https://www.valuationreview.com/vr/articlesvr/aei-housing-center-codirector-outlines-appraisal-b-95642.aspx?utm_source=enews&utm_orlocation=sty1

The damage is done.

After four years of chaos and millions in wasted funding, HUD quietly concedes what appraisers knew all along — PAVE was political theater dressed as policy.

For nearly four years, the appraisal industry has lived under the shadow of the PAVE Task Force — a government initiative that promised fairness but delivered confusion, retaliation, and overreach. The following letter, recently sent to Washington, lays out in plain language what many appraisers have quietly suspected: that HUD, the VA, and other agencies pursued bias investigations without lawful jurisdiction, using the PAVE initiative as a funding and political tool. This document is not speculation — it’s backed by internal emails, FOIA records, and direct admissions from federal officials. It exposes how the program blurred legal boundaries, inflated “civil rights” metrics, and harmed honest professionals under the guise of equity.

Working RE is publishing this letter in full because it represents more than one man’s case — it represents a turning point for the profession. The issues raised here affect every licensed appraiser in America, every lender subject to HUD review, and every taxpayer funding these “phantom” investigations. It is time for transparency, accountability, and reform!

Below is the full letter sent to Washington, just published:

WASHINGTON – U.S. Department of Housing and Urban Development (HUD) Secretary Scott Turner and Acting Administrator of the Office of Information and Regulatory Affairs (OIRA) at the Office of Management and Budget (OMB) Jeffrey Clark announced the termination of burdensome policies introduced under the Biden-era’s Property Appraisal and Valuation Equity (PAVE) task force. As part of the PAVE task force, members were directed to issue guidance on anti-discrimination obligations, review policies and practices, and issue new policies focused on “eliminating bias and advancing equity in home appraisals.”

Eliminating the core policies of the PAVE Task Force upholds President Trump’s Executive Orders, including Ending Radical and Wasteful Government DEI Programs and Preferencing and Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis.

The termination of specific policies eliminates unnecessary regulatory hurdles imposed on lenders, appraisers, and other program participants, which will allow HUD’s Federal Housing Administration (FHA) to better serve American home buyers and homeowners.

“By tearing down these onerous hurdles, we’re freeing professionals from a tangle of red tape that drove up costs, inhibited access to home ownership, and discouraged market participation,” said HUD Secretary Scott Turner. “Under President Trump’s leadership, the Biden-era’s obsession with DEI and over-regulation is over. At HUD, we’re restoring common sense and putting the American Dream of home ownership back within reach.”

The myth is that wokeism is just a social policy. And it surely is corrosive social policy. But, in reality, wokeism at HUD was brass-tacks economic policy that snatched away the American Dream of homeownership from an entire generation. That ends today,” said Acting OMB OIRA Administrator Jeffrey B. Clark.

Established in 2021, the PAVE task force exemplified government overreach by increasing bureaucracy using various tools aimed at addressing so-called systemic biases in the home appraisal process. It asserted that, in part, appraisals often result in systematic undervaluation of properties in black and Hispanic neighborhoods. However, data from the American Enterprise Institute (AEI) concludes that other characteristics unrelated to race – including educational attainment, average credit score, and family formation – are more likely significant drivers in differences between home values and appraisal outcomes.

“We’re encouraged that HUD and other agencies are beginning to roll back certain PAVE- inspired policies adopted by the Biden administration. These actions were driven by claims of race-based disparities in home values, mortgage denial rates, and appraisal under-valuations. These claims ignored AEI Housing Center research that found similar disparities in white communities with similar socioeconomic status, thereby invalidating the argument that the disparities were race based,” said Tobias Peter and Ed Pinto, Co-Directors at the AEI Housing Center.

As a result of pro-growth economic policies under President Trump’s first term, real household
income and wages grew at a record pace, including for individuals at all levels of educational
attainment and socioeconomic status. President Trump’s legislation continues many of these successful policies that create a stronger economy and greater home ownership opportunities for all Americans.

The terminated policies related to Reconsideration of Value and Appraisal Fair Housing Compliance include:

• ML 2024-16, Extension to the Effective Date of Appraisal Review and Reconsideration of Value (ROV) Updates
• ML 2024-07, Appraisal Review and Reconsideration of Value
• ML 2021-27, Appraisal Fair Housing Compliance and Updated General Appraiser Requirements

Current laws, including The Fair Housing Act and Equal Credit Opportunity Act, prohibit discrimination in all housing-related transactions including in the home buying and lending processes. The Fair Housing Act and Equal Credit Opportunity Act will continue to be enforced.

Kenneth J. Mullinix is a Certified Residential Real Estate Appraiser based in Newport Beach, California, with more than 25 years of professional experience serving the VA, FHA, and private sectors. After being wrongfully targeted under HUD’s PAVE Task Force, he uncovered extensive government misconduct and retaliation — ultimately exposing systemic overreach that affected appraisers nationwide.

Mullinix now dedicates his time to helping other appraisers, homeowners, and industry professionals navigate investigations, defend their rights, and understand the laws that protect them. His work has been featured in Working RE Magazine and in ongoing federal filings, where his case continues to shape the national conversation about fairness, due process, and accountability in housing policy.

You can reach him at kjmull@aol.com

When the PAVE Task Force was rolled out in 2021, appraisers were told this was a “whole-of-government” initiative to root out bias in valuation. What few in our profession knew at the time was that HUD and the Federal Housing Finance Agency (FHFA) signed a Memorandum of Understanding (MOU) on August 12, 2021.

On its face, the MOU looked harmless: a cooperation agreement signed by HUD Secretary Marcia Fudge and FHFA Director Sandra L. Thompson. But once you read it closely, a startling fact jumps out:
The MOU gave no new powers to any agency.
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What the MOU Actually Said
The MOU:
• Allowed HUD and FHFA to share information within existing laws (FOIA, Privacy Act, etc.).
• Allowed FHFA (and by extension, VA or others) to refer complaints to HUD if they appeared to involve housing discrimination.
• Allowed the agencies to collaborate on studies, policy reports, and training.
• Did not create new investigative or enforcement powers.
In other words: coordination only, within existing statutory authority.
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What HUD Actually Did
Instead of following the MOU’s limits, HUD began treating referrals from VA, FHFA, and others as automatic bias cases — even when they involved:
• Conventional loans, not FHA.
• Financial grievances reframed as “bias” (like my case, where the homeowner admitted it wasn’t race at all, but money).
• Complaints that never met Fair Housing Act standards.
This is how we got to HUD claiming where by my estimate had an estimated 1,500–2,000 bias cases nationwide — not because they were legitimate civil rights matters, but because HUD inflated referrals into full-blown investigations.
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Why This Matters to Every Appraiser
1. Jurisdiction Defect: HUD and other agencies had no authority to investigate civil rights complaints unless they rose to Fair Housing Standards. Referrals from VA should have been screened and closed. HUD had no legal right to accept them as cases.
2. Rocket Mortgage Case: Even Rocket’s case involves a conventional loan, where HUD has no jurisdiction. Yet DOJ is litigating it today as if it were a Fair Housing Act matter.
3. Fraud Risk: HUD used these inflated numbers to justify hundreds of millions in PAVE funding. If proven, this isn’t just regulatory overreach it could be illegal.
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The Signatures That Seal the Deal
Remember: this wasn’t buried in a staff memo. Marcia Fudge and Sandra Thompson signed this MOU. Their signatures confirm the deal was coordination-only. No expansion of law. No new enforcement authority. Which means HUD’s decision to run with these referrals as “bias cases” was outside the very framework its own leadership created.
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The Bigger Picture

If HUD can create phantom cases out of thin air, then every appraiser, lender, and AMC caught in this dragnet is fighting charges that may have never been legal to bring. And to press these cases while ignoring the MOU’s limits, it puts the entire PAVE program — and its $357 million price tag — in jeopardy.
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Final Thought

The appraisal profession isn’t afraid of fair housing laws. What we are afraid of is the abuse of process — being hauled into investigations that have no lawful basis, simply to feed a political program.
The MOU shows us one thing clearly: the PAVE program was built on coordination optics, not on new law. And HUD’s decision to treat those optics as authority is why appraisers are now at the center of one of the largest federal fraud exposures in housing history.
________________________________________

About the Author
Kenneth J. Mullinix is a Certified Residential Real Estate Appraiser (California OREA License #AR027585) with over 25 years of experience serving Southern California. He is VA- and FHA-approved, a certified home inspector, and a licensed (inactive) real estate broker and contractor.
He has become one of the nation’s leading voices exposing HUD’s misuse of the PAVE Task Force, FOIA abuse, and phantom bias cases.

Kenneth offers consultation services to appraisers, attorneys, and lenders navigating HUD/VA/FHFA appraisal complaints. He is available to answer questions and provide guidance to professionals who find themselves caught in this new wave of investigations.

Disclaimer: This article reflects the author’s professional opinion and analysis of publicly available documents and regulations. It does not constitute legal advice.

Contact: kjmull@aol.com

The civil case was dropped? Can you sent a source?

https://www.valuationreview.com/vr/articlesvr/senator-urges-investigation-into-hud-whistleblower-95575.aspx?utm_source=enews&utm_orlocation=sty6

Over the past few years, our profession has been under pressure like never before. Bias accusations, phantom investigations, FOIA denials, and political optics have left many appraisers feeling isolated, vulnerable, and unsure where to turn.

But here’s what I’ve learned: when we stand together, we’re stronger than any agency or headline.

In the past several months alone, I’ve had 15–20 appraisers reach out to me directly for help. Each one had a different case, but the themes were the same: a lack of due process, overreach by agencies, and accusations built on speculation rather than evidence.

I’ve offered my help freely — reviewing charge letters, pointing out USPAP and jurisdictional flaws, and showing appraisers how to fight back the right way. And the feedback I’ve received has been humbling. Appraisers are telling me that my input gave them hope, cleared confusion, and in some cases helped them take decisive steps that made the difference in their cases.

To those who have contacted me: thank you. Your trust means a lot, and your stories confirm that this fight matters. Together, we are building a foundation that will protect appraisers across the country.

Where Do We Go From Here?

The future of our industry depends on a few critical steps:

Accountability: Agencies must be held to the laws and rules that govern them. Jurisdictional overreach can’t become the norm.

Transparency: Appraisers deserve access to evidence, FOIA records, and clear investigative timelines — not endless stonewalling.

Community Support: No appraiser should ever feel they are fighting a government agency alone. We need more networks of support, education, and shared resources.

Reform: Programs built on political optics rather than real data have harmed both appraisers and homeowners. That must be exposed and reformed.

My Commitment

For those who don’t know me, I’ve been a Certified Residential Appraiser for over 25 years, working as a panel appraiser for many banks and lenders across Southern California and the nation. I never asked to be put in this position, but I’ve now been under federal investigation for nearly four years — an ordeal that has taught me exactly how agencies bend rules, conceal evidence, and pressure appraisers.

Instead of breaking me, it has given me the knowledge and drive to help others. The word is spreading that I am here to help, and I’m committed to continuing this work. My goal is to build something lasting — a defense system for appraisers — so that no one else has to face what so many of us already have.

We’re making a difference. And the more we share, support, and stand up, the stronger our profession will be.

Call to Action

If you are an appraiser facing bias allegations, HUD inquiries, or state board pressure — reach out. You don’t have to go through this alone. I’ve already helped colleagues navigate more than a few dozen cases, and I will continue to offer my support, free of charge.

Together, we can protect our licenses, our livelihoods, and the future of the appraisal industry.

Reach me at: Kenneth Mullinix- email to: kjmull@aol.com

https://www.theblaze.com/columns/opinion/did-rent-go-up-blame-ai-price-fixing

Curious… AI driven avm algorithms push valuations higher, for rent and sales pricing.

Can you guess what happens next?

Damned if you do, damned if you don’t

Idiots.

See, right there, a lawyer, and officer of the court knew damn well this was not a case yet still brought the suite. No consequences, for an obvious abuse of power. Life goes on as though nothing happened. But let one disgruntled person make an unsupported accusations of racism and all hell breaks loose. The world is screwed up and out of control my friends

(b) Requiring an appraiser to indemnify the appraisal management company against liability, damages, losses, or claims other than those arising out of the services performed by the appraiser, including performance or nonperformance of the appraiser’s duties and obligations, whether as a result of negligence or willful misconduct;

Yet, despite this being a continual widespread practice for seven years since this was enacted, not a single action has ever been taken against an amc or their controlling appraisers. Restriction of trade continues.
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More to your point why appraisers are quitting and not training replacements in CO;

https://rmaa.org/limitations-of-actions-against-appraisers-bill-approved-by-the-senate/
https://leg.colorado.gov/bills/sb25-035
Under current law, the statute of limitations to bring certain claims against a real estate appraiser does not start until the party filing the claim has discovered, or should have discovered, an alleged defect in the appraisal. The act requires a claimant to bring an action against a real estate appraiser (appraiser) within 5 years after the date the appraisal report is completed and transmitted to a client. The 5-year limitation does not apply to an action against an appraiser for a defective appraisal report or service if the action is brought by: / A consumer who is an original party to a residential mortgage loan or residential real estate transaction; or / A mortgage originator who must repurchase a loan. /
The 5-year limitation also does not apply to an action for fraud, for misrepresentation, or for a discriminatory housing practice brought against an appraiser.

That means liability for life, but only for mortgage lending appraisers or appraisers accused of ‘bias’.
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Then we also have this; A recurrent four hour valuation bias class every other cycle, until an appraiser dies or retires. Like other factors in appraisal, the education to maintain an appraisers license has become Kafkaesque, a punishment in to itself.
https://rmaa.org/appraisal-licensee-advisory-valuation-bias/
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Now with the new forms demanding appraisers abandon traditional trustworthy process. The systematic dismantling of the GSE related appraisal industry is nearly complete. The gse’s and FHFA could not be happier.

Please also read this post, if you have a moment. Sums everything up quite nicely.
Related / https://www.reddit.com/r/appraisal/comments/1npwrny/comment/ng560k3/
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Don’t miss this speech; Javier Milei from Argentina, UN General Debate 79th session. Speaking of bureaucratic mismanagement… Americans used to talk this way. Listen to the end. (AI dubbed for english translation so it’s not exactly perfect but close.)

I’m genuinely disgusted by how disgracefully she was treated. Charged while hospitalized, denied a delay, and left to defend herself in absentia? That’s not due process, that’s a demolition job.

She was an accomplished appraiser long before this circus. Her writing was sharp, her insights generous, and her expertise undeniable. She contributed to this profession with clarity and conviction, only to be steamrolled by rhetoric that’s allergic to facts.

We talk about protecting the integrity of the profession. Maybe we should start by not torching the people who actually upheld it.

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

With a county population of 3.4 million and only 6 true appraiser trainees you would think the powers that be would act to protect the publics trust. Considering we have been determined to be the problem, they keep adding gas to destroy us faster.

Seek the truth.