So appraisers out there please take my post to heart and if you have any information that can help the cause please contact me. Ken

Please state the name of the law firm you have hired to assist you in this matter.

Please confirm to the people whom may wish to participate with you directly, that you are not misleading them into a situation without actual legal representation.

If you’ve been contacted, questioned, or “investigated” by HUD under the PAVE or bias complaint process, this message is for you.

In recent years, hundreds upon hundreds of appraisers across the country have received letters from HUD suggesting they’ve been accused of appraisal bias or discrimination. Some of these letters use strong language. Some reference civil rights violations or FHA enforcement authority. Many appear designed to pressure appraisers into settlement, silence, or submission — even when no clear wrongdoing is alleged.

But here’s the truth: many of these “investigations” may not be legal at all.

I’ve spent the last three years digging into how HUD’s regional enforcement offices — particularly under the PAVE initiative — have pursued appraisers with little or no jurisdiction, often bypassing the standard complaint procedures outlined in federal regulations. What I’ve found is deeply troubling.
This isn’t about protecting bad actors. It’s about protecting good professionals from being used as scapegoats in a broken political narrative.
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❓What I’m Looking For:

If you received any of the following from HUD:

• A letter accusing you of appraisal bias or discrimination
• A formal “charge” letter or “Notice of Investigation”
• Any communication from HUD Region IX, or any regional FHEO office
• An invitation to “conciliate” a complaint you were never shown
• FOIA denials or missing documents after requesting your file
• A complaint tied to a property that wasn’t FHA-related

…I want to hear from you.

I’m specifically looking for copies of letters, emails, and notices HUD sent to appraisers in the past three years, particularly those that appear to initiate civil rights cases or bias reviews.
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Why This Matters

Here’s what I’ve learned: in many cases, HUD does not have legal authority to investigate these complaints — especially if the loan was VA, conventional, or not subject to FHA funding or oversight. Yet appraisers are still being pulled into murky processes with no transparency and no due process.

In some cases, the “charges” appear to be nothing more than internal memos disguised as enforcement letters. In others, HUD offices seem to be misusing FOIA exemptions to withhold the very documents appraisers would need to defend themselves.

What’s worse — many appraisers don’t even know they have the right to push back.
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What I’m Building

I’m compiling a database of HUD investigation letters, charge notices, and correspondence from affected appraisers nationwide.

The goal is simple:

• Identify patterns in how HUD has approached these cases
• Analyze the legal footing (or lack thereof) in each
• Share findings with appraisers, advocates, and oversight groups
• Ensure that those who’ve been wrongfully investigated can respond effectively — and possibly seek redress
I believe the evidence will show a pattern of legally questionable enforcement tactics — and that many cases should never have been opened.
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How to Contact Me

If you’re an appraiser who received communication from HUD related to appraisal bias or discrimination — I want to review your letter.

Email me directly and confidentially at:
kjmull@aol.com

All documents shared will be treated with discretion and reviewed only for legal framework analysis — not public disclosure.

The agencies responsible will be held to account for marking the appraisal industry in general us all as as “Racist” will be rectified and the general public and the government will soon hold those responsible to the fire. I am making sure of that just have faith in me and what I am trying to accomplish.

https://appraisersblogs.com/uncovering-flaws-in-fha-appraisal-n-loan-review-process/#comment-45542

IOT, AI, Lidar, others use of IOT devices, privacy concerns.

From Cars to Jewelry to Appliances — How the Internet of Things Invades Your Privacy Without Your Consent

He’s like; yeah I kind of just voted the way they told me to vote. Did not really have much of a choice.

Personally I think I’ll pass on AI. For life. Where is the off button? The next big thing fans are going to have to reconcile the fact many of us do not want to use this technology. That we find this approach objectionable and demand the ability to opt out. Already there are people proposing taxing AI in order to supplement all the millions of human jobs it will eliminate, the excess energy it unnecessarily consumes.

Think objectively here. We watch this insane build up over our lifetimes of a total interconnected world where technocratic interests, corporate and governance alike, all race towards extreme exploitation tracking and retention of every iota of data possible on the entire world. They create such incredibly advanced tools. The immediate result is exploitation of the system. Where is the actual benefit here for every day people other than these machines ability to act like a librarian and find data references, laid forth in a human writing style in what’s called LLM or language learning model outputs? It’s artificial intelligence because it’s not real intelligence. The advanced silicon processing chips or ‘quantum computers’ are built around a theoretical model that mimics the human mind. But they don’t come anywhere near to a human, because they are soul less and devoid of empathy and logic. The human mind is the original quantum computer.

99% or more of all humans using AI tech can not answer basic questions about Moores law, quantum computing, isotopic relations to the ever changing physical hardware used in advanced processing. How the varying material used in the quantum computing machines themselves actually effects the output of the simulation. How photons may be interacting within the hardware. In their ignorance they call this an ‘ai hallucination’. They can’t have basic conversations about what quantum computing is, how that’s different than analog systems, how quantum theory diverges from newtoneon physics, how the nature of quantum processing allows two answers to be simultaneously correct in the ‘mind’ of those computers. Because this new tech is apparently so advanced, let it do the thinking for them, speak for them, write for them, make personal and business decisions on their behalf. Yet they never slow down to ask the most fundamental questions what it means to be human and if this technology is more destructive than beneficial.

Ken your bot is short circuiting, it’s only focusing on false complaints and completely ignored a decade and a half of content which revolved around this website the many peoples here, our arguments and requests to save the appraisal industry to limit financial predation on every day American consumers, to save everyones careers long term. And it behaves that way because you’re using it that way, that machine is your advocate and no one elses unless they are directly aligned with the limited scope of your personal goals in using the machine. I’m sorry, it’s just not the real thing. This is not enough.

People should put the TURK back in the closet and quit playing around like it’s a toy. Not worth the risk to win a game of chess or save the few hours it may take to write a legitimate paper.

What if the agency investigating you also controlled the only door through which you could defend yourself — and then locked it shut?

That’s what happened to me. I’m a VA-approved appraiser with decades of experience, and in 2021, I was falsely accused of bias by a borrower whose refinance appraisal I completed. Despite the VA clearing me and confirming no discrimination took place, HUD opened a parallel investigation that spiraled into something far more disturbing: a case of retaliation, civil rights violations, and systemic abuse of federal process.

For nearly four years, I have been fighting to clear my name and expose what I believe is a programmatic misuse of civil rights investigations for political optics and funding retention under the PAVE initiative. But just weeks ago, the fight took a darker turn.

After submitting hundreds of pages of documentation to HUD and the VA, I attempted to send new exculpatory evidence through HUD’s online portal. The upload failed. I then emailed the same documents directly to HUD’s FOIA and enforcement officers. I was met with this message:

“550: 5.4.1 Recipient address rejected: Access denied.”

In other words, the very agency investigating me had blocked me from submitting evidence that could clear me — including my rebuttals, FOIA proof, and direct contradictions to the original complaint. Days later, I discovered that this was no error: I had been formally cut off from HUD’s email system, with no explanation.

This came after HUD cited Exemption 7(A) to withhold documents in a FOIA request — claiming the case was still “open,” even though the VA had cleared me months earlier. The same exemption was used to justify redactions and refusal to provide records. Meanwhile, the investigation continued in silence.

HUD’s internal legal and enforcement branches have refused to respond to multiple certified letters. The EEOC has closed my complaint without ever contacting me. And to date, I have received no formal charges, no hearing, and no opportunity to defend myself in any transparent forum.

This isn’t due process. It’s procedural suffocation.

Worse, I am not alone. Other appraisers and even homeowners have come forward with eerily similar stories of FOIA obfuscation, blocked communication, and suspicious investigation timelines tied to the PAVE program. What started as an initiative to address appraisal bias now appears to be entangled with grant-driven investigations, ZIP code profiling, and retaliatory targeting of cleared professionals.

To be clear: I support true civil rights enforcement. But what I’ve experienced is something else entirely — a ghost investigation kept alive through silence and suppression.

I’ve submitted everything to the Department of Justice Civil Rights Division, filed multiple FOIA appeals, and am now seeking congressional and media exposure. But the most dangerous thing isn’t the investigation. It’s the fact that HUD believes it can shut out a whistleblower entirely and no one will notice.

If this can happen to me, it can happen to any appraiser. We are not just battling bias accusations — we are battling a broken system.
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Editor’s Note: If you’ve had a similar experience with HUD, FOIA denials, or retaliation under the PAVE initiative, contact Working RE Magazine. Your story matters.

*Andy Askbite was primarily responsible for handing your fees to AMCs in 2009.

They’ll train AI to do every which task this way and sideways, automate everything, review everything. Mysteriously nobody asks the AI systems if the implementation of automation and the removal of full service real estate appraisers may in any way correlate with affordability challenges, rise in fraud, market instability, etc, etc. Looks more like a tool of fraud than anything meant to prevent fraud. Who’s still buying this?
______________________________________

https://appraisersblogs.com/the-appraisal-professions-perfect-storm-a-veterans-take-on-a-dying-craft/#comment-45510

Ran across this article today, check this out. Must read and an excellent article appraisers should share.

Notice any time line correlations to these dramatic up shifts in fraud and affordability issues having to do with changing appraisal industry policy?

https://www.zerohedge.com/personal-finance/how-housing-bubble-2-bursts
https://charleshughsmith.blogspot.com/2025/06/how-housing-bubble-2-bursts.html

Another AI generated letter, spammed to the board. Call a lawyer already.

Date: 06/21/2025

This post is for every real estate appraiser who has received a HUD charge letter, or fears they might. What happened to me was not just an attack on my professional reputation — it was a breach of my civil rights, a disregard of federal appraisal standards, and an abuse of investigative authority.

I have contacted the Civil Rights Department of the Department of Justice, and the DOJ in also another division, the Office of Inspector General at HUD, and the Office of Inspector General of the Veteran’s Administration among other government agencies. So investigations by the government are in progress as well.

Using AI-assisted analysis, I dissected HUD’s letter and uncovered numerous violations — of constitutional rights, federal law, HUD’s own Handbook 4000.1, USPAP, and basic principles of due process. This article shows how technology like AI can help protect our profession, expose government overreach, and prepare a proper defense.
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Exhibit A: The HUD Charge Letter File: HUDDEMAND._000016.pdf

This document alleged that I, as a real estate appraiser, committed discriminatory conduct in one of my appraisals. Yet, it offered no specifics, no citation of evidence, and no actionable violation. Worse, it demanded unrelated appraisals from other ZIP codes — a tactic designed to find, not follow, evidence.
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1. Lack of Specificity in Allegations (Due Process Violation – Fifth Amendment) The charge letter failed to identify any concrete language, valuation method, or data I used that constituted discrimination. Instead, it implied guilt by insinuation.

• Violation: Fifth Amendment — Right to due process.
• Federal Standard: Administrative Procedure Act (APA), 5 U.S.C. §706(2)(E) — agency decisions must be based on substantial evidence.
• HUD Handbook 4000.1 Reference: Section II.D.4 — HUD investigations must be based on specific, supported complaints.
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2. Fishing for Evidence (Fourth and Fifth Amendment Violations) HUD requested appraisals from other ZIP codes — unrelated to the subject property or complaint.

• Fourth Amendment Violation: Prohibits unreasonable search and seizure.
• Fifth Amendment Violation: Protects against compelled self-incrimination.
• Legal Concept: This is a “fishing expedition,” an unconstitutional overreach.
• HUD Handbook 4000.1: No provision authorizes requesting unrelated work products without a legitimate basis.
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3. Presumption of Guilt Before Investigation (APA and Due Process Violation) The letter reads as if a verdict has already been reached. There’s no neutral language, no allowance for explanation — only assumption and pressure.

• APA Violation: Section 553 — agencies must act impartially and not issue decisions before reviewing evidence.
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4. First Amendment Violation (Chilling Effect on Professional Speech) If the charge stems from my description of neighborhood characteristics, sales trends, or other factual data — then HUD is punishing appraisers for doing their job.

• First Amendment Violation: Freedom of speech and professional expression.
• USPAP Reference: Ethics Rule and Scope of Work Rule — appraisers are required to provide objective, market-based reporting.
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5. HUD’s Jurisdictional Overreach HUD is not a licensing body. It cannot discipline appraisers outside the scope of FHA program participation.

• Legal Limitation: 12 U.S.C. §3341 — state boards hold disciplinary authority.
• Overreach: Any attempt to coerce or penalize appraisers directly exceeds HUD’s legal limits.
________________________________________

6. Interference with Appraiser Independence (Dodd-Frank and HUD Handbook Violations) The letter appears to intimidate me into changing or disclosing appraisals to match HUD’s social objectives.

• Violation: HUD Handbook 4000.1, Section II.A.1.b.iv — prohibits undue influence.
• Dodd-Frank Act (2010), Title XIV, Section 1472: Makes it illegal to attempt to influence appraisal outcomes.
________________________________________

7. Equal Protection Violation (14th Amendment) If HUD is selectively targeting appraisers as part of the PAVE initiative without evenhanded standards, that is discriminatory enforcement.

• Violation: Fourteenth Amendment — Equal Protection Clause.
• Implication: Appraisers may be targeted for perceived, not proven, bias — and held accountable to undefined social expectations.
________________________________________

A New Tool for Defense: AI Dissection of Government Charges This case also shows how AI tools can assist in:

• Rapidly analyzing and summarizing government documents
• Cross-referencing Handbook rules, civil rights statutes, and appraisal standards
• Identifying coercive language, procedural errors, and potential legal claims

Fellow appraisers: you are not alone. If you’ve received a similar letter, AI can be part of your defense. Share your story. Speak up. Hold agencies accountable.
________________________________________

Conclusion: This Is Bigger Than Me This isn’t just about one appraiser. It’s about preserving independence, professionalism, and civil rights in our industry. HUD must follow the laws it enforces, respect constitutional protections, and uphold procedural fairness.
To my peers: Stand your ground. Know your rights. Use technology wisely. And never forget — your voice matters.
________________________________________

About the Author Kenneth Mullinix is a certified VA and FHA appraiser with decades of field experience and a clean record of independence and accuracy. After enduring five strokes, he continues to fight — this time, for the rights of appraisers across the country.
________________________________________

Call to Action: Join the Fight I am currently initiating a class action lawsuit against HUD for civil rights violations, due process breaches, and procedural misconduct tied to its treatment of independent appraisers.
Lawyers, appraisers, and anyone in the industry who has received a similar letter — or who wants to support this cause — please contact me.

Together, we can hold HUD accountable and restore integrity to our profession.

What happens when a federal agency promises civil rights justice, collects millions in federal grants, and then quietly drops cases it never legally opened?

HUD’s PAVE initiative wasn’t just a failure — it was a double-sided fraud.

Recent evidence now shows that the Department of Housing and Urban Development (HUD), through its PAVE (Property Appraisal and Valuation Equity/now closed but still has active cases) Task Force, misled homeowners into thinking their complaints were being formally investigated under federal civil rights law — when in fact, no legal case was ever opened.

This revelation cuts to the heart of the PAVE narrative and raises questions about fraudulent use of federal funds, false reporting to Congress, and public deception at the national level.
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HUD’s Legal Jurisdiction: What They Can’t Investigate

Under the Fair Housing Act and related statutes, HUD only has legal jurisdiction over appraisal bias claims involving:
• FHA-backed mortgages
• Programs subsidized by HUD grant funds

They do not have jurisdiction over:

• VA loans (administered by the Department of Veterans Affairs)
• Privately funded loans
• Conventional mortgages held by Fannie Mae or Freddie Mac without FHA insurance

And yet, homeowners with VA or private loans were told they had valid discrimination cases under HUD oversight — when legally, HUD couldn’t pursue them.

HUD used a tactic called a “risk assessment” — an internal review that mimics an investigation but has no legal standing. These risk assessments were never entered into HUD’s legal tracking system (TEAPOTS) and were never disclosed as non-binding. An estimated 15% of all loans nationwide are FHA backed.
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The Homeowner Illusion

In one documented case, a homeowner was told their complaint against an appraiser was a civil rights case. HUD told them they were under formal review. But no case file existed, and no closure letter was ever issued.

HUD never told the homeowner:

• That it lacked jurisdiction due to the loan being VA-backed
• That no formal complaint had been filed under HUD Form 903.1
• That their complaint was being used for PAVE grant justification
The homeowner was led to believe they were part of a historic civil rights moment. In reality, they were a data point in a political funding scheme.
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Secretary Fudge’s Public Misrepresentations

HUD Secretary Marcia Fudge publicly claimed in 2023:

“We’re holding appraisers accountable. We have over 800 bias cases open across the country.”
This statement, made to the media and cited in congressional reports, formed the basis for continued funding of the PAVE Task Force. Yet recent internal reviews show that the vast majority of these “cases” were risk assessments, not formal investigations. HUD never explained the distinction — not to homeowners, not to Congress, and not to the public.
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The Appraiser Demographic Misdirection

In support of PAVE, several advocacy groups and HUD-aligned media outlets circulated a now-debunked statistic:
“95% of appraisers are white — therefore the system is biased.”

This framing was used to push urgency for PAVE, implying that statistical whiteness equated to discrimination. However, independent reviews later showed that the appraisal industry reflects larger licensing trends, and no systemic racial bias was found in credible field studies.

Still, this misleading claim fueled HUD’s push for PAVE enforcement, contributing to millions in grant allocations, new staff hires, and regional office expansions.
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Fraud on Both Ends

By misleading:

• Homeowners into thinking they were involved in real cases
• Congress into believing hundreds of legal investigations were active
• The public into thinking PAVE was rooted in due process

…HUD effectively played both sides:

• It used complaints that never became legal cases to justify funding
• It dropped cases without disclosure, violating borrower trust
• It blocked further access to records through misused FOIA denials
The result? A false narrative, fueled by federal dollars, built on phantom enforcement.
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What Needs to Happen Now

Congress must demand:

• A full audit of all PAVE “investigations” opened since 2021
• Disclosure of how many cases were actually entered into TEAPOTS
• A refund or clawback of PAVE-related funds spent on non-jurisdictional cases
• A review of all communications to homeowners and appraisers who were misled

This isn’t just bureaucratic failure. This is potential fraud under the False Claims Act — using fake enforcement optics to secure real money.

HUD must explain how it:

• Investigated complaints it had no legal right to pursue
• Counted risk assessments as “active cases”
• Misled homeowners and appraisers alike
• Avoided FOIA disclosure by claiming phantom legal authority
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Conclusion

The PAVE program was sold as justice. But its execution has revealed injustice of another kind — one where narrative mattered more than legality, and numbers mattered more than people.
This is a call for accountability, transparency, and restitution.

HUD’s silence is no longer acceptable.

Good advice, thanks again Ken

In today’s regulatory climate, appraisers can no longer assume they’re safe from scrutiny just because they did nothing wrong. With the political pressures of HUD’s PAVE initiative (now winding down but still active with cases) and heightened sensitivity around appraisal bias, even a routine assignment can spiral into an administrative nightmare. I know this firsthand.

Here are 10 critical actions every appraiser should take — not after you’re accused, but the moment any sign of an inquiry appears. These steps may determine whether your case escalates or ends quickly.
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1. Request Everything in Writing

Why it matters: Investigators may call you casually, asking questions as though it’s no big deal. But anything you say can be used against you, and verbal conversations can be mischaracterized.

What to do: Politely ask that all questions or concerns be submitted in writing. Then respond in writing — preferably after reviewing with a trusted peer or legal advisor.
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2. Know Who Has Jurisdiction

Why it matters: Agencies often overstep. HUD has no jurisdiction over VA appraisals only with FHA loan, yet in my case, they pursued me anyway. If you don’t challenge jurisdiction, they may proceed unlawfully.
What to do: Ask: “What law, policy, or statute gives your office authority over this appraisal or complaint?” Document their answer.
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3. Request a Case Number and Tracking ID

Why it matters: Many appraisers are caught in shadow “risk assessments” that aren’t formally opened in HUD’s TEAPOTS system. If there’s no case number, you may have no due process rights.
What to do: Ask for a formal case number and tracking ID. If they refuse, note it in writing and ask again. This can be crucial later.
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4. Submit a Written Statement — But Control the Format

Why it matters: Agencies may pressure you into interviews, but you risk being quoted out of context. A written rebuttal lets you control your language and ensure accuracy.
What to do: Provide a formal written statement addressing each issue raised. Avoid opinions or assumptions. Stick to verifiable facts and cite exhibits.
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5. File Your Own FOIA Request Immediately

Why it matters: FOIA (Freedom of Information Act) lets you request the government’s internal communications and files about your case. If used early, it can reveal agency bias, misconduct, or case flaws.
What to do: File FOIA requests with all relevant agencies (e.g., HUD, VA). Ask for emails, memos, call logs, and intake forms related to your name and file. Keep your request specific.
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6. Save Everything — Emails, Envelopes, Metadata

Why it matters: Seemingly small details can later disprove agency claims. For instance, a postmark can contradict a claim that a letter was sent earlier. An email’s header can reveal forwarding patterns.
What to do: Save all correspondence — not just content, but envelopes, headers, footers, even screenshots of website activity. Back them up off-site or to the cloud.
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7. Demand a Copy of Any Video or Audio Evidence

Why it matters: If a complainant submits Ring footage, it may show the opposite of their claim. In my case, it proved I was respectful and professional — yet the video was never provided to me.
What to do: In writing, request any video or audio evidence submitted by the complainant. If denied, cite your due process rights and note the refusal in your record.
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8. Watch for FOIA Red Flags

Why it matters: HUD and others may illegally deny FOIA requests using false exemptions, or fail to assign tracking numbers. This prevents appeals and hides misconduct.
What to do: If you receive a FOIA denial:
• Check for a case/tracking number.
• Look for a signature, appeal instructions, and basis of denial.
• If any are missing, document it — and consider filing a FOIA appeal or complaint to the Office of Government Information Services (OGIS).
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9. Document Retaliation

Why it matters: If you speak out, file FOIA requests, or push back — and then experience access blocks, threats, or delays — it may be retaliation. That’s illegal.
What to do: Log every incident: email blocks, upload denials, refusal to respond. File a police report if a government letter appears altered. These records become key if you pursue legal action or whistleblower protections.
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10. Tell Your Story — or You’ll Be Silenced

Why it matters: Staying quiet lets the agencies control the narrative. But when you speak publicly, they can’t rewrite the facts as easily.

What to do: Start by documenting your story. Then share it — with your peers, your attorney, your association, or a publication like Working RE. I chose to go public because it was the only way to force accountability.
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Final Thought:

You don’t have to be an expert to defend yourself. But you do need to be organized, persistent, and vocal. These 10 steps helped me survive — and might help protect the next appraiser from being destroyed by a false narrative.
We’re stronger when we stand up together.

Kenneth J. Mullinix
VA-Certified Appraiser | Whistleblower | Newport Beach, CA