
2a) Identified housing providers to provide
training and education of fair housing laws
and prohibited actions.
2b) 15 Fair housing workshops presented for
3 target audiences: community based
organizations, disability advocacy groups,
local housing industry
Participated in community and housing faits.
2c) Promotional products created, such as:
magnets, pens, bags to distribute to the
community to market fair housing. Identified
and provided local media T.V., print and
radio mediums, including Miami -TV, to air
public service announcements.
1a) 3 trainings conducted specifically for
City of Miami employees from the NET
Offices. Documentation of meetings,
attendees available.
2a) 1 training conducted for local housing
providers. Materials, agendas and
attendance rosters available.
2b) 28 Fair housing presentations
conducted for community agencies,
disability advocacy groups and local
housing industry. Attendance rosters and
agendas available (includes above
mentioned training for provider).
Participated in 3 housing fairs.
2c) Promotional products created and
purchased including: pens, chip clips,
bags and magnets advertising fair housing
efforts and contact information for help.
PSA provided to City of Miami for airing.
Table continued on the following page.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice
Page 50
Table continued from the precious page.
MAY2004 — SEPTEMBER 2004
Impediments & Goals
Fair Housing Activities
Action
Measurable .Results
Continued.
IMPEDIMENT 2: Discrimination on the
basis of race/color, national origin, family
status and disability_
GOAL 2: Decrease in the level of illegal
housing discrimination in the City of Miami.
2d) Operated a housing discrimination
Hotline to enforce instances of housing
discrimination
2d) A phone line to be monitored specifically
for the intake of complaints from the public
of housing discrimination
2d) The phone line (305-651-HOPE)
received 70 housing intakes from the city
of Miami, 35 of which were referred to
outside agencies.
IMPEDIMENT 3: Disparities in fair and
equal lending in predominantly Hispanic
and Non -Hispanic Black minority areas_
GOAL 3: Educate community members and
homeowners about their rights to fair
lending.
3a) Implemented a publicity campaign to
make residents aware of various loan
opportunities. A variety of outreach
efforts were utilized to reach targeted
audiences. Brochures and other
educational materials (in English,
Spanish, and Creole) were be produced
and distributed. Door-to-door canvassing
was conducted using volunteers.
3a) Produce marketing materials (brochures)
in English and Spanish and distribute by way
of community presentations and housing
fairs in the City of Miami. Community
canvassing of predatory lending materials in
targeted areas with the City of Miami was
implemented.
3a) Produced a bilingual predatory
lending marketing piece. 3 presentations
made to homebuyer groups about
predatory lending. Participated in 3
community fairs to educate about the
dangers predatory lending- Agendas and
sign in sheets of presentations and
number of participants available.
IMPEDIMENT 4: Advertising practices in
Miami -Dade County fail to emphasize
availability of housing on an equal basis and
to encourage housing choice.
GOAL 4: Decrease the amount of illegal
housing discrimination based on the
protected groups through the use of
advertising.
4a) Provided community members with
up -to date information on fair housing.
4a) Created and distributed a fair housing
newsletter informing residents of the City of
Miami, government officials and providers
about fair housing.
4a) Published 2 fair housing newsletters
during the 2 quarters of the contract
period_ Documentation of where and to
whom newsletters were distributed is
available.
Source: Information provided by HOPE, Inc.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice
Page 51
Table 75: Fair Housing Education and Outreach Activities, 2003
JULY- DECEMBER 2003
Media Awareness Campaign
HOPE has continued to monitor the
following newspapers, apartment magazines
and books for housing discrimination and
prohibition advertisement.
• The Apartment For Rent
• Senior Outlook
• The Miami Herald
• Homes By -Owner
• The New Times
• Harmon Homes
• Casas Harmon South Florida
• Colcwell Banker Real Estate Buyer's
Guide
• Greater Miami Apartment Guide
• The Flyer
• For Rent Magazine
• South Florida Senior Outlook
• El Flyer
• New Times
• El Clarin
• Apartment Magazine and Street
• Para Rentar
HOPE placed educational advertisement in
the Apartment Guide.
Educational Outreach
The following organizations received educational
materials:
• APHEC International, Inc
• Department of Human Services
• Mother's Voices
• Gay & Lesbian Foundation of S.FI.
• Prideline Youth Services
• League Against AIDS
• _James E. Scott Community Association, Inc. OESCA)
• Greater New Bethel Missionary Baptist Church
• Economic Opportunity Family Health Center, Alpha
Program
• YMCA
• Economic Opportunity Family Health Center
• Salvation Army
• Fresh Start Drop -In Center, Inc.
• Centro Comunitano Hispano
• Bay -view Center for Mental Health
- South Beach Aids Project
• Shelbourne House
• Help From the Heart Foundation
• National Alliance to Nurture the Aged and the Youth
(NANAY)
- HEP-C Alert
• Center for Positive Connections
• Stop Hunger, Inc.
• Aspita of Florida
• Food for Life Network
• Jewish Community Services
• Haitian Organization of Women, Inc.
• GALATA H.C.E.S.E., Inc.
• Coalition of Florida Farmworker Organizations
• Women United in justice, Education and Reform, Inc.
(M.U.J.E.R., Inc.)
Helpline and
Counseling Services
The H.O.P.E., Inc.
helpline continues to
serve as the screening
arm of the agency's
Private Enforcement
Housing
Discrimination
Initiative.
13 complaints and 1
referral for persons in
the City of Miami
• December
1 complaint and
3 referrals.
• November.
2 complaints
• October:
3 complaints
• September:
4 complaints
• August:
1 complaint
• July:
2 complaints
Presentations, Workshops, Trainings and Fairs
Fair Housing Education:
• Tester Training x
• Group Mobility Counseling for Mobility Pool
Members (33 secessions)
Fair Housing and Disability Workshops:
• 1 secession for AYUDA's Family Empowerment
Program & Parents Now Program
• 2 secessions for Villa Esperanza
(English & Spanish)
Fair Housing Training for Property Managers:
• Dominum Management
• Miami Stadium Apartments
Fair Housing Education & Predatory Lending
• US HUD Homeownership Fair
• Universal Truth Home Now Program
CNC Management: Property Owners and Managers
Training
Fair Housing and Disability Workshop:
AYUDA
Fair Housing and Disability Presentations:
• APHEC International., Inc
• Department of Human Services
• Mother's Voices
• Gay & Lesbian Foundation of S. Ft
• Pndeline Youth Services
• League Against AIDS
• YMCA
•
Fair Housing and Disability Presentation
• James E. Scott Community Association, Inc.
• Greater New Bethel Missionary Baptist Church
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice
Page 52
• Haitian Women of Miami, Inc.
• Catholic Charities
• AYUDA
• Curley's Hope Relief Food Bank
The following educational materials were available:
Newsletter (15th, 16th & 17'h Edition), H.O.P.E.
Brochure (English, Spanish, Creole), HIV /AIDS
Brochure Disability Brochure, H.O.P.E. Discrimination
(English), Tenants Rights and Responsibilities Brochure
(Spanish)
Source: Information provided by HOPE, Inc.
•
Economic Opportunity Family Health Center
▪ Salvation Army
• Fresh Starr Drop -In Center
• Centro Comunitario Hispano
• Bayview Center for Mental Health
• Help from the Heart Foundation
• Stop Hunger, Inc.
• Jewish Community Services
• Haitian Organization of Women, Inc.
• GALATA H.C.E.S.E., Inc.
• Coalition of Florida Farmworker Organizations
(COFFO)
• Women United in Justice, Education and Reform,
Inc. (M.U.J.E.R., Inc.)
• Haitian Women of Miami, Inc.
• Curley's Hope Relief Food Bank
2005 — 2010 City of Miami Analysis of Irn ediments to Fair Housing Choice
Page 53
CURRENT PROGRAMS
A BRIEF SUMMARY OF CURRENT PROGRAMS AND ACTIVITES
TO AFFIRMATIVELY FUTHER FAIR HOUSING IN THE CITY OF MIAMI
This chapter briefly summarizes the current programs and the activities carried out by the City of
Miami. Both federal and non-federal programs are included in the assessment. Also, it should be
noted that the activities cited in this chapter were identified in the 2004 — 2005 Action Plan and are
currently underway. In addition the programs and activities, this chapter will also states the City's
Affirmative Fair Housing policies, including the outreach to Minority Business Enterprises (MBEs).
PROGRAMS
FEDERALLY FUNDED PROGRAMS
American Dream Downpayment Initiative (ADDI): ADDI will provide downpayment, closing
costs, and rehabilitation assistance to eligible individuals. The amount of ADDI assistance provided
may not exceed $10,000 or six percent of the purchase price of a home, whichever is greater. The
rehabilitation must be completed within one year of the home purchase. Rehabilitation may include,
but is not limited to, the reduction of lead paint hazards and the remediation of other home health
hazards.
Community Development Block Grant Entitlement Program (CDBG): As an enudement City,
Miami receives an annual CDBG grant on a formula basis. The formula takes into account total
population, overcrowding and poverty. CDBG funds must be used for activities that benefit low -
and moderate -income persons. Affordable housing is included among the eligible.
Home Investment Partnerships Program (HOME): The purpose of the HOME Program is to
increase the supply of safe, decent, sanitary, and affordable housing for low and very -low-income
households. HOME also seeks to expand the capacity of nonprofit housing providers through
CHDOs. Jurisdictions can use HOME funds to carry out a wide variety of housing activities for low -
and very low-income families, including:
■ Homebuyer programs, which may include downpayment and closing costs
assistance, construction loans, or loan guarantees for acquisition, rehabilitation, or
new construction
• Rental housing programs, consisting of construction loans, permanent mortgage
loans, bridge loans, or loan guarantees for acquisition, rehabilitation, new
construction, and refinancing
Homeowner rehabilitation programs, including grants, loans, interest subsidies, and
loan guarantees to pay for hard costs, related soft costs, and refinancing expenses
✓ Tenant -Based Rental Assistance (TBRA) to pay for rent, utility costs, security
deposits, and utility deposits
Emergency Shelter Grant Program (ESG): The ESG program is a formula grant program that
allocates monies to improve the quality and number of emergency homeless shelters and related
social services for the homeless. ESG provides a foundation for homeless people to begin moving to
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 54
independent living. The current level of funding is based on the yearly homeless assistance
appropriation, as well as the demand of HUD's other McKinney-Vento Act programs. The City of
Miami does not provide homeless shelters, since this is a function of the County. The City uses ESG
funds to provide outreach services to the homeless.
Housing Opportunities for Persons with AIDS (HOPWA): The City of Miami serves as the
administrator of the formula grant -funded Housing Opportunities for Persons with AIDS
(HOPWA) program for the entire geographical area of Miami -Dade County. The goal and intent of
the local HOPWA Program is to ensure that a continuum of housing options and related housing
services is available to low income persons with acquired immunodeficiency syndrome or related
diseases to prevent homelessness of such individuals and their families. HOPWA funds may be used
for addressing the housing needs of persons with AIDS and their family.
Section 8 Moderate Rehabilitation Program (Rental Assistance): Housing choice vouchers allow
very low-income families to choose and lease or purchase safe, decent, and affordable privately -
owned rental housing. Though the City of Miami does not operate any public housing, it is
responsible for a limited number of Section 8 Tenant Based Assistance. This is a housing choice
voucher program developed to assist eligible low-income families to receive housing assistance
through a rental subsidy that enables tenants to afford standard units.
Section 108 Loan Program: The CDBG Section 108 Loan Guarantee allows CDBG entitlement
communities to use their CDBG funds to guarantee loans/notes for large development projects.
Under this program, the applicant pledges current and future CDBG funds as principal security for a
loan guarantee. Among the eligible activities are: acquiring real property, rehabilitating publicly
owned real property, and housing rehabilitation.
NON -FEDERALLY FUNDED PROGRAMS
State Housing Initiatives Partnership program (SHIP): State Housing Initiatives Partnership is
the first permanently funded state housing program in the nation to provide funds directly to local
governments to increase affordable housing opportunities on a noncompetitive basis. The funds are
used to produce and preserve affordable homeownership and multifamily housing for very low, low
and moderate income families. The City of Miami uses SHIP dollars to fund emergency repairs, new
construction, rehabilitation, down payment and closing cost assistance, impact fees, construction and
gapfinancing, mortgage buy -downs, acquisition of property for affordable housing, matching dollars
for federal housing grants and programs, and homeownership counseling.
ACTIVITIES
City of Miami stated in its FY 2004-2005 Action Plan that the current activities would focus on
implementing policies that advance housing preservation and neighborhood revitalization, with the
overall goal of improving the quality of life of the residents and preserving the social and historic
character of low income neighborhoods threatened by gentrification. Specifically, the focus has been
on the following activities:
• Affordable housing preservation and new construction
• Neighborhood revitalization through the creation of the Model Block concept
• Mixed use/income redevelopment
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PRESERVE AFFORDABLE RENTAL HOUSING ACTIVITIES
In order to preserve affordable rental housing opportunities within the City of Miami, CD has
encouraged the construction of new rental units; The target area has been specifically within the
Model Blocks and Neighborhood Development Zones (NDZs) identified in the 2004-2009
Consolidated Plan. Through this initiative, the City seeks to increase the inventory of affordable
rental housing available to low and moderate income households. As recommended in the Housing
Needs Assessment in the Consolidated Plan, the focus will be on serving those that are most in need
of rental assistance, namely small families and single person households, such as the elderly and
persons with HIV/AIDS. Below is a description of the programs.
Finance Construction of New Rental Units: To increase the inventory of affordable rental
housing in the Model Blocks and the NDZs, the City of Miami has continued to encourage the
construction of new rental units. The City will finance project costs for site development and offer
hard and soft construction financing and permanent financing associated with the development of
affordable housing units.
Continue to Provide Section 8 Rental Housing Assistance: The City of Miami has provided
rental housing assistance to very low income households through the Section 8 Program. This
assistance consists of Project Based and Tenant Based vouchers. The Project Based units are
privately owned buildings. The owners of these rental structures were given moneys to rehabilitate
the buildings in return for securing all the units for very low income residents. Through this program,
very low income residents are able to live in safe, decent, and affordable privately -owned rental
housing.
PRESERVE EXISTING AFFORDABLE HOUSING - HOMEOWNER RETENTION
ACTIVITIES
The City of Miami has focused on providing housing rehabilitation assistance to low and moderate
income households in order to help them maintain and retain their homes and in order to prevent
the existing housing stock from continuing to decline. This is important since there are a substantial
number of the single family homes in the City that fall below minimum housing quality standards
(disrepair) which are owned by low and moderate income homeowners who lack the financial
capacity and/or credit history required to obtain home repair financing from private lenders. Special
outreach is planned to target housing units in the Model Block areas. The goal has been to assist
homeowners with deferred maintenance, emergency repairs, removal of code violations, and
replacement of unsafe structures. Preference has been given to the elderly, disabled and persons with
HIV/AIDS. Below are the specific programs that have been used to implement this policy.
Rehab Existing Homeowner Units and Correct Code Violations: The City of Miami provides
home improvement and rehabilitation assistance to homeowners throughout the City in order to
improve the condition of existing housing stock. Under this rehab program, homeowner(s) that
reside and maintain a property as their principal residence in the City of Miami will be able to obtain
a deferred loan to bring their property to decent, safe and sanitary housing standard, or to correct
existing code violations. Through this program, the City has been able to encourage low to moderate
income owners that have illegal units to bring their properties up to code or to remove the illegal
structures. The Community Development Department plans to continue to work closely with Code
Enforcement to target areas that have a high number of code violations. The intent is to provide
incentives for homeowners to correct code violations.
Emergency Grant Home Repair Assistance: The City has provided deferred payment loan
assistance to an eligible homeowner to carry out limited repairs such as roofing, electrical and
2005 — 2010 City of Miami Analysis of Impediments to Fait Housing Choice Page 56
plumbing to immediately rectify life hazardous and potentially hazardous conditions that threaten the
safety and health of the occupants of the home.
Replace Unsafe Housing Structures: The City has provided assistance to replace dilapidated
owner -occupied housing units which are not suitable for rehabilitation. Funds are used to defray the
cost of temporary relocation expenses, demolition of the dilapidated structure, and soft and hard
construction costs associated with the reconstruction of the new home.
HOMEOWNERSHIP ACTIVITIES
The City of Miami continues to assure that affordable homeownership opportunities are available for
working class and moderate income families who are seeking homeownership opportunities but may
be priced out of the market due to increasing real estate costs. The City plans to continue to seek to
increase the inventory of affordable homeownership units through new construction. In addition, the
City has provided second mortgage, down payment, and closing cost assistance to new homebuyers,
Finally, the City has helped renters to prepare for homeownership by referring them to Homebuyer
Counseling Programs. The following describes the specific programs.
Finance Construction of New Homeownership Units: The City of Miami promotes affordable
homeownership opportunities for low and moderate income families by financing new construction.
The City also provides hard and soft construction financing and permanent financing for affordable
housing units.
Provide Homeownership Financing: To assist homebuyers in the purchase of a home, the City of
Miami provides down payment, closing cost and/or second mortgage Financing assistance to eligible
persons and households who are first time homebuyers. Although this assistance is available to
anyone who wants to purchase a home in the City of Miami, City residents have access to the
maximum allowable subsidy. Residents who are moving into the City will be eligible for assistance,
but at a lower cap.
Provide Homeownership Counseling: Homebuyer counseling is a vital component of any
homeownership program. The City of Miami plans to continue to will work closely with the Miami -
Dade Housing Agency and Greater Miami Local Initiative Support Coalition (LISC) to assure that
families who are interested in homeownership are referred to their Comprehensive Housing
Counseling Program. The goal has been to create a pipeline of qualified buyers who will be able to
purchase a home. The City plans to conduct outreach in the Model Blocks, with the goal of referring
residents to participate in the Comprehensive Housing Counseling Program.
STIMULATE HOUSING DEVELOPMENT — OTHER NON -HUD ACTIVITIES
In addition to the activities listed above, it has been important for the City of Miami to provide
incentives to stimulate housing development. Such incentives help to off -set the barriers that make it
difficult to undertake affordable housing projects. The following is a list of the incentives that the
City of Miami provides in order to facilitate the development of affordable housing.
Tax Credit Assistance/Housing Credit Match: Untapped resources such as the Low -Income
Housing Tax Credit (LITHC) program need to be creatively utilized and combined with private
Financing to create a viable housing production incentive. To this end, the City of Miami plans to
assist developers by providing matching funds and by making sure that the items on the LITHC
application checklist that apply to the jurisdiction are completed promptly.
Affordable Housing Incentives: The City of Miami continues to provide incentives to developers
through the Affordable Housing Incentive Plan. This plan provides developers of affordable housing
2005 -- 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 57
projects with a number of local incentives that are intended to expedite the pre -development process
and reduce certain cost(s) in connection with the production of affordable housing projects in the
City of Miami. The incentives include:
■ Expedited Permitting for Affordable Housing Projects
• Review of Legislation, Policies and Plans that Impact Affordable Housing.
• Impact Fee Wavier / Exemption
• Interim Proprietary and General Services Fee Waiver / Exemption
• Reduction of Parking and Setback Requirements
■ Interim Proprietary and General Services Fee Waiver / Exemption
• The requirements of the plan will be amended to limit incentives to projects that are
located within the Model Block and the NDZ, areas.
Training/Workshops to Developers on City Programs and Regulations: The Community
Development Department plans to work with other City departments and Miami -Dade County to
provide training to developers on the rules and regulations that govern the development process.
Such training may include workshops on the permitting process, zoning, and environmental
clearances.
Increase Capacity of Non-profit Housing Providers: To help improve the capacity of non-profit
housing providers, the City of Miami provides various services intended to assist these organizations.
Specifically, the City provides local government matching for Community Development
Corporations (CDCs) applying for tax credit financing for affordable housing projects. Furthermore,
the City encourages CDCs to partner with private developers by giving developers extra credit points
in their RFP applications if they have a 51 percent partner that is a non-profit.
SPECIAL NEEDS AFFORDABLE HOUSING ACTIVITIES
The City of Miami is committed to assisting persons with special needs and their families obtain
affordable housing. Special needs populations include the elderly, individuals living with HIV/AIDS,
and persons with disabilities who are within the very low to moderate income range. The programs
for special needs populations are described below.
Housing Opportunities for the Elderly: The City continues to provide funds far rehabilitation and
new construction of residence projects that are Section 202 Support Housing.
Housing Opportunities for Families with AIDS through HOPWA: Through HOPWA, the City
of Miami works to expand housing opportunities for county residents that are low to moderate
income and have been diagnosed with HIV/AIDS. Programs include project -based rental subsidies,
the Emergency Rental, Mortgage and Utility Assistance Program, and the Housing Information,
Referral & Advocacy Program. Preference will be given to units that have a mix of residents with
various household incomes.
Homeless Program; The Community Development Department continues its efforts in the
prevention of homelessness by supporting the City of Miami's Homeless Program and its outreach
programs. The City's Homeless Office provides outreach services in the form of referrals for a
myriad of social services, to include behavioral, mental, health, and supportive housing.
2005 — 2010 City of Miami Analysis of Impediments to Fair Housing Choice Page 58
OTHER HOUSING ACTIVITIES
Fair Housing: Fair housing practices are aimed at reducing predatory lending and housing
discrimination. The City will ensure that fair housing laws are enforced and that low income groups,
minorities, and special needs populations are protected against discriminatory practices.
Lead Based Paint Hazards: The City of Miami is committed to significantly reducing lead base
paint hazards and preventing childhood lead poisoning. To this end, the City will, secure the services
of a consulting firm specializing in the reduction and stabilization of lead paint hazards in lower
income neighborhoods. In addition, the City will continue to provide educational pamphlets and
guidelines to all public housing residents informing them of the hazards of lead base poisoning.
Public Housing: Though the City of Miami does not operate any public housing, it is responsible
for a limited number of Section 8 Tenant Based Assistance units. This is a housing choice voucher
program developed to assist eligible low-income families to receive housing assistance through a
rental subsidy that enables tenants to afford standard units. Activities identified in the City's five-year
plan for housing choice vouchers include: 1) Maintain or increase Section 8 lease up rates by
establishing payment standards that will enable families to rent throughout the jurisdiction, 2)
Undertake measures to ensure access to affordable housing among families assisted by the City,
regardless of unit size requirements, 3) Maintain or increase Section 8 lease -up rates by marketing
programs to owners, particularly those outside of minority and poverty concentration, 4) Maintain or
increase Section 8 lease -up rates by effectively screening Section 8 applicants to increase owner
acceptance of the program, 5) Leverage affordable housing resources in the community through the
creation of mixed -finance housing —in particular, the City of Miami will direct CDBG funds towards
housing management support for new construction homeownership projects and will make available
local Surtax funds for rehabilitation of Section 8 multi -family rental projects with predominately
eligible elderly tenants that have met their affordability term requirements, and Affirmatively market
families of races/ethnicities shown to have disproportionate housing needs.
AFFIRMATIVE FAIR HOUSING MARKETING
Pursuant to HUD regulations, 24 CFR 92.351, the City of Miami has adopted affirmative marketing
procedures and requirements for rental and homebuyer projects containing five or more
HOME/CDBG-assisted housing units. Furthermore, the City's policies are consistent with Davis-.
Bacon and Section3 protocols.
Affirmative marketing consists of actions to provide information and otherwise attract eligible
persons in the housing market area to available housing without regard to race, color, national
original, sex, religion, familial status or disability. It should be noted that affirmative marketing
procedures do not apply to families_with Section 8 tenant -based rental housing assistance or families
with tenant -based rental assistance provided with HOME funds.
The City's affirmative marketing policy consists of the following elements:
1. Informing the Public, Owners, and Potential Tenants:
Acceptable methods for informing the public, owners, and potential tenants about the
applicable Federal Fair Housing Laws and HOME Program's affirmative marketing policy
may include, but are not limited to: providing a copy of this policy in all media releases, using
the Equal Opportunity logo and slogan in all media releases, and explaining the policy in
general to the media, property owners, and tenants involved with the HOME Program.
2. Advertising Vacant Units:
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In order to meet the obligations towards the City's affirmative marketing policy
requirements, each property owner should have a policy that clearly specifies or suggests
activities such as the use of commercial media to advertise vacant units, local community
contacts for potential tenants, or the use of the Equal Housing Opportunity logo or slogan.
The policy must clearly define the recordkeeping obligations of the property owners.
With respect to special outreach efforts, the HOME and CDBG recipient(s) shall use the
following procedures to inform and solicit applications for rental units or homeownership
opportunities for persons in the housing market who are least likely to apply, such as
African -American and non -Hispanics.
The Miami Times (mostly African -American readers)
• The Miami Herald (mostly non -Hispanic readers)
• El Nuevo Herald (mostly Hispanic readers)
• Community Newspapers (mostly non -Hispanic readers)
3. Requirements of Owners for Outreach Efforts:
Procedures to be used by the owners to inform and solicit applicants from persons in the
housing market area who are not likely to apply (defined in general as those who are not the
race/ethnicity of the residents of the neighborhoods in which the unit is located). Such
procedures may include, but are not limited to: the use of community organizations,
churches, employment centers, fair housing groups, Public Housing Authorities (PHAs), or
housing counseling agencies specifically chosen because they provide services to, or have as
members, persons on the groups likely to apply. The owner's affirmative marketing policy
should clearly specify who is responsible for the various necessary activities.
4, Recordkeeping:
The City of Miami requires recipients to maintain records that describe efforts taken by the
recipients and by the owners to affirmative market units for a period covered by the
agreement conditions. The City will use those records to assess the results of these actions.
5. Assessment of Affirmative Marketing Efforts of Owners:
All affirmative marketing requirements and procedures shall be applicable for the term of
the agreement and implemented prior to beginning the project or on a case by case basis
given the type of project and plans for rental or sales.
The City of Miami shall ensure compliance of its affirmative marketing requirements with
the owner by use of an agreement (Firm Loan Commitment) that shall be binding for a
specific period of time (affordability period) from the date of completion. To ensure
compliance with affirmative marketing requirements, the City will conduct audits and
interview. The project HOME and CDBG recipient(s) will submit copies of advertisement
for vacant units, correspondence and information, including brochures and leaflets
submitted to community organizations in advertising vacant units. The City will assess the
owner's affirmative marketing plan and the results of these efforts. It will also determine
what corrective actions will be taken when an owner fails to follow these affirmative
marketing efforts.
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