FOIA, AI, & the Appraiser’s Defense: A Blueprint for Fighting Back
For decades, appraisers have worked in silence, held hostage by regulations, scrutiny, and — recently — false narratives of systemic racism. When the Biden administration launched the PAVE Initiative, it claimed to champion equity in housing. But behind the curtain, it became a political tool. The result? Appraisers like me were targeted based on ZIP codes, stripped of due process, and labeled racist — often without a shred of evidence.
My story is not unique. But my strategy is.
When HUD opened a case against me, I did what most would do: I tried to cooperate. I waited. I asked for my file. Nothing came. I was locked out of TEAPOTS. Emails went unanswered. And then the letters started — accusations, then silence, then a phishing-style FOIA denial through an expiring DocuSign link. But I had a secret weapon:
I used artificial intelligence.
With AI, I analyzed HUD handbooks, mapped violations, cited federal statutes, and drafted responses within minutes — letters it would take most attorneys weeks to construct. When they invoked FOIA Exemption 7(a) (an illegal filing), they thought I’d be confused. Instead, I documented it, appealed it, and sent it to the Department of Justice. Now they are notified of HUD’s abuses towards the Appraisal Industry.
This isn’t just about HUD anymore. It’s about every licensed appraiser in the country who faces:
- Baseless complaints from homeowners
- Intimidation from AMCs or lenders demanding higher values
- Retaliation from state boards under political pressure
- Frivolous E&O insurance claims
With AI, you can fight back — and win.
What You Can Do With AI:
- Draft legally compliant rebuttals
Use AI to generate clear, professional responses to condition disputes or value reconsiderations — based on paired sales analysis, USPAP compliance, and pull regional market data. - Protect your license and insurance
AI can help you write persuasive letters to state boards, include legal citations, reference applicable FHA/VA/HUD guidelines, and highlight procedural violations against you. - Investigate and document patterns
Use AI to search public HUD/FOIA documents, extract contradictions in PAVE enforcement, and build a timeline proving abuse or coordinated misconduct. - Challenge appraisal bias claims
Leverage AI to cite recent legal rulings — like the recent federal judge’s decision invalidating race-based claims against appraisers — and reference data showing objective appraisal methods. - Write addendums that defend your work
Explain local market conditions, define appraisal methodology, and summarize USPAP compliance in plain language backed by data and legal precedent. - Track and audit your own reports
Use AI to internally review your appraisal files for consistency, formatting, and language that may be misconstrued — reducing the risk of allegations before they arise.
The Turning Point
When I filed my DOJ complaint (Case #550315-XMF), it included over 50 letters, exhibits, FOIA filings, ADA disclosures, and certified evidence. The PAVE case against me had been manufactured — and now, the government couldn’t bury it. My AI-generated timeline, my structured legal citations, and the second charge letter they claimed didn’t exist — all proved one thing:
They weren’t ready for someone to fight back. And they certainly weren’t ready for someone using AI.
A Blueprint for Appraisers Nationwide
If you’re an appraiser facing:
- A complaint from a borrower or homeowner
- Pressure from a lender to adjust a value
- A state license inquiry or USPAP challenge
- FOIA barriers or federal investigation threats
You can use AI right now to:
- Write a response to the borrower
- Summarize market condition data and comparable support
- File a FOIA appeal
- Document every legal point you need to protect your career
You don’t have to be a lawyer to protect yourself anymore. You just have to be prepared — and AI can be your tool, your teammate, your advocate.
The Bottom Line
HUD thought I would fold. So did the VA. But I didn’t. I’ve now turned their own policies against them — legally, ethically, and transparently.
This isn’t David vs. Goliath. This is David v. Goliath 2.0 — and I brought a digital slingshot.
I urge every appraiser reading this to stop fighting with one hand tied behind your back. Start defending yourself like I did.
And to HUD and the architects of the PAVE Initiative: You might have the funding. But I have the truth — and the technology to prove it.
- FOIA, AI, & the Appraiser’s Defense: A Blueprint for Fighting Back - June 13, 2025
- WA Appraisers Stung by Fee Hikes and Veto - June 6, 2025
- UAD 3.6: The Appraisal Industry’s Shiny New Straightjacket - May 30, 2025
Ken, I really admire how you’ve leveraged AI to push back against bureaucratic overreach. Your persistence, especially in navigating FOIA & citing federal statutes, sets an important example for other appraisers facing similar pressures.
That said, one caution I’d offer, from one peer to another: if you’re using 3rd-party AI tools like ChatGPT to process appraisal content, just be cautious about what’s being shared. Under USPAP & GLBA, nonpublic personal information (NPI) includes things like client names, borrower addresses, loan terms, interior photos of the subject property, especially if they show personal belongings, internal appraiser notes, or even email exchanges with clients. Sharing those details with external tools, unless fully redacted or run through a secure, vetted platform, could put you at risk of violating confidentiality rules, especially with HUD, VA, or state regulators looking over our shoulders.
There are secure ways to use AI while staying compliant – anonymize NPI before input, stick to policy citations or process summaries, & avoid uploading full reports to tools that aren’t designed with privacy at their core.
Your case is important. So is protecting the integrity of how we fight it.
I admire his tenacity. I hope it does him and us some good.
I use AI every day. It does for you what your best employee on their best day would do and all in a few seconds.
And I can tell the article was run through AI too! It loves to show off!
Thank you Ken for your efforts and for sharing them
HUD is attempting to charge me over $1,000 for my FOIA request to prove they inadvertently close loans reviews at the lowest severity level excusing lenders without the required field review against their own policies and procedures.
https://appraisersblogs.com/uncovering-flaws-in-fha-appraisal-n-loan-review-process/#google_vignette
Harm – sorry to hear your troubles send me the documents to my email and I will look at them for you, Ken- kjmull@aol.com.
Good for you. Thank you for doing that. My FOIA requests to HUD went nowhere. They gave me impossible hoops to try to jump through or they didn’t reply at all. Once when I requested a copy of specific complaints about appraisers they told me I needed a signed, notarized statement from complainant with their name, birth date, nation of origin stating they allow me to have the data. Ridiculous and illegal. I filed an appeal and the same. I was going to file a motion to compel lawsuit but got busy.