Fannie Mae’s Conservatorship: A Babysitter’s Blunder
What the general public doesn’t understand is that Fannie Mae has been under conservatorship since the 2008 market crash — a status far from ideal, just one step from bankruptcy. By definition, a conservatorship is a legal arrangement where a court appoints a conservator to manage the affairs of an entity unable to do so itself, due to financial distress or other incapacity. It’s a polite term for babysitting an organization that can’t handle its own affairs.
A Babysitter Who Sparks Chaos
Calling the Federal Housing Finance Agency (FHFA) a babysitter for Fannie Mae doesn’t fully capture the dysfunction. It’s more like hiring a babysitter who dumps a five-pound bag of Skittles in the kid’s lap, hands them a pack of matches for “entertainment,” and then congratulates themselves for creating a “structured environment.” Instead of guiding Fannie Mae toward independence, the FHFA has fueled a sugar-charged, fire-hazard meltdown, acting shocked when stability remains elusive.
For over a decade, the FHFA has perfected the art of doing the bare minimum, dodging tough decisions, and pretending this was all part of a master plan—while busy watching TikTok videos and plowing through Red Bulls like it’s the last 4-pack they’re gonna make. Calling them “inept” feels almost too kind, like praising the babysitter for “creative problem-solving” when the living room is literally on fire.
This situation deserves public scrutiny—a 60 Minutes special report would be a start—to expose the mismanagement. The prolonged conservatorship has left Fannie Mae in a precarious state, and greater awareness could push stakeholders, potentially with Pulte’s involvement, to address this critical issue.
With the Appraisal Regulation Compliance Council (ARCC) now involved, the potential restructuring of the Consumer Financial Protection Bureau (CFPB), and Pulte leading the FHFA, there’s a glimmer of hope. Maybe—just maybe—we can start moving toward a sane approach to funding and home valuation without burning down the house, so to speak.
This article, adapted from a comment on AppraisersBlogs, offers a sharp critique of Fannie Mae’s conservatorship. We’ve refined the text for clarity and flow while preserving its original insight and wit. We thank the author for their compelling perspective, which inspired this article and sparks an important conversation we hope our readers will continue.
Great opinion piece. You nailed it — the so-called ‘babysitters’ let Fannie and Freddie rot under the weight of political agendas and bureaucratic nonsense. It’s amazing how a conservatorship meant to stabilize the market turned into a long-term power grab. Hopefully, someone finally wakes up and puts an end to this disaster before more damage is done. Thanks for shedding light on what too many (APPRAISERS) are happy to ignore.
Skittles and matches! Too funny. So true.
Ha, I’ve never had my a post of mine “refined” and reutilized. I’m blushing.
It was among the best and most important comments in the other thread. Great job.
Have they even paid back any of the principle ($116 Billion) to us tax payers after what 17 years? GSE: Government Subsidized Enterprises sounds more truthful!
The Gov’t was paid back the full amount plus over $100 billion. So the US taxpayer made out like bandits.
So, they paid back 0.5% in interest and you’re excited about that? More like we were robbed by bandits. Man I was glad when I got my loan at 2.7% when I refinanced back in ’22, now I feel like I was duped.
Your math is horrible. They starting paying the money back in 2012 and finished in 2017. The GSE’s paid back more than they borrowed.
I have to challenge your claim that taxpayers “made out like bandits” on the 2008 GSE bailout. Yes, the government was repaid the $187 billion principal plus an additional $63 billion, totaling $250 billion over 11 years. But let’s break it down: that extra $63 billion equates to a simple annual interest rate of about 3.06% ($63 billion ÷ $187 billion ÷ 11 years).
Compare that to a high-yield savings account or Treasury bonds during the same period, which often offered similar or better returns with less risk. The bailout wasn’t a risk-free loan — taxpayers shouldered significant uncertainty with no guarantee of repayment. A 3.06% return hardly qualifies as a windfall; it’s more akin to breaking even when you consider opportunity costs.
Calling this a bandit-level win for taxpayers overstates the case. The repayment was a relief, but let’s not oversell the financial upside.
Oops… I’ll refer you to Desiree 👆 lol
The FNMA Wholesale program is a problem. Locked in housing and rental over valuation for years to come, forever if not rectified. The end result of many DEI policies in the form of real loans. This is market manipulation not necessarily saving peoples homes. Clandestine welfare. It was not possible to legitimately retool everything with an appraisal modernization program without a justifiable excuse. Appraisers were in the target line of sight the entire time and never found out until after the trigger was pulled. ‘Valuation bias.’
https://capitalmarkets.fanniemae.com/whole-loan-sales
Try and make sense of that. Add the numbers up. Consider the bpo percent relationships. The programs are simultaneously a way to place people in debt traps and over valued loans, as well as a cover to conceal predatory origination and faulty origination methods; simply restructure the loan under artificial terms later if they can’t pay. Fueling a housing bubble. Most of those should have flowed back via reo to allow for market corrections.
Dream on. Good points made, don’t get me wrong. Simply not enough people that care to initiate a change. There are too many people with their hands in the “cookie jar”.
Seventy five percent of reported FNMA loans now have an appraisal waiver. What could possibly go wrong? Appraisal waivers sound a lot like NINJA loans of the mid-2000’s.
If only over 98% ltv loans require an appraisal, does that mean 25% of their loans are high risk maximally leveraged? Out of the 25% which are still getting appraisers, is there a data breakdown for hybrid, drive by, or full 1004’s? This is why many appraisers are not working and are exiting the industry in droves. There was one thing FHFA, Fannie, and Freddie are really great at; putting small business appraisers out of business.
You said a mouthfull, Baggins – as usual your spot on. The sad thing is they never learned from the last bubble and the misguided manner in which they are trying to prevent another one will only fuel the fire even more.
While there are some good points raised in the Opinion Piece, it carries virtually no weight given that the author doesn’t have the stones to sign their own name to it. Disappointing at best. Same old crap by appraisers with no assignments, who would rather be keyboard jockeys.
A grievance that people are anonymous on the internet? Seven people have posted so far on this thread. Five of them have not linked or posted with their real name. According to this metric, all posts online anywhere have no value, unless people sign with their real name. Are you promoting digital ID or what exactly is the motivation? Let’s play a math game.
https://www.malwarebytes.com/blog/uncategorized/2025/04/hi-robot-half-of-all-internet-traffic-now-automated
You literally no nothing about me, my stones, or my workload, which are all heavy – who’s the keyboard jockey exactly? I’d rather stay anonymous than be flooded by hate mail – it’s just common sense.
The sentiment is understandable, but only to a limited point. Those claiming some intellectual authority or honest high ground by demanding full and complete transparency may not understand many key details. Multiple appraisers whom published or posted here under their real names have dealt with real world repercussions. Several appraisers were personally threatened at their homes and it scared them to the point they are now reluctant to post or publish. Doxxing of personal address and contact on other forums, something we tracked down a few years ago and I surprised quite a few people by finding the original sources one time and they were calling for groups of people to gang up and push the appraisers around, on other social forums. The site owner at times suffers from substantial hack and penetration attempts, has a lot of spam and botnet activity, especially when special disclosure pieces are published. FYI because people keep saying this, I have no financial or other interest, or any technical control of this website. That’s someone elses job, I only post and access this through regular internet browsers and do not use facebook or linked in to access this site. Personally I try to appreciate every other poster, even when things light up. We’re glad that more people pay attention and participate.
Unfortunately people don’t always do so for good reasons. There appears to be a common theme among appraisers taking this position that posting anonymously somehow discredits the message and the poster, which is simply not true. Many appear to be gse proponents, amc proponents, somehow on the insider track for so much of that work from the higher levels. In a more honest system they would not have to be defensive of the position, because there would be enough work to go around. If FNMA was not pushing over 75% of our workload to automation on the origination side, and having long since wiped out a substantial additional volume on the review side via the flawed CU system which does not work as intended. Had not allowed amc’s to plunder and exploit the independents for this long, there would likely have been an additional hundred thousand licensed appraisers and everyone with decades of experience could have been running exceptional firms, created many new employment opportunities, would be sitting as small business managers instead of fighting with each other for what’s left.
There is nothing wrong with posting anonymously, especially given the climate where gse mortgage lending and asset management focused appraisers are slated for extinction from the top down. In today’s gse appraisal world where people are routinely blacklisted with a click of the button, via the manipulation of appraiser grading, tiered ranking, automated process which can be set to instant assign disproportionate volume to the fasted and cheapest (in violation of federal registry guidelines on appraiser selection process.) As ARCC papers published also illustrate, malicious down raking of appraisers on a whim also happens, many lender and amc managers and non licensed assignment staff play this as a game against appraisers just for fun. ARCC image attached.
This is cruel and unusual behavior towards independent licensed professional small business owners. We suffer from continued restriction of trade via racketeering processes. In any other industry this would be clearly illegal behavior which violates constitutional rights and regular workers rights. Almost everyone here is a whistle blower, the industry problems and unethical arguably criminal management has been so bad for so long. I did not make these concepts up myself. They were being talked about by other senior appraisers two and three decades ago, more routinely then they are today. All people like many posters here have done is picked up the torch and carried the existing previous arguments forward.
Before there was The Appraisers Blogs. There was also The Appraisal Scoop. For anyone interested in the historical record. There is so much content there, my favorite is the amc section, over two hundred articles. Sometimes it’s helpful to go back and read history. Everything the most ethical best appraisers of the past feared would happen, did happen. What we have today as the status quo in this industry was considered outright offensive criminal behavior but a decade ago. Keep posting, this is an important time where real change might happen in this industry. We’ve came this far, don’t stop now. Write the FHFA, OCC, and White House letters asap. Is the White House petitions page still up? Someone should post these issues there or on the Policies For The People website, help us get more traction. Behind the scenes what many people may not know; collectively we’ve already written thousands upon thousands of letters. Please join in on the effort for a better future for the appraisal industry. Thank you.
https://appraisalnewsonline.typepad.com/appraisal_news_for_real_e/amc_appraisal_management/
Yeah I’ve personally appraised 3 distressed properties in the last week that had sold in the last 3 years. When doing a prior sale analysis, I could only conclude these were appraisal waivers because NO comparable sales existed even within bracketing range, there were none. An appraiser could have in no way even gotten close to these values, unless only superior comps were used. My search went as far as looking into a 5 mile to 37 mile radius…yes you read that right. The prior sale values were so extreme that I couldn’t even find a single comp even with extreme expanded boundaries. And yea…ALL FHA…all on the tax payers back. Hopefully this is a fluke and not the beginning of a major market crash.
Tempest in a tea cup. Hey, yeah, let’s all sign our real names, attach our birth certificate and our appraisal certification, our address, our phone number, our DNA profile and our fingerprints. It would not make any difference except that it would make it easier to find us and ruin our lives even more expeditiously.
The sins of FNMA , & and their babysitter are many.
The most egregious is the belief in, and perpetuating of the myth(s) that
1. FNMAs Collayeral Underwriter produces credible results, or an early warning of defective collateral as appraisal as l analysis.
2. That ANY AVM or bifurcated hybrid appraisal produce credible results.
Address these two issues, and then they can tackle the outright fraudulent practices that were common at FNMA.
Mr. Pulte still needs to do some serious culling of the ones responsible for setting policy at FNMA and FHFA.
I wish him good luck. AGA has documented evidence of this that we remain willing to provide it to Mr. Pulte’s investigators.
Ladies and gentlemen; Mr Mike Ford of the American Guild of Appraisers. Round of applause. Website link just to the left; AGA. Previous articles link below.
https://appraisersblogs.com/author/mike-ford/
Great job Mike, keep up the inspiring work. Great suggestions. They should scrap the CU project, it’s become nothing more than intellectual property theft and data mining, also arguably against GLB on consumer privacy with how they’re scraping the data and monetizing home layout and photo information, selling that to overseas third party companies.
For real, take all that data, the evidence, plan a trip, go to the FHFA offices in person. Knock on the front door, hand it to someone. Demand to see Mr Pulte in person if only for a minute and hand him over a full rolling dolly of box after box of the evidence, the articles, all the data. There is a window open, but only for a limited period of time. Who will be our champion to personally knock on that door? ARCC brings hope which we should all focus on building upon.
That’s supposed to be the job of persons at the TAF, ASC, ASB, and AI groups. If we keep waiting on them, we’ll be waiting forever and tens of thousands more appraisers will continue to lose their livelihoods and careers.
🚨 The Smoking Gun: It’s Time to Expose the PAVE Travesty Against Appraisers
Today, after years of investigative work, the “Smoking Gun” has finally been uncovered.
Evidence now points directly to HUD’s systemic misconduct under the PAVE initiative — an initiative that, while promoted as a solution to racial bias, in reality trampled on due process, civil rights, and the integrity of the appraisal profession.
This is not speculation. This is documented fact.
Emails, forced ZIP code appraisals, procedural violations, and clear evidence of retaliation and cover-ups at HUD — all now backed by internal documents, case files, and formal declarations.
🧨 Why This Matters
For too long, appraisers across the country have been silenced, investigated without cause, and accused without real evidence.
This wasn’t about justice. It was about politics, money, and public image — at the expense of hardworking professionals.
Now, for the first time, the pieces fit together.
Direct misconduct by HUD investigators.
Supervisors authorizing false charges.
Procedural rights trampled.
Federal laws potentially violated.
A clear, conscious cover-up when the truth started to surface.
This is the real scandal behind the PAVE initiative.
📢 The Call for Help: We Need You
This moment is bigger than just one case.
It’s a call to everyone who believes in fairness, accountability, and the rule of law.
We need:
Whistleblower attorneys willing to fight.
Investigative journalists ready to tell the story.
Public interest groups who believe in government accountability.
Law firms willing to take up the banner of justice and challenge HUD’s abuses.
Anyone who knows someone who can help — a contact, a lawyer, a senator, a news outlet.
If you know someone — now is the time to act.
🚀 What’s Next
Formal whistleblower filings are in progress.
FOIA investigations are active.
Legal strategies are being developed.
Media outreach is ongoing.
But we cannot do this alone.
HUD’s misconduct affects every appraiser — and every future homeowner relying on a fair system.
It threatens the very foundation of trust in the real estate market.
📬 If You Can Help — Reach Out Now
If you know an attorney, a law firm, a journalist, a congressional office, or a watchdog group —
send them this message.
Tell them the time to act is now.
This is not just one person’s battle.
It’s about defending the entire appraisal industry.
It’s about standing up to government overreach.
It’s about restoring fairness and dignity to our profession.
Together, we can hold HUD accountable.
Let’s light the fire of truth — and finally demand the justice appraisers deserve.
Someone in these comments proposed a 60 Minutes segment 🤔 but the king dictatorship would sue CBS again for exposing the truth!
Dinosaur corporate media is trapped in their own devices. They did this to themselves. They don’t even get a reasonable viewer share anymore. The vast majority of younger people and better informed more tech savvy older people are no longer turning to the syndicated networks for truth or current information. You’re watching political theater, and are an actor on the stage yourself, if you continue to tune in to those channels and repeat their messages.
Check this out. Look what’s still online hosted by the Appraisal Scoop site. Schurmans full fee white paper. FYI he was the previous TAVMA manager. The amc trade group prior to the formation of REVVA, the current amc trade group. Much like Cindy Chance, when he posted this, in defiance of the amc exploitative model, his fate was already sealed.
https://appraisalnewsonline.typepad.com/appraisal_news_for_real_e/2012/05/20-benefits-of-the-full-fee-appraisal-management-company-amc-model.html
This paper examines the self-serving benefits to appraisal management companies (AMCs) resulting from a
shift in how residential real estate appraisers are compensated by this sector of the residential mortgage
services industry. The current fee-payment system enables AMCs to leverage their market share, nationwide
coverage, information technology, specialized management services and relationships with national lender-
clients to demand deep fee concessions from real estate appraisers. We offer twenty (20) such benefits here,
although we admit the possibility that there may be more. And we have little doubt that a roughly equal
number of competitive, statutory, and structural barriers stand in the way of implementing our full-fee, or
retail fee, model; we address some of these barriers in the paper. We anticipate some readers will incorporate
our arguments into their own firm’s deliberations of the implications of the fee issue on the industry. Others
may scoff at what they take as a misguided attempt to describe a world that can never be. Regardless of the
faction, only time will tell if or to what extent the full-fee model for acquiring appraisals comes to pass.
Below are the 20 distinct benefits:
Paying appraisers their full (or retail) fees…
1. Removes the single-largest barrier to acceptance of AMC as legitimate business partners.
2. Increases the supply of appraisers willing to work with AMCs.
3. Encourages new appraisers to enter the appraisal profession.
4. Leads to better control of appraisal quality.
5. Lowers costs for recruiting, quality control, and rework.
6. Enables AMCs to gain market share.
7. Provides AMCs rationale to charge lenders for the actual value the AMC brings to the transaction.
8. Enables AMCs to provide clients quantifiable means with which to compare AMC alternatives.
9. Reduces third-party risks described in numerous FFIEC Financial Institution Letters and agency guidelines.
10. Promotes less contentious treatment of AMCs.
11. Takes the subjective “customary and reasonable” fee requirement in the Dodd-Frank bill off the table.
12. Paves the way for nationalizing AMC regulation.
13. Provides clients better overall service quality.
14. Preempts external efforts of factions to force AMCs to pay up.
15. Is the most ethical thing to do in a fair and equitable society.
16. Allows for significantly improved vendor relations between the AMC and the appraiser.
17. Reduces the risk that disgruntled appraisers will draw the attention of federal regulators.
18. Provides joint marketing opportunities because appraisers will see the AMC as worth promoting.
19. Opens the door to a better borrower experience because the appraiser doesn’t enter the home angry.
20. Opens the door for joint publicity efforts because appraisers will feel like partners.
AMC lifers may object, saying, with a point, that AMCs have led the change in how lenders acquire
appraisals. This is true, but the underlying way they acquire appraisals—the process—remains the same as it
did in the early days. Although advances in information technology and certain management practices in the
industry have been innovated and automated, the buy-low/sell-high approach to transaction-related costs
remains the same. But there are signs that the model is about to change, whether the change is by choice
within the AMC industry, or from outside the industry through a hodgepodge of legislative and judicial means.
It is increasingly apparent that the AMC industry growth (due in large part to the effects of the HVCC and
seemingly simultaneous shedding of production jobs by mortgage lenders dealing with the housing bust that
began in 2008) has now peaked. There are now two factions—those convinced that AMCs benefit the
mortgage lending ecosystem, and those convinced that AMCs are a cancer that need to be eliminated in order
to save the industry. But there is a middle ground, which honors both factions. It is the renewal of the AMC
business model to serve not only the self-serving needs of the AMC industry and the clients the industry
serves, but also the providers of the very services AMCs rely on for sustenance: appraisers.
The starting point for renewal, in our view, is to pay appraisers their full-retail fees. Each of the other
dozen or so categories of criticism of the AMC model will seem more tolerable and perhaps even acceptable
absent the fee issue. Others will fade away or go away as AMCs leverage their retail fee model to place more
of the quality control and customer service burden where it belongs—on appraisers.
We envision a future in which the former factions come together to educate another industry undergoing a
renewal period of its own—the mortgage lending industry—as to why appraisers in partnership with appraisal
management companies ought to be valued advisors rather than necessary inconveniences, and as to why
they’re a superior solution than AVMs and other low-end evaluation tools. And why not? AMCs, as inevitable
as they are to the mortgage lending ecosystem, will be of no value to anyone if the appraisals they supply to
lenders become passé.
_______________
HAHAHAHA. Merry Christmas! From the amc’s top representative, before they decided to oust their own management and ramp up even more exploitative predatory processes. Save the document, I certainly did.
17. Any questions?
Over 1,500 Days Under Federal Investigation and counting! – And Still Waiting for Answers
How the U.S. Government Spent 1,566 Days Trying to Brand Me a “White Racist” Without Evidence
As of today, I have been under federal investigation for 1,566 days—over 4 years and 3 months—on false allegations of racism in my work as a licensed real estate appraiser. I have been called a “White Appraiser” and a “Racist”.
It began with the VA on January 15, 2021, and continued even after they cleared me on April 15, 2022. Instead of dropping the matter, HUD picked up the same baseless case and has kept it open ever since. Today is April 30, 2025—that’s 1,111 days under HUD’s scrutiny alone.
Despite repeated requests and official filings, I am still waiting for the release of my FOIA reports from both the VA and HUD. These reports may finally expose the internal communications, procedural violations, and political motivations that kept this ordeal alive long after it should have been dismissed.
This isn’t just about me—it’s about every appraiser who’s been wrongfully accused, investigated, or intimidated under the flawed and politically driven PAVE initiative.
________________________________________
📣 If you’re an appraiser who has been targeted, investigated, or pressured by HUD or any federal agency—join the class action effort.
We’re building a coalition. If you’ve been:
• Investigated without cause
• Cleared but still pursued
• Coerced into higher values or settlements
• Harassed for doing your job by the book
➡️ Email me at: kjmull@aol.com to get on the list. You are not alone—and together, we are preparing a legal response to this abuse of power.
Stand up.
Speak out. Fight back.
https://appraisersblogs.com/mismo-blueprint-2-eliminate-appraisers
That. Really. Happened.
Thanks Baggs…Id almost forgotten about that article. Got side tracked fighting phony complaints against appraisers for the next 6+ years!
Thanks. When I write appeals for help in this industry, I find it rather common to include links to some of your previous articles, as well as Mr Bagotts. I can pick them somewhat randomly and they are still entirely relevant.
🚨 HUD’s Dirty Secret: Fighting Racism by Practicing Racism — ZIP Code Profiling Exposed 🚨
On the day I opened the letter from HUD, I thought it would be a request for clarification of a appraisal I performed — maybe a simple inquiry.
Instead, what I read shook me to my core.
HUD wasn’t interested in facts.
HUD wasn’t interested in fairness.
HUD wanted to destroy me based on ZIP codes — and they said so in black and white.
Here’s exactly what they wrote.
________________________________________
🎯 HUD’s Demands: ZIP Code Profiling in Their Own Words
“You are hereby instructed to produce appraisals from properties located within the following ZIP codes 90209, 90210, 90211, 90212, 90213, 90214, 90035. Moreover, you have not provided appraisals that you performed in 90209, 90210, 90211, 90212, 90213, 90214 and 90035”.
No investigation.
No impartial review.
Just demands for documents based purely on ZIP codes — areas HUD selected based on their own assumptions about race and neighborhoods found in my appraisal coverage area.
They weren’t asking whether I had discriminated.
They were fishing — trying to build a case around geography, not evidence.
This is not a fair housing investigation.
This is ZIP code profiling — plain and simple.
________________________________________
🛑 HUD’s Threats: Chilling and Coercive
Before I could even process the ZIP code demands, I was hit with another wave of government threats — not implied, but written in no uncertain terms, and the direct quotes of my first charge letter sent to me that opened my own “Twilight Zone of Appraisal Nightmares”, quote:
“Any person who willfully fails or neglects to attend and testify or to answer any lawful inquiry or to produce records, documents or other evidence in obedience to a subpoena “shall be fined not more than $100,00 or imprisoned not more than one year, or both 42 U.S.C. 3611(c). “Non-compliance may lead to the initiation of administrative proceedings that could result in the suspension or revocation of your license.” “You may be subject to civil penalties and criminal prosecution for failure to cooperate.”
In one letter introductory letter, HUD threatened:
• Massive financial fines,
• The destruction of my career,
• And even criminal charges.
All before I was even allowed to explain myself.
________________________________________
⚖️ What Laws HUD Broke (and They Knew It)
HUD’s own Handbook 8024.01 and federal law prohibit exactly what they did:
• Fair Housing Act (42 U.S.C. § 3601 et seq.):
Prohibits targeting individuals based on race, national origin, or proxies like ZIP codes.
• HUD Handbook 8024.01, Chapter 3-4(B):
“Investigators shall not request or compel production of documents or evidence based solely on geographic location or neighborhood demographics.”
• Fifth Amendment of the U.S. Constitution:
Guarantees due process — the right to a fair, unbiased investigation based on individual conduct, not stereotypes or geographic assumptions.
• Administrative Procedure Act (5 U.S.C. § 706):
Prohibits arbitrary and capricious government action.
✅ By demanding appraisals tied to ZIP codes, HUD violated the Fair Housing Act and their own rules.
✅ By issuing threats of fines, license revocation, and criminal prosecution before any facts were established, HUD violated my constitutional rights.
________________________________________
💥 The Government Abused Its Power — and I Have the Proof
HUD’s letter wasn’t just chilling.
It was proof that the federal government has abandoned fair investigation practices in favor of political witch hunts.
They didn’t come looking for truth.
They came looking for a target — and they used ZIP codes to find one.
________________________________________
🧨 If They Can Do It to Me, They Can Do It
to Anyone
When the government uses ZIP codes instead of facts…
When the government threatens citizens before an investigation even starts…
When the government abandons its own rules…
No one is safe.
Today it’s appraisers.
Tomorrow it’s teachers, doctors, business owners — anyone whose profession touches demographics the government wants to manipulate.
________________________________________
📣 This is Why I’m Speaking Out
✅ Because ZIP code profiling is illegal.
✅ Because HUD broke the law and their own handbook.
✅ Because no American should face criminal threats based on where they worked — instead of what they did.
I have the charge letter.
I have the quotes.
I have the truth.
Heads Up all Peter Fontana (Appraisal Foundation Board Member) and Lyle Rieke are good buddies and Pete is leading the charge to dumb down standards to let the IAAO crowd more easily secure Appraisal Profession licenses. Pay attention, soon the lenders will be using the assessed value as valid FMV support. Seriously pay attention and speak up. Baggins your thoughts please1
Thanks. I don’t know about the groups, never meet other appraisers anymore except online. We’ll go through the same research routine though. Links below.
Recently, appraised an attached property which the assessed value was about $80k over today’s market. Tends to happen more frequently in some counties than others. Often tied to higher density housing. The difference between traditional structure with federally regulated transactions, regulated lenders operating as part of the GSE program which rules were written around that operational expectation, the traditional full service appraiser servicing, attentive underwriting, title, all of that. You can’t have the SEC OCC ASC or for most practical purposes the state boards, down at the local county municipal offices to oversee anything, jurisdictional conflicts. The room for conflict of interest and lack of effective oversight is substantial. How easy would that be to sweet talk the local assessor staff, instead of having to deal with independent appraisers? Avm’s for frt’s is not a practical concept and one wonders why anyone would promote that in the first place. But you don’t have to wonder; it’s another non profit out reach to expand income and influence.
https://www.iaao.org/publication/fe-april-may-2025/
Publication is titled; Fair + Equitable / Sorry, no login to read that. How long have they had that name?
IAAO is the parent company of PCS which is a registered not-for-profit educational organization dedicated to improving standards of assessment practices, fees for services are carefully considered. For further information on Professional Consulting Services of IAAO, LLC
https://www.irs.gov/charities-non-profits/tax-exempt-organization-search
36-2210012
https://projects.propublica.org/nonprofits/organizations/362210012
https://apps.irs.gov/pub/epostcard/cor/362210012_202112_990T_2022091220338118.pdf
https://apps.irs.gov/pub/epostcard/cor/362210012_202112_990_2023012720841552.pdf
Last link is the main one.
Lawyers win again. Have you ever wondered what it must be like, to have one of those free ride type of positions, coast through life on easy street, part of some influential group? Revenue is up, substantially.
The thing about non profits is once things are set up much of the activity goes towards a sort of auto pilot. Eventually the scope and reach of the organization expands, so does it’s members influence, and often the groups move past the restrictive boundaries of their non profit status. But as nobody looks, nobody investigates, and more specifically; nobody files irs non profit scope of reach spending and authority type challenges, there is not much actual oversight occurring.
Eventually the people are dominating other segments of the market and a consolidation or monopolization effect occurs, providing a business advantage. All all the big corps and groups are in on the game, they’ve got non profits with their own non profits behind them, and so on and so forth. Which is why we say; Rise of the non profits. This is what stopped DOGE group from many audit attempts, the networks can become so complex, sometimes even the own members don’t know where the money goes. I’m not insinuating anything here, just a general statement on many of the problems which recurrently surface with the non profit status. There are non profits whom specialize in investigating other non profits these days.
The counter argument is more simple and straight forward. Let’s be honest about what’s happening. A business is operating for profit. Some people are getting paid, sometimes very well. They have money, influence, status, and reach. That’s a business. A for profit business. Then wave the wand, have a few token charitable efforts, just like that; non profit status, aka tax exempt status. We should move to a flat tax and skip the special favors and taxable relief programs. The non profit sector continues to expand at an exponential pace, having moved far from the programs original purpose, to allow religious institutions or feed the poor type charitable organizations whom survived on often inadequate income, to avoid having their property seized by the tax assessor. Does this meet the definition of irony? It’s all way past my league man. I’m out here struggling for singles, living check to check these days.
🚨 HUD Had No Legal Authority to Investigate Most Appraisers — and They Knew It!
By: Kenneth Mullinix (Appraiser/ Advocate/ Activist)
From the very beginning, HUD’s bias investigations under the PAVE Task Force were illegal for one simple reason:
“HUD only has legal jurisdiction to start racial bias/discrimination-motivated investigations over FHA-insured loans”!!
🔹 They have no authority over VA loans.
🔹 They have no authority over conventional loans.
🔹 They have no authority over private transactions.
Yet HUD opened hundreds — possibly nearly 900–1,200 or more — investigations anyway.
Yet statistics show that an estimated only 12% or less of these cases involved FHA-backed loans.
Additionally, it appears that HUD deliberately kept many of these investigations open rather than referring them to an Administrative Law Judge (ALJ) for formal review or closure. The likely reason: HUD lacked legal standing to prosecute these cases. Had any of these investigations been forwarded to an ALJ, the first question asked would have been whether HUD had proper jurisdiction over the transaction. Because most involved non-FHA loans — VA, conventional, or private — the ALJ would have immediately recognized the jurisdictional defect and thrown the cases out. Rather than expose their unlawful overreach to judicial scrutiny, HUD chose to leave cases open indefinitely. In doing so, they artificially padded the number of “active investigations” to justify continued funding, political talking points, and media narratives — even though many of these cases were legally invalid from the start. This left hundreds of appraisers trapped for years in a system that knowingly denied them due process and weaponized investigations as a political tool rather than a lawful enforcement action.
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📚 Exact Laws and Handbook Sections HUD Violated:
• Fair Housing Act (42 U.S.C. § 3608): HUD must only enforce fair housing in programs it administers — primarily FHA loans.
• HUD Handbook 8024.1 REV-2, Page 1-5, Section 1-9 (“Jurisdictional Requirements”): HUD must verify jurisdiction BEFORE opening an investigation. Complaints involving VA or conventional loans are typically outside HUD’s authority.
• HUD Regulation 24 CFR § 103.25: Complaints outside HUD’s jurisdiction must be referred or closed immediately — not investigated.
✅ This means every non-FHA loan investigation HUD opened was illegal from the start.
✅ It means every appraiser dragged through years of baseless investigations was denied due process and had their civil rights violated.
✅ It means HUD weaponized government power without legal authority — and appraisers across America paid the price.
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📚 Civil Rights Violations by HUD’s PAVE Task Force
HUD’s illegal overreach is not a technicality — it is a direct violation of civil rights, protected under:
• The Fifth Amendment of the U.S. Constitution (Due Process Clause)
• The Fair Housing Act (requires jurisdiction and fair process)
• The Americans with Disabilities Act (ADA) (for disabled appraisers, including myself, targeted without accommodations)
But the violations didn’t stop there.
HUD conducted biased fishing expeditions, including:
• ZIP code fishing — asking for appraisals by neighborhood or city without a specific discriminatory allegation.
HUD Handbook 8024.1 REV-2, Chapter 2, Page 2-2 (“Investigation Planning and Scope”):
“Investigations must be based on specific, articulated allegations.
Investigations must not be used for broad inquiries or searches without a specific factual basis.”
And under:
24 CFR § 103.400:
“Investigations must develop specific facts relevant to the particular allegations of discrimination.
Investigations shall not be general searches without factual foundations.”
✅ ZIP code fishing was illegal under HUD’s own handbook and federal law.
HUD pressured appraisers for settlements before real investigations,
ignored disability protections, and buried jurisdictional failures —all to create a political narrative.
This wasn’t enforcement.
It was government abuse — funded by taxpayer dollars — and now exposed.
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📚 The Bigger Picture: How PAVE Was Built on a Lie
In 2021, under an Executive Order by President Biden, the Property Appraisal and Valuation Equity (PAVE) Task Force was created.
It was marketed as a civil rights initiative — but from the start:
• Investigations were rushed.
• Jurisdictional checks were skipped.
• Political headlines were prioritized over legal compliance.
• Appraisers were sacrificed to produce “bias findings” without evidence.
By Fall 2021, HUD had committed millions to expanding PAVE —
many investigations involving VA, conventional, or private loans HUD had no legal right to touch.
In March 2022, HUD celebrated supposed “findings” of bias —
while hundreds of appraisers were being illegally targeted.
Today, while PAVE has effectively collapsed, the civil rights violations it unleashed are still fresh — and accountability is coming.
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📚 Documented Violations of Law and Handbook
HUD’s misconduct violated:
• HUD Handbook 8024.1 REV-2, Page 1-5 (Jurisdictional Requirements)
• HUD Handbook 8024.1 REV-2, Page 2-2 (No broad fishing expeditions without specific allegations)
• 24 CFR § 103.25 (Must close or refer out-of-jurisdiction complaints)
• 24 CFR § 103.400 (Specific facts required for investigations)
• Fair Housing Act (42 U.S.C. § 3608)
• Americans with Disabilities Act (42 U.S.C. § 12101 et seq.)
• Fifth Amendment Due Process Rights
Every non-FHA case opened was a direct violation of federal law and civil rights.
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📚 My Story: Fighting Back Against an Illegal
Investigation
I was targeted under HUD’s illegal PAVE initiative — despite working on VA loans HUD had no right to investigate.
For four years: (1 year after appraisal on 11-0-2021homeowner filed racial case/ 1 year for VA investigation to conclude/ homeowner filed again with HUD now a 27-month long investigation from HUD- still open):
An estimation:
• Wrote and estimated 500-750 pages defending myself.
• Filed multiple FOIA requests to uncover the truth with HUD/ VA.
• Filed a whistleblower complaint with the U.S. Office of Special Counsel.
• Filed a case with the Department of Justice
• Informed the Legal Counsel of HUD about the abuse/case
• Filed a police report- break in of my office
• Contacted numerous media outlets
• Contacted congressmen and other government agencies
• Wrote the Inspector General’s Office at HUD multiple times
• Filed a GAO FraudNet report exposing HUD’s misuse of taxpayer funds.
• Filed an EEOC disability retaliation complaint.
Through it all, I endured:
• Constant emotional stress
• Worsening PTSD
• Insomnia/ sleep disorders
• Shingles outbreaks
• Anxiety/ panic attacks
• Financial damage
• Reputational harm
I am not alone.
Appraisers across the country have been contacting me with similar stories. I have an estimated 20-25 personal stories about HUD investigations so far.
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📚 ⚖️ Building Toward Class Action Status
Because HUD’s illegal actions affected hundreds — possibly thousands — of appraisers,
I am actively preparing for future class action litigation.
✅ If you were investigated by HUD for a VA, conventional, or private loan or were investigated and cleared by your own state agency then investigated a second time by HUD
✅ If you were pressured without evidence, especially to settle early
✅ If you suffered damages or retaliation…
📧 Please contact me at kjmull@aol.com
Include:
• Loan type (VA, conventional, private)
• Dates of HUD contact
• Any settlement pressure
• Description of damages (emotional, professional, financial)
Together, we will make history — and hold HUD accountable.
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📚 FOIA Reports Are Coming: HUD’s Illegal Numbers Will Be Public Soon
Pending FOIA requests will soon reveal:
• How many cases HUD opened, and closed, how long they were open for etc…?
• How many involved FHA loans.
• How many were illegally opened without jurisdiction.
The evidence is coming —
and HUD will not be able to spin it away.
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📚 Legal Disclosure
This article constitutes protected whistleblower activity under:
• Whistleblower Protection Act (5 U.S.C. § 2302(b)(8))
• First Amendment of the U.S. Constitution
• Federal Civil Rights Laws
Any retaliation will be immediately reported to federal oversight agencies.
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📢 The Reckoning Has Just Begun
HUD gambled that no one would notice.
That appraisers would stay silent.
That PAVE could hide behind headlines and slogans.
They were wrong.
The era of silence is over.
The era of reckoning has begun.
📧 Contact me: kjmull@aol.com
🔥 HUD’s PAVE Program: A Political Fraud Against Appraisers — and a Brewing National Scandal
Byline:
Rushed investigations. Ignored jurisdictional limits. Civil rights violations. As the truth emerges, appraisers nationwide are preparing to fight back against the government overreach that nearly destroyed their industry
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In 2021, under an Executive Order by President Biden, the Property Appraisal and Valuation Equity (PAVE) Task Force was created. Designed as a racial equity initiative, PAVE was formed to “root out bias” in the home appraisal process. It quickly became a centerpiece of the administration’s broader equity agenda, with the U.S. Department of Housing and Urban Development (HUD) leading the charge.
By Spring 2021, HUD and other agencies began setting up internal structures to launch mass “bias investigations.” By Fall 2021, millions of dollars were committed to expanding these efforts, without thorough legal vetting of how these investigations should operate across different loan programs.
In March 2022, the PAVE Task Force released its first public report and action plan. In national media interviews, HUD Secretary Marcia Fudge and other officials celebrated early “findings of bias” with the press, despite very little verified evidence. Appraisers quickly became scapegoats. News outlets carried daily headlines alleging systemic racism within the appraisal profession.
HUD’s narrative took hold: investigations were launched, public trust in appraisers eroded, and accusations of bias were treated as de facto proof without due process.
But critical federal procedures were ignored. Behind the scenes, investigations were rushed without checking jurisdiction. HUD pursued complaints against appraisers involving HUD (And Other Federal Agencies) but they only have legally investigative powers/authority over only FHA loans. This crucial distinction was buried in the complexity of federal regulations and “ignored or disregarded” in the rush to create “results.”
By Late 2022 into 2023, cracks began to appear. Lawsuits and challenges surfaced quietly. Appraisers and legal experts started to question whether proper legal processes had been followed. Today, in 2025, while the PAVE program itself has effectively been canceled, the damage remains.
Appraisers like myself (My investigations ongoing now for over 4 years), and others, were targeted, investigated, and suffered reputational and financial harm from a federal program that clearly overstepped its legal authority. Even though PAVE is no longer expanding, HUD is still fully liable for the harm it caused during its operation.
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Documented Handbook and Legal Violations
HUD’s actions did not merely violate good sense — they violated written federal policies, handbooks, and civil rights statutes.
Here are a few of the key violations:
• Failure to Properly Vet Homeowner Complaints:
o HUD Handbook 8024.1 REV-2 (Title VIII Complaint Intake, Page 1-5) requires “complete intake analysis” to determine whether a complaint meets jurisdictional requirements before opening an investigation.
o HUD failed to vet homeowners’ claims, rushing cases into full investigations based solely on allegations — violating their own intake protocols.
• ZIP Code Fishing (Evidence Fishing):
o HUD Handbook 8024.1 REV-2, Chapter 2, stresses that investigations must be based on “specific allegations” not “broad inquiries or searches.” Fishing for appraisals from specific ZIP codes without direct ties to alleged discriminatory conduct violates Title VIII investigative standards.
o Such fishing expeditions violate the Fair Housing Act’s requirement (42 U.S.C. § 3601 et seq.) that investigations be “prompt and impartial” — not targeted sweeps based on geography alone.
• Improper Settlement Offers Without Real Investigation:
o HUD Handbook 8024.1 REV-2, Chapter 6, requires “good faith conciliation” only after investigation establishes reasonable cause. Settlement demands “right off the bat” violate these standards.
o Coercive settlement demands made before fact-finding are prohibited under HUD’s Title VIII enforcement regulations (24 CFR § 103.310).
• Civil Rights Violations (Due Process and ADA):
o By targeting disabled appraisers without accommodations or proper investigation, HUD appears to have violated the Americans with Disabilities Act (ADA, 42 U.S.C. § 12101 et seq.).
o Procedural due process violations (Fifth Amendment) also arise when an agency abuses investigative power without jurisdiction or without giving the accused a fair opportunity to defend themselves.
These are not mere technicalities — these are clear violations of federal law and HUD’s own binding policies.
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The Building of a Case
Over the past year, I have been methodically building a case brick by brick. Every week, I uncover more evidence of wrongdoing: improper investigative practices, violations of due process, ADA retaliation against disabled appraisers, mismanagement of taxpayer dollars, and jurisdictional overreach.
Here is where it stands:
• I have filed Freedom of Information Act (FOIA) requests with HUD and the VA to uncover the full record.
• I have filed a formal whistleblower disclosure through the U.S. Office of Special Counsel.
• I have filed a formal complaint through GAO’s FraudNet, requesting a federal audit.
• I have filed a civil rights complaint and an ADA retaliation complaint with the EEOC.
This is not just about one appraiser — it’s about uncovering systemic government abuse that affected an entire profession.
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A Call to Fellow Appraisers
If you, too, were investigated unfairly, if you were subjected to bias accusations without due process, or if you were pressured improperly during the PAVE era — I want to hear your story.
We are compiling cases for a potential future class action lawsuit. Every story matters. Every story strengthens the undeniable truth that this was not about rooting out bias — it was about political optics, funding, and expanding agency power at the expense of your professional rights. I have now had about an estimated 30-45 documented cases on my books. Appraisers across the country have been contacting me with their stories, almost all are similar in scope and nature.
Please reach out and confidentially share your experience.
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Conclusion: The Movement is Just Beginning
The public narrative that “appraisers were systemically biased” was built on shaky ground — and now, piece by piece, the real story is coming to light. This movement is building every day. We are uncovering the truth, documenting the abuses, and preparing for the next steps to hold HUD accountable for the damage done.
Even though the PAVE program has been quietly abandoned, HUD remains liable for the harm it inflicted during its operation. The story isn’t over — it’s just beginning.
Legal Disclosure:
As part of this effort, all statements contained herein are based on documented facts, personal experience, publicly available federal reports, and filed government disclosures.
This article constitutes protected whistleblower activity under the Whistleblower Protection Act (5 U.S.C. § 2302(b)(8)), the First Amendment of the U.S. Constitution, and relevant federal civil rights statutes.
Any attempt to intimidate, retaliate, or suppress these protected disclosures will be immediately reported to the appropriate oversight and enforcement agencies.
Stay tuned. More revelations are coming.
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Contact Information for Stories: email me at kjmull@aol.com
Ken, knowing the background details of your case from the early days, I have to concur. You got screwed from day one, AND it was largely due to racist HUD Secretary Marcia Fudge’ seeking scalps.
There was never any credible evidence to begin with. VA clearing you should have been the end of the issue…but it wasn’t.
HUD had a habit of going fishing and asking for every file an appraiser had done for from 6 months to as much as three years.
While they had a LEGAL RIGHT to ask for VOLUNTARY COMPLIANCE, it turns out they had no actual right to the data they were demanding. Too many attorneys failed to call them out of that. The federal law they cited in every letter, inferring they had a right to demand your data was nothing more than a legal section that specified they ONLY had a right to ask for voluntary compliance.
As practiced by HUD, what they did was violate accused appraisers right to due process. Not to mention a right to NOT incriminate themselves!
I’m skeptical about the quality of legal representation you had on this from early on as well. That’s not your fault. Thats the case-milking E&O ‘legal’ system working against you.
HUD had no actual proof in every single case I ever reviewed. Not one. By going fishing, though, they were able to argue or threaten “Disparate Impact” scenarios and intimidate appraisers into settlements.
Now that President Trump specifically said there will be no more disparate impact claims by the DOJ, I’m amazed no one at HUD has sent you a clearance letter yet (let alone apologized).
Don’t give up hope Ken. Most of your fight was during the administration that most promoted phony race bias claims. Send a history of went you went through to Harmeet Dhillon, Civil Rights Division.
Next time false claims like this arise, learn the lessons of the past. Don’t be a white male from a good zip code!
BLOG DRAFT FOR WORKING RE MAGAZINE
Title: “Locked Out, Lied To, and Still Fighting: What HUD Doesn’t Want Appraisers to Know”
By Kenneth J. Mullinix
Fee Panel Appraiser | Appraiser Advocate/ADA-Protected Federal Contractor
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When the PAVE Task Force was launched in 2021 with political fanfare and heavy media attention, it was framed as a civil rights initiative meant to expose and eliminate racial bias in property appraisals. On paper, it sounded noble. But for those of us who found ourselves on the receiving end of its unchecked investigative power, PAVE became something else entirely: a blunt instrument, used to silence appraisers, ignore due process, and generate headlines rather than facts.
Now that the Biden-era PAVE initiative has effectively ended under the current administration, many assume it’s over. It is not.
The damage is still unfolding.
Investigations remain open. Cases were opened without jurisdiction. Evidence was ignored or buried. And most disturbing of all: key HUD officials appear to have operated in bad faith, violating federal rules, weaponizing internal systems, and actively stonewalling appraisers who dared to defend themselves.
I should know. I’m living it.
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My Case: HUD’s Stonewalling and a Supervisor Gone Rogue
My case began over 920 days ago. After being cleared in a detailed 266-day investigation by the U.S. Department of Veterans Affairs, HUD opened a duplicate case against me without jurisdiction. The case stemmed from a single disgruntled homeowner and was filed under the PAVE umbrella.
Since then, I have faced:
• Two separate charge letters (the second of which HUD initially denied even existed)
• False claims by HUD that I had legal representation when I did not
• A command to stop contacting the assigned investigator, even though the case remained open
• And now, complete lockout from HUD’s TEAPOTS case system with no new investigator assigned
The official responsible for this coordinated obstruction? Sally Y. Pai, Enforcement Branch Chief for HUD FHEO Region IX.
In recent months, I have uncovered what I believe to be a pattern of misconduct that includes:
• Blocking access to federal systems
• Freezing case files to prevent submission of rebuttal evidence
• Falsifying claims about personnel status (i.e., that the original investigator left HUD)
• And misrepresenting the procedural standing of my case in violation of ADA protections and due process
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The Bigger Picture: Three FOIA Filings and a Trail of Abuse
To date, I have filed three detailed FOIA requests:
1. Focused on my individual case and procedural misconduct
2. Targeting PAVE-wide statistics, funding justifications, and outcomes
3. Now, a request zeroing in on HUD Region IX’s internal case handling patterns, particularly under Pai and her team
These FOIA requests are not fishing expeditions. They are legal instruments designed to reveal whether HUD officials:
• Left cases open to justify program funding
• Falsely inflated bias statistics for media optics
• Coordinated politically charged investigations without factual basis
Early indications point to yes.
We are uncovering documents showing that the PAVE Task Force may have generated hundreds of investigations, including many against VA appraisers — despite having no legal authority to intervene in VA-governed loan programs. That alone raises serious questions of fraud, waste, and abuse of power.
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Why This Still Matters to Every Appraiser
Appraisers nationwide are still under threat from the ripple effects of PAVE. Even though the program has been politically shelved, the cases it spawned remain open, unresolved, and deeply harmful to those accused without cause.
Worse, the HUD officials responsible for PAVE’s abuses are still in place in many regions. The bureaucracy remains. The silence continues. And appraisers have little recourse to fight back.
Unless we fight together.
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Toward a Class Action and Real Accountability
Once the FOIA records are fully returned and verified, I intend to support or lead a class action lawsuit on behalf of the appraisers harmed by the PAVE initiative. Whether you were directly investigated or impacted by the chilling effect of unjust accusations, you may have standing.
HUD cannot be allowed to claim, “That was the last administration,” and walk away from years of civil rights violations and political targeting. Public trust has been broken. And this fight is not just about me — it’s about all of us.
If you were investigated under PAVE, or believe your case was politically motivated, I urge you to contact me. We’re documenting every story. And the day is coming when HUD will have to account for what it did, what it ignored, and who it tried to silence.
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We are not going away.
You may have been bullied. You may have been afraid to speak. But know this: someone is still fighting, and I am not done.
Stay tuned. Stay loud. And stay protected.
Kenneth J. Mullinix
VA Fee Panel Appraiser
Email: kjmull@aol.com