Who Are Milwaukee’s Top Evictors?
An Overview of the Infrastructure Needed to Identify Common Landlord Portfolios
By Branden DuPont
Medical College of Wisconsin
Introduction
Eviction is a daily reality for renters across the country. Before the pandemic, 4 evictions were filed every minute in the United States. The situation in Milwaukee was no better. Landlords in Milwaukee evicted "roughly 121 households each week." Research finds that renters most at risk include, "women, people of color, and families with children". More than just a symptom of poverty, eviction is linked to higher poverty and crime rates, decreased credit access, negative birth outcomes, and even increased risk of death.
To understand drivers of eviction and mitigate filings, Milwaukee needs to identify which landlords use housing court most. Well-known strategies to reduce evictions like rental assistance, tenant organizing, and eviction diversion benefit from understanding common actors behind property ownership. However, Milwaukee court officials, city administrators, and advocates lack this key piece of data. Large landlords will use multiple LLCs, so their individual name or the parent company is not listed in the eviction record. Understanding the total evictions tied to Milwaukee’s largest landlord — Berrada — took several months of "dogged local journalism" to manually link 75 different firms.
Research finds that landlord size is one of the most important factors in formal eviction filing risk. Two 2021 studies in Milwaukee and Boston found that where evictions filings occur depends more on who the landlord is than other factors like neighborhood poverty or the presence of a child. Even after controlling for tenants they rent to, large landlords in Boston file two to three times the rate of small landlords. This alarming trend occurs alongside the recent rise of Wall Street backed institutional landlords who now own hundred of thousands of homes in the United States – including in Milwaukee.
We first use the example of Milwaukee's second largest evictor after Berrada — Anchor Properties Group — to illustrate the complexity behind identifying large evictors. Then, this report details the civic technology infrastructure needed for Milwaukee policymakers to understand its community’s large evictors.
99
Evictions
17
Buildings
owned by Anchor Properties Group from 2016-2021
At first glance, Anchor Properties appears to be a mid-sized landlord. Over 5 years, they have filed around 99 evictions at their 17 properties.
Consider a typical approach to figuring out if other LLCs are related to each other.
A keen court clerk or legal aid attorney may begin to notice that the same attorney represents other similar named LLCs in court.
These four LLC's are then linked together by a common attorney and these A-named plaintiffs make up a larger landlord than previously understood. Over 5 years, this portfolio filed around 919 evictions at 101 buildings -- nearly 10 times the previous estimate.
However, this approach is limited so LLCs are next linked using property records.
Using property records, Anchor Properties Group is linked to a total of 22 known LLCs and turns out to be Milwaukee's second largest evictor. Over 5 years, this portfolio filed an estimated 3,144 evictions at 387 buildings.
Even more than being a large evictor, Anchor Properties files at an incredibly high rate: 90%. Before the pandemic, they filed 9 evictions for every 10 units they own.
The Milwaukee Housing Authority in comparison files at a rate of 3%.
Anchor Properties Group
Background and Need
Many cities across the country do not have timely and reliable access to eviction data. According to a National League of Cities report, "22 percent of urban city officials surveyed do not know whether evictions have increased or decreased from the previous year."In 2019, the Medical College of Wisconsin’s Track Milwaukee Eviction (MCW) project was built to fill this information gap around monitoring eviction trends and conducting detailed research. Original funding was provided by the City of Milwaukee and Legal Action of Wisconsin. When the project launched, the inability to reliably identify top evictors was the main point of concern raised by several Milwaukee Alderman including Kovac and Bauman.
Understanding a city’s top evictor is a longstanding, unsolved problem here in Milwaukee and nationally. It's complex data engineering task to regularly link eviction records to a city’s property records. Even then, as shown above, property ownership is often organized under limited liability companies, or LLCs, a setup that allows owners to defer risk and to keep their identities secret, making it difficult to link property records to a single landlord.Compounding the problem even further is the fact that certain landlords will switch their LLCs for the same property they own. This complicates city planners or researchers who wish to understand progress on housing stability over time.
Understanding a city’s top evictor
is a longstanding, unsolved problem
is a longstanding, unsolved problem
The Eviction Lab was founded in 2017 and released the first ever nationwide database of evictions in the United States. Detailed data down to the tract level were made available to policymakers, researchers, and the general public. Cities for the first time could see how they compared to others nationwide. Yet for 4 years since the initial release of data in 2018, a top evictors section on the site has read coming soon.11
The current practice of identifying top evictors is expensive and inefficient. It requires an analyst spend several weeks to a month to identify one landlord. We spoke to several members of the Chief Judge-led Housing and Eviction Prevention Workgroup on this issue. We identified the following policy and program strategies this tool could support. These include:
- Provide targeted legal defense strategies to tenants of property owners who are known to engage in “serial eviction filings” where housing court is used as a rent collection tool
- Inform eviction mitigation and diversion
- Inform the distribution and targeting of rental assistance
- Assist the Milwaukee Autonomous Tenant Union’s organizing efforts
- Evaluate the impact of Milwaukee’s newly passed Right to Counsel
Legal and Data Barriers
Two factors contribute to this longstanding problem: statutes that govern and prevent disclosure of a corporate entity’s beneficial ownership and siloed disconnected data systems.
A state's legal regimes can aid or complicate an understanding of property ownership. Wisconsin’s landlord and tenant laws do not require disclosure of beneficial owners behind any corporate entity (e.g., LLC, CO). Landlords must only provide information on the “on premise owner” or an entity that can accept legal papers – often a registered agent.Furthermore, in 2016, Wisconsin’s Republican-led legislature outlawed any municipality from implementing a rental reinspection registration program. This contrasts with states like California and New York where state-level legislation mandating beneficial owernship disclosure has been introduced.&
The disclosure of beneficial ownership behind corporations and LLCs has been the subject of recent federal legislation. Congress enacted the Corporate Transparency Act in 2021 over Trump's veto. The purpose of the legislation was to identify, "bad actors who own or control businesses that act as ‘fronts’ or shell companies on behalf of those conducting illicit activities."The law, with some exceptions, mandates any "corporation, LLC, or similar entity" with at least a 25% control, to report beneficial ownership ."To the dismay of advocates, the scope of this act limits the disclosure of the data to federal law enforcement and prosecutors, instead of the general public.Across the Atlantic, the United Kingdom makes this beneficial ownership data free and open to the general public.
Even if corporate beneficial ownership data was widely available in Wisconsin or from the federal government, data is siloed. Eviction records, property data, and corporate registration filings are maintained in separate city and state agency databases and are not currently integrated in a way that facilitates easy analysis.
Solution: Property Ownership Mapping
We recommend a strategy pioneered in New York City by Justfix.nyc referred to as property ownership mapping. While true beneficial ownership data is not available, landlords can be linked to a common portfolio. It works by gathering business addresses and property owner names, fixing misspellings using fuzzy matching, and then linking these entities via their networked connection.
This approach to identify common ownership has been used successfully by other groups like the Anti-Eviction Mapping Project. Their work is based in San Francisco, Los Angeles, and Oakland. Wrangling these public datasets is no easy task. As they describe it, these data are "half-open" and often require "zillions of hours to stitch... together."- They note that while this approach facilitates understanding of landlord networks, some ongoing review of linkage results is needed to avoid incorrect classifcation.
Data Integration
A property ownership mapping tool localized in Milwaukee requires timely data from multiple government sources. This is a common government technology problem called data integration. As David Guarino, a former Director at Code for America, noted:
"Many of the problems government confronts with technology are fundamentally about data integration: taking the disparate data sets living in a variety of locations and formats (SQL Server databases, exports from ancient ERP systems, Excel speadsheets on people’s desktops) and getting them into a place and shape where they’re actually usable."
We conducted an extensive review of four administrative datasets needed for property ownership mapping to understand large evictors. In each card, we provide an overview of the data where we list the government agency and explain the mechanism for how the data is collected. We then specify the minimum data elements required to be collected. Finally, we provide a preliminary assessment on whether the data can be easily integrated.
hi
Eviction
Overview
Wisconsin State Courts maintain a statewide database of eviction records filed in local county circuit courts. Evictions are filed under the small claims court category of cases. Data availability includes all court data specified under Wisconsin’s open record law, Wis. Stat. §§ 19.31-19.39. It costs $12,500 a year for access provided via an API key. Data must be queried per individual case as no bulk query option is allowed. Data is returned as a JSON object.
Data Elements
- Eviction Filing - court action to begin eviction proceedings.
- Eviction Judgment - court action granting eviction judgement.
- Eviction Filing Date - the date an eviction was filed
- Eviction Judgment Date - the date an eviction judgment was granted.
- Defendant Address - defendant address is used to identify where an eviction took place – and to link to other property related data
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Property
Overview
The City of Milwaukee’s Information and Technology Department has maintained a table for every parcel in the City since 1975. Data on property ownership is collected and updated daily by the City’s Assessor office. Data is available via the Milwaukee Open Data Portal and can be accessed as an excel file or as a shapefile.
Data Elements
- Property ownership - current owner(s) reported to the City Assessor.
- Owner address - listed owner’s address
- Land use - type of land use at the parcel. Used to identify residential vs commercial properties.
- Unit size - the number of units at the property. Used to calculate a base eviction filing rated for large properties with >4 units.
- Parcel taxkey - unique building parcel identifier
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Real Estate Transfer
Overview
When real estate changes hands or is “conveyed” a “Real Estate Transfer Return” or RETR is filed with the Milwaukee County Register of Deeds. To understand eviction trends by property ownership over time, data on when a property changed hands needs to be accounted for so that eviction filings are not attributed to the incorrect landlord or property owner. 5 years of historical data is available via monthly excel spreadsheets. Preliminary research has shown that when a single buyer purchases a spate of homes, not all conveyance dates are appropriately updated for all parcels purchased.
Data Elements
- Parcel taxkey - unique building parcel identifier
- Conveyance date - name of formal agent registered to corporate records
- Conveyance type - what type of real estate transfer (e.g. new corporate filing or sale).
hi
Corporate Entities
Overview
The Wisconsin Department of Financial Institutions maintains yearly filings for corporate entities (LLC, CORP, LLP) that own a given property. Data is only available for bulk export via a mailed CD for the full database, a text file ASCII file containing the previous months filings, or by single search through an online portal.
Data Elements
- Legal entity name - official corporate filing name
- Registered agent - name of formal agent registered to corporate records
- Registered office address - address of registered agent.
- Principal office address - unique building parcel identifier
The linkage between datasets that were not designed to be joined requires several data preprocessing steps. Milwaukee eviction addresses need to be standardized to the same format as the City of Milwaukee's master address index. Then, eviction addresses can be linked to a unique building parcel identifier (Taxey). The taxkey is a standard parcel identifier that will deterministically link to property and real estate transfer data.
Real estate transfer, eviction, and property data are in machine readable, open, and accessible formats. Data can be regularly pulled in a programmatic fashion. At this time, WDFI data does not meet the same standard and each LLC or Corporation name needs to be collected one at a time. WDFI should be engaged to publish their data in an online data portal.
Conclusion
During the CDC Moratorium, partners of the Eviction Prevention Task Force – Community Advocates and Legal Aid – engaged in a targeted emergency rental assistance (ERA) strategy to Milwaukee’s largest landlord Youssef "Joe" Berrada. Due in part to this effort, Milwaukee became a national leader in ERA distribution and was both commended by the White House and featured as a best practice by the National League of Cities.
The Medical College of Wisconsin provided Legal Aid and Community Advocates an analysis on this ERA strategy. They found that during the CDC eviction moratorium, Berrada filed an estimated ~22 evictions. This is 99.98% of Berrada's historical average and 1,481 fewer eviction filings when compared to the three-year average of the same period – 1,503 eviction filings. Milwaukee’s then second-largest landlord featured in this report, A Properties, was not engaged and filed evictions at similar historical rates.
As this example above and plan has made clear, understanding Milwaukee's top evictors is key to addressing housing insecurity. We have given an overview of why this longstanding problem remains unsolved. We also provide an overview of an intermediate solution: a property ownership mapping tool and the data integration needed to localize it to Milwaukee.
Understanding Milwaukees top evictors is a key policy priority. Currently, enough data is available to implement the recommended solution. The next step is to identify a civic tech firm, in-house government agency, or private company to build and maintain the property ownership mapping tool. They will implement the data pipeline to collect, integrate, and link common landlord portfolios. Only then will Milwaukee be able to regularly understand its top evictors.