1. The Long Island Foreclosure Crisis
Melville, NY
March 5, 2013
Stabilizing the communities
most impacted by foreclosures
in Nassau and Suffolk Counties
Final March 4 11:00 am

2. Purpose of Analysis
Pinpoint communities affected by ongoing foreclosure crisis, particularly at risk of . . .
lost wealth
lost tax base
destabilization
Lay out strategies to address threats to stability in these communities

3. Today’s presentation will. . .
Start with a summary of “Findings” and “Recommendations”
Map the NY foreclosure crisis, particularly on Long Island
Examine home purchase lending historically and currently
Show overlays of foreclosures, lending and minority communities at zip code and census tract data levels
Identify the hardest hit communities as determined by our “Impact Score”
Conclude with a discussion of three broad strategy recommendations

4. FINDING: Foreclosures are widespread but many communities have disproportionate concentrations
Foreclosures occur in all of Long Island’s cities, towns, villages and hamlets, but . . .
Both Nassau and Suffolk Counties have numerous areas with concentrations of foreclosures -- much higher than the rest of each county.
We especially need to take steps to stabilize these impacted areas

5. FINDING: The most impacted areas have seen reduced lending, threatening economic recovery
The areas that can be identified as “impact areas” from the foreclosure crisis have also seen large declines in home purchase lending from 2006 to 2010.
Although foreclosures have increased the need for more home purchase financing, less financing is available.
The result? A “double-whammy.”

6. FINDING: Foreclosures are disproportionately hurting Long Island’s minority communities
Areas with high foreclosure concentrations and low lending levels are most often areas of high African American and Latino homeownership.
The crisis is not only impacting the households actually in foreclosure, but also the majority of African American and Latino homeowners in each county.
The foreclosure crisis raises a significant threat to “asset wealth” and economic vitality of these minority communities.

7. RECOMMENDATIONS: Limit the damages to communities from concentrated foreclosures by…
Keeping owners in their homes or keeping properties otherwise continuously occupied.
Assuring maintenance of properties in order to preserve the tax base and mitigate damage to municipalities.
Ensuring economic justice for minority communities by acknowledging disparate impact and taking steps to preserve “asset wealth.”

8. Sources of Data Analyzed
NYS Dept. of Financial Services 90-day Pre-Foreclosure Filing Notices (“90-day PFF Notices”)
Home Mortgage Disclosure Act (HMDA) home purchase lending data
From for the charts
From 2006 & 2010 for the maps
2010 Census homeowner data by race and ethnicity
NY Federal Reserve Bank delinquency and foreclosure data
Sales price data from City-Data.com

9. Each Database Separately Provides the
Reliability of Data Sources and Methodology NY Fed and NYS DFS Data are Consistent with Each Other at Zip Code Levels
Each Database Separately Provides the
Same Picture of Areas of Foreclosure Concentrations

10. Current Status of New York’s Foreclosure Crisis
NY is not yet near the end of its foreclosure crisis (differing from other areas of the country)
Our current crisis is due more to economic downturn and loss of income, rather than the housing boom and subprime bust
Foreclosures are slow to make their way through the legal system
Lenders are not triggering settlement conferences, adhering to conference requirements, or prosecuting cases post-settlement conference to judgment and sale

11. Most “90-Day Pre-Foreclosure Filing (PFF) Notices” are Concentrated in New York’s Urban and Population Centers (January – June 2012)
Rochester
Buffalo
Syracuse
Albany
NYC Metro Area and Long Island
90-Day PFF Notice totals are presented by zip code and are calculated from month by month datasets
provided by the New York State Department of Financial Services. Map © Empire Justice Center, 2012.

12. Over 25% of NY Homeowners at Risk of Foreclosure Live on Long Island
159, day PFF Notices were sent in the state in the first half of 2012:
25.7% (40,915) of those were from Long Island:
10.2 % were from Nassau County (16,175)
15.5 % were from Suffolk County (24,740)
27.1% were from New York City
47.2% were from the rest of the state

13. “90-Day PFF Notices” Distribution in the NYC Metro Area, Including Long Island (January – June 2012)
90-Day Notice totals are presented by zip code and are calculated from month by month datasets
provided by the New York State Department of Financial Services. Map © Empire Justice Center, 2012.

14. Long Island Foreclosures: The Most Impacted Areas:
To see the relationship of lending to foreclosures and the impact on minority communities, we’ll first take a look at how declines in lending relate to areas with high numbers of foreclosures.
In the slides that follow, we’ll describe how we use an “impact score”
to identify and rank the areas hardest hit by foreclosures (shown in red) in each county and then compare each zip code’s race and ethnicity demographics.

15. Home Purchase Lending – Current low levels indicate difficulties in absorbing foreclosed properties as they come onto the market
From 2006 to 2011, home purchase lending declined by 60% in Nassau County. . .
and by 70% in Suffolk County

16. Home Purchase Lending Declined Much More in Some Communities Than in Others
Declines occurred in many of the same communities targeted by predatory lenders which resulted in high levels of high-cost or subprime loans.
These communities were disproportionately impacted by the first, as well as the second, wave of foreclosures.
We’ll see this in detail in our comparisons of
Home purchase lending by census tract for 2006 to 2010 in Nassau and Suffolk
Lending declines and the distribution of 90 Day PFF Notices

17. HIGH COST HOME PURCHASE LENDING WAS PREVALENT IN SEVERAL SOUTHWESTERN NASSAU COUNTY COMMUNITIES IN 2006
In parts of central and western Hempstead, over 60% of conventional home purchase loans made were high-cost loans (see circled areas).

18. MANY NASSAU COUNTY COMMUNITIES HAD SUBSTANTIALLY LOWER LEVELS OF HOME PURCHASE LENDING IN 2010 THAN IN 2006
Home purchase lending was between % lower in 2010 than in 2006 in many neighborhoods. Several areas with high levels of high cost lending in 2006 had substantially lower levels of lending (see circled areas).
Green tracts = lending INCREASES.
Red and dark reddish-brown tracts = greatest lending DECREASES.

19. Red and dark reddish-brown = tracts with greatest lending decreases.
Zip codes with high densities of pre-foreclosure notices closely coincide with census tracts having the highest declines in home purchase lending.
Yellow dots are 90-Day PFF Notices dispersed by zip code (one dot = one notice)
Red and dark reddish-brown = tracts with greatest lending decreases.
90-Day Notice totals are presented by zip code and are calculated from month by month datasets
provided by the New York State Department of Financial Services. Map © Empire Justice Center, 2012.

20. A CLOSER LOOK AT SOUTHWEST PORTION OF NASSAU COUNTY
Notice that many of the census tracts showing the greatest
declines in lending are also those with the highest density
of 90-Day PFF Notices.
90-Day Notice totals are presented by zip code and are calculated from month by month datasets
provided by the New York State Department of Financial Services. Map © Empire Justice Center, 2012.

21. TO IDENTIFY THE COMMUNITIES MOST AFFECTED
USING AN
“IMPACT SCORE”
TO IDENTIFY THE COMMUNITIES MOST AFFECTED
You can’t compare the impact on neighborhoods simply by looking at the number of foreclosure notices in a zip code because zip codes vary too much in size and housing types.

22. COMPARING ZIP CODES VOLUME – RATE – CONCENTRATION –
To compare zip codes, we looked at three key factors:
VOLUME –
What was the number of 90 Day PFF notices in the zip code?
RATE –
How many PFF notices were there per 1000 housing units? (looking at owner-occupied units with mortgages)
CONCENTRATION –
How close are the imminent foreclosures to each other?
That is, what is the number of notices per square mile in each zip code?
Using these three factors we derived an
“IMPACT SCORE” for each zip code.
That score gives us an “apples to apples” measure
to compare one zip code to another.

23. Identifying and Describing Disproportionate Impact
In the analysis that follows we apply measures frequently used in disproportionate impact litigation including identification of areas that are
“majority-minority”
-- more than half minority, or
“disproportionately minority”
-- a greater minority population than the county as a whole

24. Nassau County – 11 of the Top 15 ‘Most Impacted’ Areas Are Disproportionately Minority
“Majority-Minority” zip codes are shown in red.
Rank
By Impact Score
Locality
# 90-Day Notices
% of County’s
Notices in Zip Code 1
Hempstead
1034
6.0% 2
Elmont
926
5.4% 3
Roosevelt
506
3.0% 4
Valley Stream (north)
793
4.6% 5
Freeport
903
5.3% 6
Uniondale
579
3.4% 7
Baldwin
730
4.3% 8
Levittown
706
4.1% 9
Westbury
700 10
West Hempstead
441
2.6% 11
Valley Stream (south)
290
1.7% 12
Hicksville
483
2.8% 13
Long Beach
429
2.5% 14
Oceanside
405
2.4% 15
Franklin Square
276
1.6%
TOTAL:
9,201
53.7%
These 15 zip codes, out of all 66 zip codes in the county, account for 53.7% of the 90-Day PFF Notices sent in Nassau County in the first half of 2012.

25. % Owners Who Are Minority
Conversely, only 4 of the 15 Most Impacted Have a Minority Concentration Below that of the County
Rank
By Impact Score
Locality
# 90-Day Notices
% Owners Who Are Minority
[County Overall = 20.7%] 1
Hempstead
1034
79.4% 2
Elmont
926
65.6% 3
Roosevelt
506
94.5% 4
Valley Stream (north)
793
48.6% 5
Freeport
903
54.9% 6
Uniondale
579
81.8% 7
Baldwin
730
40.4% 8
Levittown
706
13.7% 9
Westbury
700
39.0% 10
West Hempstead
441
32.2% 11
Valley Stream (south)
290
27.1% 12
Hicksville
483
22.4% 13
Long Beach
429
8.8% 14
Oceanside
405
7.0% 15
Franklin Square
276
12.4%
TOTAL:
9,201
“Majority-Minority” zip codes are shown in red. :
Zip codes with a minority population below the county’s overall minority percentage (20.7%) are shown with a blue background
– only FOUR of the FIFTEEN most impacted.

26. Rankings are based upon an “Impact Score”
Foreclosures Are A Problem Everywhere With The Top 15 Impacted Areas Mostly in Southern and Southwestern Nassau County
FRANKLIN SQUARE
9. WESTBURY
12. HICKSVILLE
8. LEVITTOWN
2. ELMONT
10. WEST HEMPSTEAD
1. HEMPSTEAD
6. UNIONDALE
3. ROOSEVELT
4. VALLEY STREAM (north)
11. VALLEY STREAM (south)
Rankings are based upon an “Impact Score”
5. FREEPORT
LONG BEACH
7. BALDWIN
OCEANSIDE
Map © Empire Justice Center, 2012.

27. RACE AND ETHNICITY OF ALL COUNTY HOMEOWNERS
Black and
Latino = 14.7%
Nassau County:
White – %
Black – %
Latino – %
Asian – %
Based on 357,412 total homeowners
NASSAU
COUNTY
Black and
Latino = 12.9 %
Suffolk County:
White – %
Black – %
Latino – %
Asian – %
Based on 393,616 total homeowners
SUFFOLK
COUNTY

28. Disparate Impact on Minority Communities
Nassau County –
Disparate Impact on Minority Communities
To identify the areas of minority concentration in relation to the area with the highest impact scores, we’ll switch from this “dot dispersion” map to a map showing the
top 15 impacted areas in red, and add “pies” to show homeownership race and ethnicity .
Least Impacted
2nd Least Impacted
2nd Most Impacted
Most Impacted
Zip Code
Impact Rankings:
Asian, non- Hispanic
White, non-Hispanic
Black, non-Hispanic
Hispanic (any race)
Pie Slices
Legend:

29. Nassau County – Disparate Impact:
Most Notices are in Minority Communities
17, Day PFF Notices were sent in Nassau County in the first half of 2012
15 of 66 zip codes account for 53.7% of those notices
74.5% of all of the county’s Black and Hispanic homeowners reside in those Top 15 most impacted zip codes
In contrast, only 26.8% of the White, non-Hispanic homeowners live in those zip codes

30. Nassau County – Disparate Impact:
“Majority-Minority” Zip Codes Are Impacted the Most
The top six impact areas are also the top six zip codes when ranked by the percentages of minorities in the whole county.
Five of the top six most impacted zip codes are “majority minority”
That’s ALL of the “majority-minority” zip codes in the entire county.
The sixth is nearly a majority-minority zip code (with 48.6% minority).
Four of the top six zip codes are 65% to 94.5% “minority.”
We estimate that nearly 90% (88.8%) of the Black and Latino households in Nassau County that received 90-Day PFF notices live in these six zip codes.

31. Nassau County – Disparate Impact:
Nearly ALL Black Homeowners Live in Impacted Areas
Looking at Black Homeowners alone . . .
87.1% of all Black homeowners in Nassau County live in only 10 of the top 11 impacted zip codes.
In contrast, only 11.9% of the White, non-Hispanic homeowners live in those same ten zip codes.
A Black homeowner is over 7 times more likely than a White, non-Hispanic homeowner to live in one of these ten zip codes.

32. Sales Prices: Foreclosure Impact in Nassau County
The “Majority-Minority” Zip Codes (shown in red) have the greatest declines in prices.
The price decline in Nassau County was only 12% countywide.
All 15 most impacted zip codes saw declines exceeding the county level.
Ten zip codes saw declines over twice that rate.
Zip Code
Post Office Name
% Decline in
Sales Price
[2nd Qtr 2007 to
2nd Qtr 2012]
% Owners Who Are Minority
[County Overall = 20.7%] 1
11550
Hempstead
37.4 %
79.4% 2
11003
Elmont
32.6 %
65.6% 3
11575
Roosevelt
33.6 %
94.5% 4
11580
Valley Stream (north) [48.6% minority]
27.0 %
48.6% 5
11520
Freeport
54.9% 6
11553
Uniondale
38.1 %
81.8% 7
11510
Baldwin
28.8 %
40.4% 8
11756
Levittown
21.6 %
13.7% 9
11590
Westbury
27.2 %
39.0% 10
11552
West Hempstead
23.2 %
32.2% 11
11581
Valley Stream (south)
27.6 %
27.1% 12
11801
Hicksville
21.3 %
22.4% 13
11561
Long Beach
25.5 %
8.8% 14
11572
Oceanside
18.3 %
7.0% 15
11010
Franklin Square
20.2 %
12.4%
Zip Codes with a minority population below the county overall minority percentage are shown with a blue background – generally the smallest declines in sales prices of the top 15.

33. Declines in Sales Prices Parallel Impact Scores, Not Number of Notices
Nassau County –
Declines in Sales Prices Parallel Impact Scores, Not Number of Notices
Number of 90 Day Notices in Zip Code

34. Taking a look at Suffolk County . . .
Distribution of “90-Day PFF Notices” in the NYC Metro Area, including Long Island (January – June 2012)
90-Day Notice totals are presented by zip code and are calculated from month by month datasets
provided by the New York State Department of Financial Services. Map © Empire Justice Center, 2012.

35. The slides that follow identify Suffolk County’s most impacted zip codes and then examine each zip code’s race and ethnicity demographics.
First, we see both Nassau and Suffolk counties. The most impacted zip codes are shown in red, and the next most impacted zip codes shown in a lighter color:
To appreciate the conditions that accompanied the rise in foreclosures we’ll once again take a look at how declines in lending relate to the areas with the highest foreclosure impact . . .

36. HIGH COST HOME PURCHASE LENDING WAS PREVALENT IN SEVERAL SOUTHWESTERN SUFFOLK COUNTY COMMUNITIES IN 2006
In the central parts of the Town of Islip and in two areas of the Town of Babylon, over 60% of the conventional home purchase loans made in 2006 were high-cost loans.

37. Most Suffolk County neighborhoods saw
51-100% fewer home purchase loans in 2010 than in 2006
Only five areas, in green, had the same or more lending in 2010 than in 2006, and only 13 had 1-25% fewer loans. The bright red and dark reddish-brown tracts had the greatest lending DECREASES. Note by the yellow circles that the three areas with high levels of high cost lending in 2006 had dramatically lower levels of lending in 2010.

38. Many Neighborhoods With High Numbers of Foreclosures in Saw Declines in Total Home Purchase Lending
Between 2006 and 2010
Yellow dots are 90-Day PFF Notices dispersed by zip code (one dot = one notice)
High foreclosure zip codes largely coincide with the census tracts with substantial declines in total home purchase lending shown in bright red and dark red.
(The pattern is somewhat less pronounced in the eastern parts of the county).
90-Day PFF Notice totals are presented by zip code and are calculated from month by month datasets provided by the New York State Department of Financial Services. Map © Empire Justice Center, 2012.

39. Also, note the high percentages of Latino Owners in THREE of the
Here the dots show the volume of 90-Day PFF notices in first half of 2012 and the “pies” show the race and ethnicity of the homeowners in each zip code.
There are only three “majority-minority” zip codes in Suffolk County. They score as the top three most impacted zip codes by a significant margin. 1 2
Pie Slice Legend 3 5
Also, note the high percentages of Latino Owners in THREE of the
TOP FIVE zip codes.
Number rankings are based upon an “Impact Score”.

40. Suffolk County – Disparate Impact
ALL ‘Minority’ Zip Codes Are Highly Impacted
To identify the areas of minority concentration in relation to the highest impact areas, we’ll switch from the “dot dispersion” maps to one showing the impacted areas in red and adding “pies” to show homeowner race and ethnicity . . .
Least Impacted
2nd Least Impacted
2nd Most Impacted
Most Impacted
Zip Code
Impact Rankings:
Asian, non- Hispanic
White, non-Hispanic
Black, non-Hispanic
Hispanic (any race)
Pie Slices
Legend: .

41. Suffolk County – Disparate Impact
Half of Minority Owners Are in the 10 Most Impacted Areas
26, Day PFF Notices were sent in Suffolk County in the first half of 2012
10 of 94 zip codes in the county account for
34.5% of those notices
Those “top 10” zip codes (ranked using the race-neutral “impact score”) include:
49.3% of all Black and Hispanic homeowners in the county, but in contrast only
10.9% of the White, non-Hispanic homeowners

42. Suffolk County – Disparate Impact
Top 3 “Minority” = Top 3 Most Impacted
Central Islip, Brentwood and Wyandanch are the only three zip codes in Suffolk County that are “majority minority”
Those three zip codes rank as the TOP THREE most impacted zip codes using the race-neutral “impact score”
Two thirds of all Black and Latino homeowners in Suffolk County live in the top 19 zip codes (out of 94) ranked for foreclosure impact.

43. Suffolk County – Disparate Impact
Black Owners vs. White Owners: 27% vs. 1.5%
Looking at Black Homeowners alone . . .
27% of all Black homeowners in Suffolk County live in the top 3 (out of 94) zip codes
In contrast, only 1.5% of the White, non-Hispanic homeowners live in those same three zip codes
A Black homeowner is 18 times more likely than a White, non-Hispanic homeowner to live in one of these top three impacted areas.

44. Suffolk County –
The 19 Zip Codes (out of all 94) with the greatest foreclosure impact account for nearly half (48.7%) of the 90-Day PFF Notices sent in the first half of 2012:
Rank by
Impact Score
Zip Code
Post Office
Name
# of 90 Day
Notices
% County’s
Notices in Zip 1
11722
Central Islip
931
3.6% 2
11717
Brentwood
1326
5.1% 3
11798
Wyandanch
489
1.9% 4
11967
Shirley
822
3.1% 5
11706
Bay Shore
1354
5.2% 6
11950
Mastic
526
2.0% 7
11951
Mastic Beach
472
1.8% 8
11701
Amityville
555
2.1% 9
11729
Deer Park
581
2.2% 10
11726
Copiague
366
1.4% 11
11763
Medford
714
2.7% 12
11727
Coram
645
2.5% 13
11757
Lindenhurst
804 14
11704
West Babylon 15
11784
Selden
524 16
11772
Patchogue
809 17
11720
Centereach
570 18
11789
Sound Beach
209
0.8% 19
11703
North Babylon
337
1.3%
TOTAL
12,748
48.7%

45. Suffolk County –
The Highest Impact Zip Codes Suffered the Largest Declines in Sales Prices
The price decline in Suffolk County was 20% countywide.
All 19 of the most impacted zip codes saw declines exceeding the county level.
Seven of these zip codes saw declines over twice that amount.
Rank by
Impact Score
Zip Code
Post Office
Name
% Decline in
Sales Price
[2nd Qtr 2007 to
2nd Qtr 2012]
% Owners
Who Are Minority
[County Overall = 15.3%] 1
11722
Central Islip
42.6%
63.0% 2
11717
Brentwood
43.3%
73.9% 3
11798
Wyandanch
66.7%
82.5% 4
11967
Shirley
33.2%
16.4% 5
11706
Bay Shore
31.2%
38.0% 6
11950
Mastic
63.6%
20.4% 7
11951
Mastic Beach
48.7%
15.0% 8
11701
Amityville
40.0%
43.9% 9
11729
Deer Park
25.0%
22.0% 10
11726
Copiague
38.7%
33.4% 11
11763
Medford
30.3%
21.2% 12
11727
Coram
20.1% 13
11757
Lindenhurst
26.1%
9.8% 14
11704
West Babylon
25.4%
20.8% 15
11784
Selden
54.3%
14.0% 16
11772
Patchogue
25.6%
14.2% 17
11720
Centereach
35.0%
14.1% 18
11789
Sound Beach
GAIN: 37.5%
5.1% 19
11703
North Babylon
26.7%
15.2%
[County Overall: 20%]

46. The continuing threat of the foreclosure crisis. . .
NUMBERS OF HOMES AT RISK OF DISTRESS AS A RESULT OF FORECLOSURE

47. Two Scenarios of “At Risk” Properties:
We estimate the number of homes at risk for distress and even potential vacancy for Nassau and Suffolk Counties using two different hypothetical scenarios.
Even in the best case scenarios, loan modifications alone will not solve the problem of vacant or distressed properties in the future.

48. Scenarios after homeowner receives 90-day PFF notice:
Loan modified, homeowner remains
The top scenario assumes mods for 50% of homeowners
The bottom scenario assumes mods for 30% of homeowners
Home sold and occupied (private sale/short sale or deed in lieu)
Both scenarios assume 50% of home purchase loans made in 2011 were for these types of sales
Home remains at risk of distress (i.e. foreclosure filed/pending, owner walks away, cash investor buys but does not maintain)

49. In these scenarios, Nassau County will have between 12,500 – 19,000 properties in jeopardy of vacancy or other forms of distress
These predictions are based on Empire Justice Center’s estimate that 32, day PFF notices were sent out in Nassau County in 2012.

50. For Suffolk County, the outlook is even more grim – in these scenarios, there will be between 21,000 – 31,000 properties in jeopardy of vacancy or other forms of distress
These predications are based on Empire Justice Center’s estimate that 49, day PFF notices were sent out in Suffolk County in 2012.

51. We cannot ignore the problem any longer . . .
Thousands more foreclosures are in the pipeline.
Tens of thousands of delinquencies and foreclosures were predicted, that’s what we’re seeing, but the end is not yet in sight.
Costs, especially in impacted areas, will be enormous.
The damage is everywhere but exponential in “impacted areas.” Lost property values alone will be in billions, not millions, of dollars.
The harm to African American and Latino communities is devastating
African Americans and Latinos overwhelmingly live in impacted areas so the crisis threatens to decimate their asset wealth and economic stability.

52. Each dimension of the problem needs appropriate strategies:
Across all areas of Long Island -- Additional measures and assistance are needed to keep families in their homes and housing occupied.
In impacted areas -- Targeted actions must be taken to stabilize neighborhoods and preserve value.
In African American and Latino communities -- Homeowners and other residents must be assured effective compliance with fair housing and fair lending laws.

53. 1. Keep owners in their homes
Increase and expedite loan modifications
Allow principal write-downs
Improve servicing and reduce application timelines
Prosecute foreclosure cases, keep properties out of “legal limbo” and negotiate settlement conferences in good faith
Ensure that direct services (counseling/legal) match the scale of foreclosures, particularly in areas with high concentrations
Develop strategies to keep families in their homes during, and after, the foreclosure process
Public awareness around foreclosure
“Continued Occupancy” initiatives

54. 2. Limit damage to communities and preserve tax base
Be pro-active on vacancies; develop strategies to . . .
Address inventory of current vacancies
Prevent numbers from growing
Improve ongoing property maintenance by developing . . .
“Property control” strategies for foreclosures in “legal limbo”
Enforcement tools for municipalities
Regulations for non-occupant investor purchases.
Make credit available to all qualified buyers
Advocate for adequate CRA funding and investments
Monitor and address displacement and homelessness

55. 3. Ensure economic justice in minority communities and protect their “asset wealth.”
Hold banks accountable – use fair lending and fair housing laws, especially in light of HUD’s new “disparate impact” rule (February 2013)
Increase Community Reinvestment Act (CRA) investments to stabilize low and moderate income communities disparately impacted
Design strategies to meet needs of minority communities
Develop policies to address racial and ethnic disparities (including proactive monitoring to ‘affirmatively further’ fair housing)

56. Contributors: Michael L. Hanley, Esq. Ruhi Maker, Esq.
Ruhi Maker, Esq.
Barbara Van Kerkhove, Ph.D.