By Attorney Heiner Giese

I submitted the following comment on behalf of the RPA to the Federal Housing Finance Administration's Request for Input (RFI) regarding the creation of tenant protections at multifamily properties with FHFA-backed mortgages:

The attached two files are a comprehensive study of all 1,101 residential eviction actions filed in Milwaukee County, Wisconsin in December 2019. The study was published in March 2022 with December 2019 being selected because it was the last month without the need to consider the effects of the Covid-19 pandemic.

The study confirms much academic and other research which establishes that well over 90% of all evictions are filed due to nonpayment of rent. The study refutes a misleading narrative that evictions are often filed for $500 or less of rent delinquencies. Conversely, our study shows $1,436 as the average amount requested in an eviction complaint and $2,672 as the average judgment granted for lost rent and damages.

The study refers to other research which refutes the narrative about Milwaukee landlord “Sherrena” presented in Matthew Desmond’s widely read book EVICTED. Desmond asserted that this landlord renting to low income tenants was operating a very lucrative rental property business. However, she had brought over 70 evictions and actually lost all 18 of her properties to mortgage and tax foreclosures.

Any measure of increased tenant protections must consider that lengthening the time a nonpaying tenant can stay in a property will increase costs and result in higher rents to other low income tenants.

RPA Eviction Study