BDL, I thought I knew Jim Parks, too. Clearly, I was mistaken. I don’t care how seriously feds take their responsibilities if they are ineffective.

Or worse, complicit in the subterfuge, as FHFA HAS been. Especially when FNMA was basing forced buy-backs on a quota system rather than for any legitimate defects in the loan or appraisal package.

We both agree, however, that the GSEs need to be cut loose. Similarly, FIRREA needs to be revisited or eliminated since it is not uniformly applied. If Congress is determined to repeat the judgment lapses of the late 1980s and 2007-2008, then a repeat of ‘too big to fail’ is virtually guaranteed.

If we can’t prevent that, the very least we can do is challenge the regulators’ “plausible deniability”.

For the past several years, I’ve been deeply engaged in research on HUD’s enforcement actions against appraisers — specifically in cases involving civil rights, bias allegations, or “PAVE” (Property Appraisal and Valuation Equity) program referrals.

One critical piece of this puzzle is the HUD “charge letter” — the official document HUD issues when it opens or sustains an enforcement action against an appraiser. These letters typically outline:

The nature of the complaint

The alleged violations

Any procedural steps HUD claims to have taken

The legal statutes or regulations cited

If we can gather enough of these letters from across the country, we can begin to identify patterns — such as:

Whether HUD’s justifications for opening cases are consistent

How often cases stem from initial complaints with no proven factual basis

Whether HUD is applying certain laws or “risk assessment” models disproportionately to certain markets, zip codes, or types of loans

The degree to which HUD-backed nonprofit entities are involved in referrals

Why This Matters:

Many appraisers have faced bias-related investigations or charges in recent years, often under intense political and public pressure. While some of these cases may have merit, others appear to be based on questionable grounds, with procedural shortcuts and lack of proper jurisdiction. A national pattern, if it exists, could reveal whether enforcement practices are fair — or if certain appraisers or regions are being targeted unfairly.

What I’m Asking:
If you are an appraiser who has received a HUD charge letter — or a charge letter from a nonprofit or entity acting under HUD authority — please consider sharing a copy with me for research purposes.

Important:

You may redact personal identifying information, property addresses, or other sensitive data before sending.

I am not seeking to re-litigate anyone’s individual case — this is about building a research database to identify patterns in HUD’s enforcement nationwide.

If requested, I will keep your identity confidential and will only use the document’s substantive content for analysis.

What I Will Do With This Information:

Review each letter for statutory citations, procedural steps, and patterns of enforcement.

Compile an anonymized national summary for publication and discussion in the appraisal community.

Share insights with industry advocates and publications so we can have an informed conversation about HUD enforcement trends.

If we can pool our experiences and documents, we may be able to answer a question that many in our profession are quietly asking:

Are HUD’s enforcement practices consistent, lawful, and fair — or are some appraisers being swept into a political or programmatic dragnet?

How to Contribute:
Email a redacted copy of your charge letter to: kjmull@aol.com

The more of these documents we can collect, the clearer the picture will become. If you’ve been on the receiving end of a HUD charge letter, your experience matters — and together, we may be able to bring transparency to a system that has remained in the shadows for too long.

Thanks for posting. This was a great article. Sadly, the FHFA never actually did anything to help the appraisal profession.

Nothing actually happened, not for appraisers.

The people deserve better. They deserve the truth. Don’t expect the truth anytime soon in this industry. Might as well rebrand as the appraisal management industry basically runs everything now.

Admin said will post more articles soon, had been busy for the past few months.

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
________________________________________

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.
________________________________________

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
________________________________________

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.
________________________________________

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.
________________________________________

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.
________________________________________

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

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.

Thanks Baggs…Id almost forgotten about that article. Got side tracked fighting phony complaints against appraisers for the next 6+ years!

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!

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
________________________________________

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.
________________________________________

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.
________________________________________

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.
________________________________________

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.
________________________________________

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.
________________________________________

Contact Information for Stories: email me at kjmull@aol.com

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.
________________________________________

📚 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.
________________________________________

📚 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.
________________________________________

📚 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.
________________________________________

📚 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.
________________________________________

📚 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.
________________________________________

📚 ⚖️ 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.
________________________________________

📚 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.
________________________________________

📚 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.
________________________________________

📢 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

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.

Oops… I’ll refer you to Desiree 👆 lol

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.

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.
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💥 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.
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🧨 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.
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📣 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.

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.

That. Really. Happened.

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.
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📣 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.

17. Any questions?