Good luck

I am currently compiling a supplemental evidence package for submission to the Civil Rights and Commercial Litigation Sections at the U.S. Department of Justice, related to a federal filing. As part of that effort, I am reviewing how HUD has communicated with appraisers under the PAVE (Property Appraisal and Valuation Equity) initiative — particularly whether the documents sent were formal charge letters, pre-textual “risk assessments,” or improperly issued under FHA authority when no FHA loan was involved.

If you received a HUD letter or notification of any alleged racial bias in an appraisal — whether labeled a “charge letter,” “risk analysis,” or any related form — I would appreciate it if you could share a copy with me. I am including my own original HUD charge letter as an example for comparison. This effort will help determine whether HUD followed proper legal procedures or misrepresented jurisdiction to justify continued funding. All materials will remain confidential and may be submitted anonymously unless otherwise authorized. Thank you for helping bring transparency and accountability to this issue.

Sincerely,

Kenneth Mullinix
DOJ Civil Rights Division Report No. 629018-TPJ
7204 West Coast Highway #44
Newport Beach, CA 92663

Hey Bags – my website is built and managed by SFREP – also my software vendor. “Keeping the Reality in Real Estate” is mine and trademarked – thanks for noticing. It always irks me to get a check made out to Kennedy Reality – however I never had trouble cashing them 😉

In recent years, appraisers have faced increasing scrutiny from agencies like the Department of Housing and Urban Development (HUD). While oversight is essential, there are growing concerns about investigations that disregard established protocols, leading to prolonged and unwarranted scrutiny. However, by harnessing advanced tools like ChatGPT and understanding HUD’s guidelines, appraisers can effectively defend their practices and ensure fair treatment.

The Accardi Doctrine: Agencies Must Follow Their Own Rules

A cornerstone of administrative law is the Accardi Doctrine, established by the Supreme Court in United States ex rel. Accardi v. Shaughnessy, 347 U.S. 260 (1954). This doctrine mandates that federal agencies are obligated to follow their own regulations, policies, and procedures. Failure to do so can result in their actions being invalidated if challenged in court. This principle empowers appraisers to hold agencies accountable, ensuring that any investigation adheres
strictly to established guidelines.en.wikipedia.org+1en.wikipedia.org+1

HUD’s Single Family Housing Policy Handbook 4000.1: A Tool for Defense

HUD’s Single Family Housing Policy Handbook 4000.1 outlines the procedures and standards for appraisals and related investigations. Familiarity with this handbook allows appraisers to identify any deviations from prescribed protocols during an investigation. For instance, if HUD initiates an investigation without proper notification or fails to provide clear reasons for the inquiry, these actions may violate their own guidelines, rendering the investigation procedural flawed.

Leveraging AI: A Modern Approach to Ensure Compliance

The advent of artificial intelligence offers appraisers a powerful ally. By inputting case documents, correspondence, and relevant files into AI platforms like ChatGPT, appraisers can analyze the investigation’s adherence to HUD’s guidelines. The AI can cross-reference the actions taken against the procedures outlined in the handbook, highlighting discrepancies or procedural missteps.

Example Prompt for ChatGPT:

“Analyze the attached investigation documents and identify any deviations from the procedures outlined in HUD’s Single Family Housing Policy Handbook 4000.1.”

This approach provides a detailed, objective analysis that can be instrumental in defending against unjust investigations.

Case Law Supporting Procedural Adherence

The importance of agencies following their own procedures is further reinforced by cases like Citizens to Preserve Overton Park v. Volpe, 401 U.S. 402 (1971). In this landmark decision, the Supreme Court emphasized the necessity for agencies to adhere to statutory requirements and established procedures, underscoring that failure to do so can lead to judicial invalidation of their actions.en.wikipedia.org+1en.wikipedia.org+1

Actionable Steps for Appraisers

1. Educate Yourself: Familiarize yourself with HUD’s Single Family Housing Policy Handbook 4000.1 and other relevant guidelines.

2. Document Everything: Maintain meticulous records of all communications and actions related to any investigation.

3. Utilize AI Tools: Leverage platforms like ChatGPT to analyze investigation procedures against established guidelines.
4. Consult Legal Counsel: If discrepancies are identified, seek legal advice to challenge any procedural violations effectively.

By proactively engaging with available resources and technologies, appraisers can ensure that investigations are conducted fairly and in accordance with established protocols, thereby safeguarding their professional integrity.

A reverse mtg borrower can be 90 years old and no job and if there is equity in the home say 500k to 2 million, the borrower is on easy street to enjoy their life and travel if they want to.

Having read that guys website I’m not so sure. He’s a legitimate retired police officer. He’s almost certainly captured the premium lawn care subscribers on the North side. Anyways I’m too old. Almost died just trying to get moving and do spring prep on my own yard last week. We’re pushing another save the bees and butterflies garden this year.

Looked into origination classes I’m not so sure of that either, too much desk time. The stress of appraisal in this new modernized form is simply too much. None of this is what we signed up for. Central planning never works.

Baggins. You still can have a whole fleet of riding lawn mowers if you wanted. These lawn cops don’t have 100. % of the market. There should be plenty of work for more mowers.

Really wish he’d keep a repository of all articles online somewhere other than twitter, so we could link them without needing accounts.

Eric your website is awesome; Keeping the reality in real estate. Inspired.

‘The investigation’… I’ll believe it when I see it and not a moment sooner. One can not take a half step any direction in real estate appraisal without hitting a stone wall of concerted racketeering an collusion. It’s the open secret everyone knows about, and nobody does anything to correct. Going on two decades now if not longer.

Look what I found driving around in a small town Northern CO. Had to snap a photo. I could have been someone. I could have been a successful small business owner. If only I’d chose lawn mowing and shrubbery maintenance instead of real estate appraisal. Just bad luck.

Shane filed for summary judgement..that process is almost finished and the judge should render her opinion sometime in the near future..Thanks for asking !!

Yep, Ipock and Retired and NOT known for their optimism. Peace ya’ll, some of us don’t mind fighting back even if it means mostly banging our heads against a brick wall Occasionally we get a breakthrough.

Over the past few years, the U.S. Department of Housing and Urban Development (HUD) has systematically targeted independent appraisers through the PAVE (Property Appraisal and Valuation Equity) initiative, using baseless allegations of racial discrimination to prolong investigations, entrap professionals, and ultimately reshape the appraisal industry for political and financial gain. I am one of many appraisers who have been subjected to what appears to be a deeply flawed investigative process, and after years of fighting, I am now escalating this case further—seeking congressional intervention, media exposure, and the legal backing to launch a “class-action lawsuit” against HUD for its questionable enforcement practices.

This is not just my story. Dozens of appraisers have come forward and contacted me with similar experiences (And Growing), and the pattern is clear: state appraisal boards and other government agencies review complaints and find no evidence of wrongdoing, yet HUD moves forward with an investigation anyway—disregarding exonerating evidence, extending cases indefinitely, and imposing unjustified hardship on appraisers. The real goal of these investigations appears not to find racism but to make the investigation itself the punishment—ruining the health, finances, and careers of appraisers caught in HUD’s system.

How My Case Exposes HUD’s Actions

I was falsely accused of racial bias after conducting a routine real estate appraisal. Another government agency conducted a year-long investigation and found no evidence of racism. However, instead of the matter being resolved immediately after showing them proof, HUD launched its own separate investigation, disregarding the findings and failing to address clear evidence in my favor.

• Entrapment Tactics: HUD filed a second charge of “Coercion” against me after I followed an investigator’s direct email instructions to contact the complainant about a potential resolution. This was later used against me as an additional violation.

• Prolonged Investigations Without Justification: HUD has exceeded its own statutory limits for investigations, keeping my case open for over two years (the appraisal was performed in 2021) despite clear evidence in my favor. The homeowner was not vetted per (Section 4000.1) HUD’s own handbook guidelines and Fair Housing Regulations, yet HUD proceeded with the case despite blatant perjury by the homeowner.

• Failure to Provide Transparency: I also filed a Freedom of Information Act (FOIA) request to obtain the status of my case, yet HUD has failed to respond.

• Severe Personal and Financial Impact: Like many others, I have suffered significant emotional distress, anxiety, insomnia, and financial hardship—all while HUD continues its prolonged inquiry.

A System That Benefits from Keeping Cases Open

There is growing concern that these prolonged investigations are not about justice, but about sustaining a system that financially benefits from keeping cases open.

• HUD’s Funding Tied to Open Cases
The PAVE initiative has received millions of dollars in federal funding under the premise of addressing appraisal bias.
o More open cases = more funding. If HUD resolves cases quickly, they have no justification for additional grant money.

o Congress must audit HUD’s financial incentives and determine whether prolonged investigations are artificially inflating their budget justifications.

• Bureaucratic Self-Preservation Over Fairness

o HUD investigators are not evaluated based on fair resolutions—they are evaluated based on how many cases they manage.
o Closing cases means less funding and fewer positions within HUD’s enforcement divisions.
o Congress must demand transparency and justification for these prolonged investigations.
• The Industry Profits While Appraisers Are Left Defenseless
o DEI consultants, law firms, and compliance companies profit from prolonged investigations, offering costly “bias training” and “diversity reviews” for appraisers.

o Banks and Appraisal Management Companies (AMCs) benefit as fewer independent appraisers allow them to consolidate control over property valuations.
My Efforts to Seek Accountability
Since the last call for appraisers to join this fight, I have taken the following actions to escalate this case:
• Contacted multiple Senators and House Representatives, including the offices of Rand Paul and Josh Hawley, Adam Shiff, Dave Minn, among others, urging a full congressional investigation into HUD’s investigative practices.
• Contacted the FBI: Confidential.
• Filed multiple reports with HUD’s Office of Inspector General, formally expressing concerns over procedural irregularities and investigative conduct.
• Filed a complaint with the HUD whistleblower hotline, requesting independent oversight of the process and my case.
• Contacted the DOJ Twice, requesting a review of the handling of these cases and the broader implications for regulatory fairness.
• Contacted DOGE/Elon Musk, I populated the proper forms.
• Engaged multiple law firms, including civil rights attorneys, to explore legal avenues for holding HUD accountable.
• Sent follow-up letters to HUD’s San Francisco office, which regulates West Coast appraisers, demanding transparency on how cases are being handled.
• Reached out to many media outlets, reporting DEI violations, and ensuring that this issue is not ignored.
• Contacted the General Accounting Office (GAO) in Washington D.C., seeking assistance or appropriate redirection to an oversight agency.
• Gathered multiple testimonies from appraisers currently under investigation, many of whom report the same pattern of extended cases despite being cleared by other agencies with many Investigators suggesting a quick settlement.
One appraiser even reached out stating that he was battling cancer while HUD continued to investigate him despite evidence clearing him of any wrongdoing. Like myself, many appraisers have suffered severe mental, emotional, and financial distress fighting cases that should have been closed long ago.

What Happens Next? Join the Fight.

This is just the beginning. Many more appraisers are coming forward, and this needs to be a nationally recognized class-action lawsuit.

If you are an appraiser under HUD investigation or past investigations—or if you were previously investigated and cleared by your state board or another agency—I urge you to reach out. We need to gather as much evidence as possible to force Congress and the courts to take action.

? If you have been targeted by HUD, email me at: kjmull@aol.com
? If you are a journalist, legal expert, or someone who can assist in bringing this case forward, contact me immediately.

This issue is not about improving appraisal standards or racial equity—it’s about political and financial manipulation of an industry under false pretenses. If we do not fight back now, the ability of independent appraisers to work without fear of government retaliation will be lost.

It’s time to hold HUD accountable.

– Kenneth J. Mullinix