https://therealdeal.com/chicago/2025/08/04/appraisal-institute-settles-ex-ceos-lawsuit/
If there is more news to read on the matter, it’s currently behind a login wall.
https://x.com/MaryCummins1/status/1951747122979828197
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Look what I found while trying to search the recent news…

The ‘appraisal modernization act’ had it’s second reading on the senate floor.

Kiss good by to client confidentiality and report data confidentiality.

Read the bill. It was just given a second reading this july, 2025.

https://www.congress.gov/bill/119th-congress/senate-bill/2322/text

wow! I stand with you on this. Sorry you had to experience this.

By Kenneth J. Mullinix
Fee Panel Appraiser | ADA-Protected Federal Contractor | Appraiser Advocate
________________________________________

What happens when a federal agency is caught violating civil rights, ignoring due process, and misusing investigative authority?

At HUD, they just shut the system off and pretend the case doesn’t exist.

That’s exactly what happened to me 2 weeks ago.
________________________________________

🔒 They Locked Me Out — To Bury the Evidence

After more than 27 month of fighting for transparency, submitting rebuttal evidence, and enduring one of the longest unresolved appraisal racial/ discrimination investigations in HUD history (10 Months investigation with the VA), I was recently locked out of the TEAPOTS system — HUD’s official case management portal for active investigations.

The action wasn’t random.

It was carried out without notice, without a finding, and without legal justification.
I was still under investigation. The case was active. There was no written closure letter.

So why was I cut off?

Because I uncovered the truth: HUD never had jurisdiction, and they knew it.
________________________________________

🧩 Meet the Players: Sally Pai and Theresa Muley

My ordeal began after I completed an appraisal for a VA loan in 2021. A single complaint was filed. The VA launched a full investigation and cleared me of bias after 266 days. Case closed.

But then, HUD — “Without Jurisdiction” — reopened the case under the PAVE Task Force banner. They assigned it to Theresa Noreen Muley, a HUD investigator who:

• Would not tape phone calls or use Zoom
• Would not consider evidence of my innocence
• Did not investigate possible perjury by the homeowner since the VA just cleared me then he went and filed a mirror claim with HUD
• Misrepresented my legal representation status

Shortly after, HUD Enforcement Branch Chief Sally Y. Pai intervened.

She removed Muley from the case (with no HR paperwork), refused to assign a new investigator, and ultimately froze the case entirely.

Then she blocked my access to TEAPOTS.

No closure. No contact.
Just silence — and a sealed vault of federal misconduct.
________________________________________

⚖️ Violations, Obstruction, and Civil Rights Abuse

Let me be clear:

This isn’t just bad management — this is illegal.

HUD’s own FHEO Handbook requires:

• Timely communication with parties under investigation
• Transparency around investigator changes
• Fair access to procedural tools and rebuttal channels

Additionally, their conduct violated:

• My ADA rights (I am a documented stroke survivor with PTSD and protected status)
• Federal whistleblower protections
• Due process obligations under the Fair Housing Act

And now, by cutting off my access to TEAPOTS and halting the case without explanation, HUD is actively obstructing justice and concealing its own wrongdoing.
________________________________________

🔎 I Fought Back — And Now They’re Cornered

Rather than backing down, I escalated the case:

• I’ve filed multiple FOIA requests targeting Pai, Muley, and HUD Region IX
• I’ve demanded the system logs showing who ordered my access revoked
• I’ve requested case duration records proving this multi-year delay is part of a pattern
• And I’m preparing congressional outreach and possible litigation
What we are uncovering appears to be a systemic abuse of power under the PAVE Task Force, driven more by politics and PR optics than evidence.
________________________________________

📣 To My Fellow Appraisers: This Is the Moment to Speak Out

If this can happen to me — a VA-cleared appraiser, with medical hardship protections, and hundreds of pages of rebuttals submitted — it can happen to anyone.

How many of you are:

• Still waiting for answers?
• Still under investigation after a year or more?
• Denied your right to respond?
• Told nothing, while your career stalls?

The time to be silent is over.

If HUD thought they could freeze my case and make it disappear, they made a mistake. Because now, it’s not just a complaint — it’s a cover-up.

And I’m exposing it.
________________________________________

Kenneth Mullinix

Appraiser Advocate | HUD Respondent | ADA-Protected Federal Contractor
Contact me at: kjmull@aol.com

(My CASE was illegal from the Start and never should have been opened-Double Jeopardy- the VA cleared me)

Title: “When HUD Freezes Your Case to Cover Their Tracks: Naming Names, Exposing the Playbook”

By Kenneth J. Mullinix
Fee Panel Appraiser | ADA-Protected Federal Contractor

In my last post, I described how HUD weaponized the PAVE Task Force to target appraisers without due process, how it bypassed jurisdiction, and how it ignored the findings of the Department of Veterans Affairs when clearing me of wrongdoing.

Now it’s time to name names.

Because the pattern is undeniable. And the facts are no longer hidden — HUD hid them from me.
🔒 Locked Out of TEAPOTS — The Digital Cover-Up

After two years of defending myself and sending over 50,000 words of legal and factual documentation, I was recently locked out of HUD’s TEAPOTS system — the very platform where I had previously accessed case updates and submitted rebuttal materials.

No warning. No reason. No explanation.

The supervisor behind this?
Sally Y. Pai, Enforcement Branch Chief of HUD Region IX.

She did not assign a new investigator. She did not respond to my inquiries. Instead, she froze the case, cut off access, and blocked my ability to submit any further rebuttals or ADA-related hardship documentation.

That’s not just unprofessional — that’s illegal.

📘 Handbook and Civil Rights Violations

HUD’s own internal FHEO Handbook 8024.1 requires:

That complainants and respondents be treated with transparency and fairness;

That investigators document, notify, and update parties about material changes;

And that closing a case without proper process is a violation of Title VIII of the Civil Rights Act.

My case wasn’t closed.
It was buried.

What Ms. Pai did amounts to:

Obstruction of process

Suppression of ADA-protected disclosures

Misuse of federal systems to block legal participation

Deprivation of rights under color of law

And yes — that last one is a federal crime under 18 U.S.C. § 242.
❌ No HR Record, No Paper Trail – Just Silence

After the original HUD investigator, Theresa Noreen Muley, was removed (or reassigned — HUD refuses to clarify), I was told to stop contacting her. When I asked who my investigator was now, I received no answer.

Even worse: HUD at one point falsely claimed I had legal representation, which I did not — and they used that as an excuse to cut off direct communication.

HUD used my own rights against me.
Then, when caught, Pai sealed the vault and iced the case.

🔍 We’re Not Letting Them Bury It

This week, I submitted a second formal FOIA request demanding:

The internal logs of case freezing and TEAPOTS access suspension;

All communications involving Pai and Muley regarding my case;

And HUD’s internal justification for keeping the case open for 722 days with no findings and no closure.

We’re also requesting records showing how many other appraisers have been locked out of the system or left in legal limbo for over a year — and how many of those were VA panel members with no HUD jurisdiction.

💡 Appraisers: This is How You Fight Back

This isn’t about just me anymore. This is about every appraiser who’s:

Been accused without evidence

Investigated for years without resolution

Forced to prove a negative in a hostile system

Targeted not for what they did — but for what ZIP code they worked in

We’re blowing this case wide open because it’s time.

If HUD, through Pai and others, thought they could intimidate me into silence, they miscalculated.

My case is becoming the test case. And if you’re an appraiser who’s gone through the same thing, it might be time to add your name to it.

Stay tuned.

The FOIA documents are coming — and they won’t be able to hide the truth much longer.

Kenneth J. Mullinix
HUD Respondent, Appraiser Advocate,
Federal Contractor Under the ADA

Non profit tax return time. Oh yes. Because as half of all licensed appraisers face going out of business, somewhere north of thirty thousand GSE focused small businesses soon to be gone. AI execs are raking in the cash hand over fist and having closed door meetings with amc bosses. That’s fitting.

2022 / propublica
https://projects.propublica.org/nonprofits/organizations/363739643/202313199349316611/full

APPRAISAL INSTITUTE
EIN: 36-3739643
https://apps.irs.gov/app/eos/

Is there a special reason these returns are delayed for public viewing several years?

Thank you John. I don’t understand why the appraisal industry is continually framed and staged as a dog eat dog everyone for themselves type of industry. It never used to be this way.

Seriously, what’s wrong with a more fairly equalized distribution of work at a more consistent pace, at a more consistent fee, to a broader range of licensed professionals? We used to say all it takes is one or two good lender clients and you’re set.

Just about every amc out there follows them same model; rake off the top, appease commission based interests, sub out and prefer sub par appraisers whom utilize outsourcing and pencil the most deals. The same lenders whom use rotational assignment in the VA system also prefer amc’s when not constrained in a similar manner. Because they know that amc’s pressure appraisers which results in higher closing ratios, with a bonus junk fee on the side. Illustrating how veterans have reasonably fair consumer protection, but nobody else does.

How nobody is enforcing appraiser independence rules, nor respecting why those rules were ever set in place. The regulatory structure around appraisal is nonsensical. Amc’s should be regulated at the federal level by the SEC and OCC just like lenders, or at least be completely separated from appraiser licensing boards. At the state level, amc’s being agents of the lender, in direct service as an agent to a mortgage lender, should be overseen by mortgage lender boards not appraiser boards. Amc’s were put in place to provide separation from loan production. But today; amc’s are loan production. Regulatory structure needs revisited immediately.

Probably a good time to revisit the fact that big corporations, fintechs, investment firms, venture capitalists, all the power players, viewed an industry rife for exploitation and monopolization, swept in like vultures to dismantle the entire thing, restructure everything, capture substantial monetary flow for themselves, co opt management at the highest levels, call it ‘appraisal modernization’. In the name of ‘valuation equity.’

The entire thing came straight from the top. Carefully crafted and implemented over more than a decade and a half. And even though there has been management restructuring, nothing is getting corrected. As the end of the line not only draws near, but has came and went for many independent small businesses, hence the accelerating attrition count of licensed appraisers and limited new entrants.

The AQB had it’s final day to post responses to their ‘alternative pathways to licensing’ just the other day. Here is an excerpt of an anonymous and quite lengthy set of responses. Sort of a chop up here, I skipped quite a bit but copied a few key portions of just one question. The entire thing was ten pages long. If I’m on the way out, lecture the bureaucrats at the door.

And as predicted, here comes the rush for artificial intelligence and other automated service substitutes. They’re feverishly claiming this technology will be more independent than independent humans. Conveniently and consistently ignoring the basics of software programing that nothing exists in cyber space without a human programming and directive behind it. That a machine is not constrained by consequences to actions and law like a human would be. AI learning based modeling. Input = output. All they’ll have to do is flip a switch and enter a new prioritized peramiter to manipulate results. Avm programmers have been effecting outcomes of their systems since the start. That’s how they gain market share and beat out the competition to sell their software instead of the next guy. By providing the avm users more of what they want; numbers either high or low which fits their specific business interests at the time. That is not free market capitalism, sound regulatory decisions, or the concept of the invisible hand. Who’s still buying this? Policies that effect the entire country, have built up a massive housing bubble and led to wide spread economic instability. And nobody ever got to vote on the matter. ‘Stake holder interests’.
________________

Q: What portion of the total required experience hours (e.g., a percentage or specific number of hours) do you think should be allowed to count as ‘Foundational Knowledge’ experience, and why? Please explain your reasoning, considering how this balance might affect competency, public trust, and accessibility to the appraisal profession.
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A: You can’t form a long term workable solution without addressing the root cause of the problem. Appraisal management companies. An incredible reduction in appraisal demand due to the stake holder interests whom want independent checks and balances gone, so they can run the entire country into a debt trap and play housing like the stock market.
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Newsflash there is no public trust in the real estate profession hardly at all anymore. Because of all the wokeness and DEI nonsense. The trust is broken. The public hates appraisers. The appraisal trade groups has done nothing to help and only made the problem exponentially worse. So instead of recognizing your own failures, you’re trying to create artificially trained appraisers like they will somehow imaginarily not be subjected to the same market forces which is currently forcing out thousands or more appraisers a year and they’re not being replaced.
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The same market forces that have been decimating most gse appraisers opportunity and working structure since around 2010. Every day working appraisers often do not earn enough to afford to hire or train an apprentice because nobody in the appraisal trade groups works to expand our service reach and service demand, but rather constantly does everything in their power to diminish the independent appraiser position for the largest client set in the world; the GSE’s. You know; ‘stake holders’.
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Then on top of that, per the ARCC, the amc’s have siphoned off at least 12 billion dollars worth of fees which would otherwise have gone to appraisers.
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Which is why the amc’s also support the avm final rule, parea for more pliable less independent workers, and have consciously driven the majority of the best and brightest appraisers out of the gse servicing section. How many trainees do you think twelve billion dollars would buy?
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If there is anyone to blame for the lack of diversity or lack of new people and demand to be an appraiser or the ability for appraisers to hire and train, look no further than the mirror. Appraisal trade groups caused this failure by their inability to be independent, their constant reactive positioning to ‘stake holder interests’, and utter disregard for the protection and viability needed for independent 1099 sole proprietor small business appraisers to exist in this current lopsided improperly balanced constantly decreasing demand for our services climate.
______________

That is all. Carry on and thank you for participating.

This info comes from conversations at a recent CE session. I will track down the source and pass it along.

Thanks for the work you do. As you know we are a maverick bunch so your voice is appreciated and has serious impact.

More likely that comes in the form of revolving door opportunities and fast tracked approval for insiders at the big amc’s. Just take a look at their executive and management boards. There was a disclosure piece on this website several years back which showed an internal document that with one amc, a set of two appraisers received millions of dollars worth of orders each year while all other appraisers in the location were sidelined except for occasional part time requests. They’re all that way. If the amc industry was ever given a complete top down audit…

The amc is an agent of the lender. The same lender companies are forced under VA rules to use rotational appraiser panels. Then with HUD Freddie and Fannie they adamantly insist on using amc’s in a completely different approach. Because they have the proof positive data that using amc’s increases mortgage production rates. Meaning the same safeguards applied to VA borrowers are being circumvented for the general public. There is no ‘separation from loan production’ with many amc’s. Amc’s are loan production.

Play the ‘amc’s management skills cut up game’.
https://appraisersblogs.com/class-valuation-brags-about-maximizing-rov-conversion-rates/#comment-44718

The state of Colorado accidentally stumbled across one of these insider appraisers while hunting appraisal bias phantoms.
https://appraisersblogs.com/appraisal-management-companies-deceptive-fee-skimming-exposed-in-lawsuit/#comment-44699

Here is a concept; The avm final rule; ‘shall adjust valuation output to correct disparate valuation outcomes across racial and ethnic lines.’ This is out in the open discrimination and is coded into the avm systems. This creates an open door for financial predation and is already being exploited on a ground level by institutional investors. They just reach into the avm systems and adjust values higher or lower whenever they feel like it or such changes suits their business interests. Lenders using avm waivers is the exact opposite of consumer protection. The avm final rule is the end product of the PAVE task force and NFHA’s tech equity hackathons. To fundamentally alter the way avm’s may operate. The program was specifically stated on NFHA’s publicly available non profit tax returns. Shortly after, financial regulators approved the avm final rule, stating it’s mandatory for lenders to use avm’s. FHFA ramped up the pressure for gse’s to eliminate independent appraisers, conditioning executive compensation on their ability to meet ongoing goals for fewer and fewer independent mortgage lending appraisers in the process. Fannie pushed the 98% ltv waiver allowance shortly there after.

The story coming together yet?

CG here – bigger firm, mostly lending work. I love a couple of our AMCs, the ones run by former fee appraisers we have good relationships with. More complex review questions are usually settled with a phone call and they are always quick to advocate for us with the client when we have done our job.

That said, fee and timing are both down around 30% for me since Q421. More assignments going to out-of-market appraisers who underbid us. We saw some summary appraisals bid at $1k and 1 week when it was super dry in 2022-23.

Now that AMCs are cutting into the commercial and private work

Please provide examples where this comes from. Because gse appraisers have been warning everyone they’re next, that simply getting away from gse lending work rather than tackling the amc issue head on, will not save anyone. Amc’s don’t want a piece of the appraisal industry, they want it all.