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.

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
________________________________________

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
________________________________________

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
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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
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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.
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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.
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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.
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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.
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ATTACHMENT: HUD CHARGE LETTER (Complete Text from HUDDEMAND._000016.pdf)

Note: Redacted personal information for privacy

Subject: Notice of Violation of the Fair Housing Act – Appraisal Discrimination
From: U.S. Department of Housing and Urban Development (HUD)

To: Kenneth Mullinix
Date: [Redacted]
Dear Mr. Mullinix:
This letter serves as formal notification that the U.S. Department of Housing and Urban Development (HUD) has determined there is reasonable cause to believe you engaged in unlawful housing practices in violation of the Fair Housing Act (42 U.S.C. §§ 3601–3619).

Specifically, our investigation has revealed indicators of racial bias and discrimination in the appraisal of a subject property located in [Redacted]. Our analysis concluded that your appraisal potentially undervalued the property based on race-related factors in violation of 42 U.S.C. § 3604(b).

While the appraisal does not contain overt racial references, your valuation adjustments, neighborhood descriptions, and comparable selections may have contributed to a disparate outcome based on race. As such, your actions may have denied the buyer equal access to housing opportunities.

HUD requests the following:

1. Copies of three additional appraisals you completed between January 1, 2019, and December 31, 2021, in ZIP codes [Redacted], [Redacted], and [Redacted].
2. A written explanation of your methodology for neighborhood selection and adjustments used in the subject report.
3. Disclosure of any communication between you and the lender related to the valuation or the neighborhood demographics.
Please respond within 14 calendar days of receipt of this letter. Failure to comply may result in formal enforcement actions including administrative proceedings or referral to the Department of Justice.

Sincerely,

[Redacted]
Office of Fair Housing and Equal Opportunity
U.S. Department of Housing and Urban Development

Title:

“Cleared but Damaged: What HUD Investigations Are Really Doing to Appraisers—and Why It Matters”
By Kenneth Mullinix, VA-Approved Appraiser

Dear Working RE,

For several years, I have been the subject of a HUD-initiated investigation based on unsubstantiated allegations of racial bias. I was recently informed that the case will likely be closed and I suspect there will be no findings of racism or misconduct on my part (which is correct). You might think that would be the end of the story. But for me—and potentially for many other appraisers nationwide—the damage is far from over.

The purpose of this letter is to raise awareness within our profession about what these secretive investigations may be doing behind the scenes while we’re left in the dark, struggling to explain lost work and damaged reputations.
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❗ The Hidden Consequences of HUD Investigations

Appraisers are routinely required to disclose whether they’re under investigation when applying to appraisal management companies (AMCs), lenders, or government panels. These disclosures are standard—and in many cases, mandatory.

But what happens when the tables are turned?

Does HUD or FHA disclose to appraisers that they’ve been internally flagged? Do they notify lenders, silently causing work to dry up without warning?

The answer appears to be yes—and that is deeply problematic.

________________________________________

📉 A De Facto Blacklist?

Although no statute or public record shows a formal “blacklist” for appraisers under investigation, HUD’s own FHA Single Family Housing Policy Handbook (HUD Handbook 4000.1) gives the agency wide leeway to sideline or restrict appraisers administratively, even before due process is granted.

📘 Relevant Policy Citations:

• Section I.B.2.b.iv(A) – Appraiser Roster Requirements:
“FHA may remove or suspend an appraiser from the Roster at any time for cause…”
• Section I.B.2.b.v(D) – Administrative Removal/Suspension:
“The Department may take administrative action to remove an appraiser… in its discretion, when it determines such action to be in the best interest of HUD.”
These clauses are dangerously broad and lack any requirement for notifying the affected appraiser or giving them a chance to respond before their business is quietly undermined.

________________________________________

⚖️ A One-Way Transparency Street

Appraisers are expected to disclose:
• Whether they are under investigation.
• Whether they are party to litigation.
• Whether they’ve been disciplined or removed from any roster.

Meanwhile, HUD can open an investigation, begin internal flagging, and potentially notify AMCs or lenders—without ever informing the appraiser or giving them an opportunity to challenge the investigation in real-time.

This raises major legal and ethical questions:

• 5th Amendment – Due Process Clause: Can a federal agency take adverse action that directly affects your livelihood without due process?
• Privacy Act of 1974 (5 U.S.C. § 552a): Are federal agencies lawfully disclosing and managing personal information about you without your knowledge?
• FOIA (5 U.S.C. § 552): Can you demand documentation of what HUD has said about you behind closed doors?
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🛑 Cleared, but the Harm Remains

If HUD closes an investigation with “no findings,” that should be a complete vindication. But in reality, the loss of work, reputational harm, and stress during the multi-year process can be devastating, over 800 HUD cases appear to be still open. Worse yet, there is no formal HUD mechanism for restoring your name, notifying AMCs that you’ve been cleared, or compensating for lost time and income.

This creates a chilling effect: appraisers afraid to speak up, fight back, or even ask questions—because a silent administrative flag could ruin their livelihood.

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🛠️ What You Can Do

• File a FOIA request: Ask HUD what records exist about you and whether your name was ever internally flagged or shared with third parties.
• Cite the Handbook: Be familiar with sections I.B.2.b.iv and I.B.2.b.v of HUD Handbook 4000.1 if you’re ever in a position to challenge an action.
• Demand accountability: It’s time our profession had parity in disclosure. If we’re expected to report every detail of our history, federal agencies should do the same when they threaten our future.
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🧑⚖️ Join the Class Action Effort

I am currently in the process of organizing a class action lawsuit against HUD on behalf of appraisers who have suffered similar harm—whether through investigations based on false allegations, reputational damage, or lost income stemming from HUD’s handling of these cases.

If you have been impacted—or believe you may have been flagged, removed, or blacklisted due to a HUD or FHA investigation—I want to hear from you. Write me a short letter about what has happened to you so I can add your name into my files. We all seem to have a similar story.

Please contact me at:
📧 kjmull@aol.com

Let’s protect our profession, stand up for our rights, and hold federal agencies accountable for the harm they’ve caused behind closed doors.

Sincerely,

Kenneth Mullinix
VA Fee Appraiser
Newport Beach, California

I apologize for any confusion caused by the differing figures provided earlier regarding HUD’s handling of racial discrimination complaints against appraisers. Recent information indicates that since 2020, HUD has received over 200 complaints alleging appraisal discrimination. As of May 2024, none of these cases had been resolved, highlighting a significant backlog in addressing such claims. ​

Appraisers Blogs

In contrast, broader statistics on housing discrimination reveal that in Fiscal Year 2022, HUD and its Fair Housing Assistance Program partners received a total of 11,741 Fair Housing Act complaints. Of these, 2,457 were based on race. These figures encompass all types of racial discrimination complaints in housing, not solely those related to appraisals.​

HUD

The discrepancy arises from the distinction between general racial discrimination complaints and those specifically concerning appraisals. While thousands of racial discrimination complaints are filed annually, the subset related to appraisals is smaller, with over 200 cases reported since 2020. The resolution rate for these appraisal-related cases has been notably low, with many remaining unresolved as of mid-2024.​

This situation underscores the challenges HUD faces in addressing appraisal discrimination allegations and highlights the need for more efficient processes to resolve such complaints.​

Kenneth Mullinix

Date: 03/28/2025

By Kenneth Mullinix

As a veteran appraiser with decades of experience, I never imagined being falsely accused of racism. Yet that’s exactly what happened — and I’m not alone. A growing number of appraisers are being investigated, harassed, or publicly smeared without evidence, in violation of their constitutional and civil rights.
If you’re one of them, here’s how to fight back — and why we must.
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1. HUD Must Follow the HUD Handbook — Or Their Case Is Invalid
All HUD investigations related to fair housing complaints must strictly follow the procedures outlined in HUD Handbook 8024.1 Rev-2.

If HUD fails to follow these mandatory steps, their entire investigation can be challenged. Key excerpts include:

• Chapter 2 (Page 2-3, Section 2-5): HUD must establish jurisdiction and verify the validity of a complaint.
• Chapter 3 (Page 3-1, Section 3-2): All complaints must be in writing and signed by the complainant.
• Chapter 3 (Page 3-3, Section 3-4): Respondents (you) must be notified within 10 days of a verified complaint.
• Chapter 5 (Page 5-2, Section 5-3): HUD must verify all evidence and attempt conciliation; they cannot proceed on vague or unsubstantiated allegations.

If even one of these steps is skipped, the case is out of compliance with federal protocol.
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2. You Are Not Required to Respond to Voluntary Letters
Most letters appraisers receive from HUD a letter that clearly states that participation is “voluntary.” This is your legal protection.

You are not required to respond unless the letter is backed by a subpoena or part of a formal legal action. Responding voluntarily can unintentionally harm your case. Instead:

• Request everything in writing
• File a FOIA request for your file
• Consult legal counsel before saying a word
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3. Your Civil Rights Are on the Line

If HUD investigates you improperly, they may be violating your constitutional rights, including:

• 5th Amendment – Protection from self-incrimination
• 1st Amendment – Protection from compelled or censored speech
• 14th Amendment – Due process and equal protection
• 42 U.S.C. § 1983 – Legal remedy for violation of civil rights under color of law
• 42 U.S.C. § 3601–3619 (Fair Housing Act) – Requires proper vetting of housing bias claims

You do not lose these rights simply because you’re an appraiser.
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4. Legal Timelines They Must Follow

According to 24 CFR § 103.400, HUD must:
• Acknowledge complaints within 10 days
• Complete investigations within 100 days
• Issue a final determination promptly after review

If you’ve had a case open for longer than 100 days, especially without updates or a resolution, HUD is already out of compliance — and likely violating their own federal mandate.
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5. Here Are the Numbers — They Don’t Lie
The statistics behind this issue are staggering:
• Over 1,000 racial bias complaints have been filed against appraisers through HUD and the PAVE Task Force since 2021.
• Of those, over 800 cases remain open — with no clear end in sight.
• Fewer than 200 cases have been closed.
• And most notably: only one appraiser, according to FOIA results, has received any settlement or satisfaction through the administrative complaint process.

Let that sink in.

HUD is quick to open cases, slow to close them, and nearly impossible to hold accountable. Meanwhile, appraisers are left in professional limbo — losing work, licenses, and reputation with no due process.
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6. PAVE Program: A Weapon, Not a Solution

The PAVE Task Force was launched in 2021 to reduce racial bias in appraisals. But instead of providing meaningful reform, it became a political machine — encouraging complaints without verification, giving lenders and borrowers leverage, and turning the appraiser into a scapegoat.

No clear guidelines. No training. No protection. No fair resolution. Worse, appraisers are being pressured by AMCs and lenders to change wording in their reports to avoid “code words” — which violates USPAP, undermines valuation independence, and effectively stifles free speech in professional reporting.
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7. We’re Organizing a Class Action Lawsuit

Enough is enough.

I am currently organizing a class action lawsuit against HUD, for violating:
• HUD’s own Handbook 8024.1 Rev-2
• Federal Civil Rights Law (42 USC § 1983)
• Due Process under the U.S. Constitution
• FOIA transparency laws

We currently have over 25 licensed appraisers who have joined the class, and that number continues to grow. Many of these professionals have had cases left open for years, despite being cleared by state boards, VA offices, or other independent agencies. I have a FOIS (Freedom of Information Request) in the work that is in an Expedited Status with a 4 urgency rating which means my request have about the highest urgency that can be filed. So stay tuned for that to be delivered.

We are moving forward. If you’ve been targeted without proof or process, this is your chance to stand up.
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8. What You Can Do Now
📌 Download HUD Handbook 8024.1 Rev-2 and highlight Chapters 2, 3, and 5
📌 Submit a FOIA request for your complaint record
📌 Demand all charges be issued in writing and signed
📌 Do not respond to any letter labeled “Voluntary” unless advised by legal counsel
📌 Join our class action suit or follow its progress
📌 Stay informed through Working RE Magazine and the Appraisal Institute
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This is about more than just one appraiser. This is about our rights, our profession, and our ability to do our jobs without being labeled and smeared without due process.

We’re not going away — and we’re not staying quiet.

Kenneth Mullinix
Veteran Appraiser | Civil Rights Advocate | Class Action Organizer

By Kenneth Mullinix, VA-Approved Appraiser

As a long-time real estate appraiser and VA-approved fee panel member, I’m speaking out on behalf of hundreds of appraisers across the country who have been falsely accused of discrimination, railroaded by federal agencies like HUD, and left defenseless by the very institutions we serve.

This isn’t just my story—this is a national crisis. And now it’s time for action.
The Stats They Don’t Want You to See

Let’s get to the facts—these aren’t rumors. These are real, documented numbers you won’t see in press releases:

HUD Discrimination Complaints:

Since 2020, over 200 complaints have been filed with HUD alleging appraisal discrimination. As of **May 2024, not one single complaint has been resolved on its merits. Not one.
[Source: AppraisersBlogs.com]

Appraiser Targeting Settlements:

In July 2024, The Appraisal Foundation settled with HUD over claims it maintained biased qualification criteria that harmed diversity.

In September 2024, LoanDepot.com reached a major settlement in a landmark appraisal bias case. These settlements send a message—whether you’re guilty or not, the government is coming for you.
[Sources: HousingWire, FairHousingNC]

HUD Fair Housing Data:

In 2023, over 34,150 complaints were filed—a 470% increase in color-based discrimination complaints and 115% rise in race-based claims. This explosion in allegations coincides directly with the federal push to root out so-called bias—regardless of evidence.
[Source: National Fair Housing Alliance]

VA Internal Discrimination Complaints (EEO):

The VA received over 2,200 EEO complaints recently. More than 530 were race-related, including more than 100 involving white individuals—showing this problem cuts both ways.
[Source: EEOC.gov]

The Human Cost: My Story, and Likely Yours

I was personally investigated by HUD under vague and unsupported accusations of racial bias. The toll it took on me professionally and emotionally was enormous. Despite being cleared by the VA, the cloud lingers. The message is clear: you’re guilty until proven innocent—and proving your innocence may never come.

Worse, every appraiser now knows the threat: if your value doesn’t match expectations, the feds might accuse you of racism. This has created an atmosphere of fear and coercion, where neutrality and independence—the foundation of our profession—are being undermined.

The Call to Action: Join the Fight

I am now calling on fellow appraisers who have been:

Investigated by HUD or another agency for racial bias,

Pressured to alter appraised values due to fear of accusation,

Harassed by lenders over use of “trigger words” in reports, or

Personally and professionally damaged by false allegations…

To contact me directly and join efforts to launch a national class-action lawsuit.

We are building a legal team to challenge HUD and affiliated agencies for violating our civil rights, engaging in unlawful coercion, and creating a hostile regulatory environment under the guise of the PAVE Task Force and other DEI-driven mandates.
We Must Act Now

HUD’s refusal to close a single complaint on its merits while simultaneously pressuring appraisers into settlements or reeducation is a violation of due process. The Constitution guarantees fairness, not bureaucratic overreach and public shaming.

If you’re ready to stand up for our profession, for our rights, and for truth—

📧 Contact me: [Insert your preferred contact info or email]

Let’s form a united front and hold HUD and others accountable in court.

Together, we can protect the integrity of real estate appraisal.
Together, we can fight back.

I have a case pending with my state board from a FNMA word police complaint. I think it’s frivolous, but we shall see what my state investigator thinks. For me it has been stressful, time consuming and anytime you have 2 reports under investigation it opens the door for being “over investigated”. I will be following you and sending an email

Date: 03/18/2025

Fellow appraisers,

For the past several years, I have been entangled in a HUD investigation that has exposed serious flaws, misconduct, and a systemic issue that impacts all of us in the appraisal industry. Despite clear exonerating evidence, HUD ignored key documentation, disregarded findings from other agencies, and appears to have kept my case open for reasons unrelated to justice.

This is not just about my case—it’s about a nationwide pattern of abuse that has left countless appraisers fighting for their professional reputations.

Key Issues That Have Been Uncovered

🔹 HUD disregards evidence that clears appraisers—including prior state and federal investigations that found no wrongdoing.
🔹 Cases remain open indefinitely, suggesting that HUD is leveraging these cases to maintain funding streams rather than to seek justice.
🔹 Due process is being violated—many appraisers have never received proper notifications, have been denied access to key evidence, or were never given a fair chance to defend themselves.
🔹 Lack of transparency in investigations—HUD investigators appear to have a predetermined outcome rather than an impartial review of facts.

Why This Matters

🚨 This is a systemic issue, not just an isolated case. If you have faced a similar situation with HUD, your case may have been handled in the same unfair manner.
🚨 The appraisal industry is under attack. HUD’s approach not only defames professionals but threatens the integrity of our entire industry.
🚨 We must take action now. The time to expose this corruption and demand reform is here.

What Can You Do?

✅ If you have been investigated by HUD under the PAVE initiative or any similar program, contact me.
✅ If HUD ignored exonerating evidence in your case, your case may be part of a larger class action lawsuit.
✅ If you are part of an appraisal institution or professional organization, now is the time to step up and get involved. Spread the Word?

Class Action Lawsuit – Join the Fight

I am working to bring together appraisers nationwide who have experienced HUD’s unfair investigations. If you or someone you know has been impacted, reach out to me immediately.

This isn’t just about one case—it’s about protecting all of us from false accusations, systemic corruption, and government overreach.

📢 If you believe in defending your profession, share this post with other appraisers, appraisal organizations, and industry leaders. The more voices that come forward, the stronger our case becomes.

💡 We are stronger together. Let’s fight back! Reach me Ken Mullinix at: kjmull@aol.com with your story.

AMC’s have been working to be Appraiser MC’s, not Appraisal MC’s. Dudd-Fwank gave them the oppotrunity to own us as Chattel… and they will not be satisfied until they replace us with staff and keep pocketing $Billions as the public still thinks they are paying for an “Appraisal”.

‘The local real estate agents must be picking up the slack for appraisers as pdc’s’.

Well, yes. Appraisal management companies exploited the residential appraisal industry by redirecting a substantial portion of appraisers workload to non appraiser laborers, or automated substituting for in house fulfillment instead. Amc’s grew weary of licensing restrictions, so they sidestepped those instead.

Why are these companies even called appraisal management companies, when their primary purpose and end result of business growth appears to be replacing appraisers entirely, avoiding all previous effective regulatory oversight? ‘Appraisal management’ is only a fraction of their work load. Amc’s are effectively unregulated branches of lenders for most practical purposes.

All the top tier high volume amc appraisers do is receive orders, have everyone else do all the work, then sign and get paid. The entire process is on auto pen. The prerequisite to being a successful high volume amc appraiser is to be complicit in consumer billing fraud and look the other way. ‘Appraisal modernization!’

Hi Bill

When I started appraising before licensing in 1986, i have no data other than at the time, I knew I was at the right place and time because there was a shortage of licensed appraisers. In 1990 there were 1,850 appraisers in San Diego. I quickly looked at La Jolla for stats. There are only 10 Active Certified Appraisers in all of La Jolla and only 3 AG Certified Appraisers there. I would have my software key word search to have your name come up as an expert La Jolla or any other under served location right now.. Even if you just went to attorney and legal services, your email and phone contact information for the non lender Boomer Estate Work there.

Wow. There is a boat load of Equity in La Jolla and when rates drop or not, there is still a lot of properties in need of a Certified Appraiser NOW and not a Property Data Collector to due the complexity of high end properties. Non Lender, Estate Work. The local real estate agents must be picking up the slack for appraisers as PDC’S.

Check this out Flash!

Within a blog here almost two years ago to the day, I noted the following.

https://appraisersblogs.com/opportunity-2-work-4-free-is-not-a-plan

Bill Johnson
February 23, 2023 at 8:44 pm
In CA alone there are 9,178 active licensees ( https://brea.ca.gov/html/bureaustats.html ). I used to keep track on a quarterly bases (not any more) but for several years CA was losing an appraiser a day. Of note, and again I used to keep track (used to be 900) but there are currently 799 active appraisers in San Diego County, 470 in Riverside County, 1,114 in Orange County, and 1,703 in Los Angeles County. All counties are within 2 hours of each other, and per above there are 4,086 competing appraisers. For comparison, the entire state of Idaho is believed to have less than 700 appraisers.
Seek the truth.

Nearly exactly two years later the numbers are as follows.

Doing an “Active” appraiser search the following is true.
San Diego County currently has 650 active appraiser or some 149 fewer.
Riverside County currently has 400 active appraiser or some 70 fewer.
Orange County currently has 969 active appraiser or some 145 fewer.
Los Angles County currently has 1,461 active appraiser or some 242 fewer.

Considering my county of San Diego has experienced 20.3% inflation over just the past 6 years (MOST OF ANY CITY IN THE NATION), and lenders want to pay set national appraisal rates, its no surprise the number of appraisers in my practicing county has declined by nearly 20% in just two years.

https://fox5sandiego.com/news/local-news/san-diego-has-highest-cost-of-living-increase-among-major-us-cities-since-2019-study/#:~:text=Based%20on%20those%20results%2C%20the,amount%20has%20increased%20to%20%24104%2C654.

Seek the truth.

If 50 per month are leaving or falling by the wayside in California, say in 12 months time it easy to predict a loss of 600 appraisers per year due to the low amount of work and never ending office costs. My office nut is $10k per year for license, software, data, e/o, etc ,etc, etc. I plan to keep my license and see what happens until late 2026 and then evaluate the business going forward.

As a broker with over 30 years in the business, my educational continuing education is capped off now, but appraisers with over 30 years in the business are required to just keep taking an infinite number of continuing education courses that never ends.

The phones are getting busier now and I am still turning down low paying broadcasted assignments everyday or so. The business is picking up slowly now in my area. 99% of my work is still Non Lender since there is no shortage of Estate Work from the Boomer Generation now. Good Luck out there my friends and Stay Classy.

Imagine being falsely accused of racism, pressured to change your professional opinion under government scrutiny, and then left to bear the financial and legal consequences—all because of a politically driven housing initiative. This is the grim reality for appraisers across the country under HUD’s overreach, and it’s a crisis that extends far beyond individual livelihoods.

As a real estate appraiser with decades of experience, I never imagined that doing my job accurately and ethically would put me in the crosshairs of a federal agency bent on forcing a predetermined narrative. Yet, here I am—dragged through an investigation where HUD disregarded evidence, applied entrapment-like tactics, and even charged me with coercion simply after they guided me into it, all because my valuations did not align with their agenda.

HUD’s aggressive enforcement of its PAVE Initiative—a policy designed to root out “bias” in home appraisals—has turned into a thinly veiled campaign of intimidation. Appraisers are being investigated, accused, and coerced into adjusting home values not based on market data, but on fear of government retaliation. This is not just regulatory oversight—this is entrapment.

A System Rigged Against Appraisers

HUD’s tactics have created an un-winnable situation for appraisers. The agency pressures appraisers to inflate home values without supporting data, which goes against every professional and ethical standard in our industry. Yet, if an appraiser refuses and stands by their valuation, they risk being accused of discrimination and subjected to a drawn-out investigation that disregards due process.

Here’s the catch: appraisers are legally liable for their appraisals for five years. If the housing market collapses, if a loan defaults, or if values drop due to artificially inflated assessments, the appraiser alone will take the fall. Not the lenders, not HUD, not the politicians who set this disastrous policy in motion.

This is a lose-lose situation:
• If appraisers inflate values to avoid scrutiny, they violate professional ethics and expose themselves to lawsuits when the market corrects.

• If they refuse, they are investigated, harassed, and potentially lose their livelihood.
At a time when the industry is already suffering from a shortage of qualified appraisers, this heavy-handed approach will drive professionals out of the business and leave homebuyers with even less protection in an unstable market.

The Damage Is Already Done—Buyer Beware

Some may argue that this nightmare will go away if a new administration rolls back the PAVE Initiative. That’s wishful thinking. The damage is already done. The chilling effect on appraisers is permanent, and the market distortion caused by these manipulative investigations cannot be undone overnight.

Appraisers are now second-guessing their valuations, fearful that a single number in their report could be misinterpreted as discriminatory. Banks and lenders, seeing the risk of federal entanglement, are pushing for “safe” values rather than accurate ones. And homeowners—especially those who overpaid due to inflated values—will be the ones left footing the bill when reality catches up.

This is the real danger of HUD’s overreach: a housing market manipulated by fear rather than facts. If home values are dictated by government pressure rather than market conditions, we are marching toward another financial collapse, just like in 2008.

The only difference? This time, the government is the one pulling the strings.

Hold HUD Accountable Before It’s Too Late

HUD must be held accountable for its reckless campaign against appraisers. Congress, industry watchdogs, and legal organizations must investigate how HUD has abused its authority to manipulate the housing market.

The American public deserves a fair and transparent real estate system—not one built on fear, political agendas, and manufactured accusations. If appraisers can no longer provide unbiased valuations without risking their careers, then who will protect home buyers from another housing bubble?

Buyer beware. The system is rigged, and if we don’t act now, the next housing crash will be one of Washington’s making. Contact me with your story via email: kjmull@aol.com. I am starting a “Class Action” lawsuit against HUD and the PAVE Initiative in order to demand restitution for the Appraisal Industry.

A storm is brewing in the real estate appraisal industry, and it is about to break wide open. A Freedom of Information Act (FOIA) report, set to be released soon to me, is expected to reveal incriminating evidence against the Department of Housing and Urban Development (HUD) and its handling of racial discrimination investigations into appraisers. This revelation could blow the lid off a massive scheme that has been weaponized against the appraisal industry for years.

The evidence points to a deliberate pattern of misconduct in which HUD investigators systematically left racial discrimination cases open for extended periods, not to serve justice, but to keep the grant money flowing and HUD’s bureaucracy funded under the now-defunct PAVE initiative. Instead of fairly investigating claims, HUD allegedly manipulated investigations and ignored exonerating evidence to falsely implicate appraisers, tarnishing their reputations and careers while ensuring a steady stream of federal dollars.

The Breaking Point: How HUD Kept Cases Open to Pad Their Coffers

The FOIA report is expected to uncover the extent to which HUD engaged in these practices, providing damning proof that cases against appraisers were kept open without merit simply to justify the continued receipt of federal funding. Appraisers who had already been cleared by other government agencies, including the VA, were still pursued by HUD with no new evidence, violating HUD’S own due process and federal laws.

For years, HUD has targeted appraisers, falsely accusing them of racial bias in valuations, ignoring crucial evidence in their favor, and applying heavy-handed investigative tactics with no legal basis thus breaking their own handbook guidelines which govern these cases.

The HUD handbook that directs investigations into fair housing complaints and discrimination cases is the:
HUD Title VI, Fair Housing, and Equal Opportunity (FHEO) Investigations Handbook

• Title: Fair Housing Complaint Processing Handbook (HUD Handbook 8024.1)

• Governing Office: Office of Fair Housing and Equal Opportunity (FHEO)

Additionally, HUD Handbook 4000.1 (Single Family Housing Policy Handbook) is often referenced in cases related to appraisal review and compliance, but it does not directly govern investigations into discrimination allegations.

For administrative enforcement and investigative procedures, the following may also be relevant:

• HUD Title VI Compliance Manual (for civil rights and discrimination cases)

• HUD’s Fair Housing Act Guidelines (governs complaints and resolutions)

• HUD Handbook 2225.6 (Audit Guide for Fair Housing Compliance)

Sspecific HUD investigation, such as one related to the PAVE initiative or allegations against appraisers, you’ll want to cite HUD Handbook 8024.1, as well as any relevant sections of HUD’s regulations under 24 CFR Part 103 (which details complaint procedures).

Investigators refused to vet my complainants, failed to record interviews, altered official documents, and even misrepresented the existence of charges in official correspondence.

The latest evidence suggests that HUD has engaged in a concerted effort to cover up its fraudulent activities, including misleading statements from HUD officials denying the existence of second charges (Coercion) when internal documents suggest otherwise.

A Call to Action: The Fight for Industry-Wide Justice

This is bigger than one case—it is about an entire industry under siege. The revelations from this FOIA report could provide the leverage needed to force HUD’s hand into not only settling but also ensuring relief for hundreds of appraisers who have been wrongfully accused under the flawed PAVE program. The implications could reshape the way HUD operates, ensuring that due process and fairness are restored in all future investigations.

I am continuing to recruit appraisers who have been affected by this corrupt system for a potential class action lawsuit. If HUD is found guilty of keeping cases open to siphon grant money, the entire industry has a right to demand restitution and change.

The truth is about to come out, and HUD is out of time. If you are an appraiser who has been targeted by the PAVE initiative, now is the time to take a stand. The FOIA report will soon shed light on just how deep this corruption runs, and we must be prepared to hold those responsible accountable.

Stay Tuned – The FOIA Report Could Change Everything

As soon as the FOIA report is released, I will provide further updates, breaking down the full extent of HUD’s wrongdoing and what it means for appraisers across the country. This fight is far from over—but we are on the brink of a monumental victory against an agency that thought it could act without consequence.

If you are an appraiser who has been affected, reach out. The time for accountability is now.
Contact me at: Kenneth Mullinix at: kjmull@aol.com (law firms are welcome to reach out to me)

WATCH: Top Democrat Attack Dog Maxine Waters Tries to Storm HUD Building to Protest DOGE Cuts – HUD Spox Responds with FIRE

https://www.thegatewaypundit.com/2025/03/watch-top-democrat-attack-dog-maxine-waters-tries/

if we were as corrupt as hud…it would be a life sentence with no chance of parole

https://www.thegatewaypundit.com/2025/03/ric-grenell-destroys-obama-crony-susan-rice-epic/

set up???they have con artists impersonating home owners

The Department of Housing and Urban Development (HUD) is waging an aggressive and flawed campaign against real estate appraisers, with an estimated 1,300 appraisers currently under investigation. While regulatory oversight is necessary, HUD’s investigative process is plagued by procedural violations, lack of transparency, and due process failures that put livelihoods at risk.

HUD’s Failure to Follow Its Own Rules

HUD’s own guidelines, outlined in Handbook 4060.1, Chapter 1, Section 1-4, require formal notification to appraisers under investigation, including specific allegations and supporting evidence. Yet many appraisers, including myself, have been subjected to investigations without receiving the proper written notification via certified mail.

Key Issues with HUD’s Investigations:

1. Lack of Proper Notification – Appraisers are often left in the dark about allegations until it is too late to mount a proper defense.
2. Entrapment Tactics – HUD personnel have instructed appraisers to take actions that later result in charges against them, a clear violation of due process.
3. Suppression of Evidence – Investigators have failed to document key evidence, including recorded phone calls and past appraisal records, violating HUD’s own procedural requirements.
4. Retaliatory and Political Targeting – Many appraisers believe they are being unfairly targeted for political reasons, rather than legitimate concerns about appraisal practices.
My Case: A Textbook Example of Government Overreach
As a HUD-approved appraiser, I was instructed by HUD personnel to contact a homeowner—a directive that later became the basis for a charge of coercion against me. This is a blatant example of entrapment. Additionally, the investigator failed to properly document recorded calls as required by HUD Handbook guidelines, further demonstrating investigative misconduct.

Even more concerning, the Department of Veterans Affairs (VA) conducted an independent review of my appraisal work and found no wrongdoing. Yet HUD ignored this exoneration, proceeding with its case against me in violation of procedural fairness regulations.

Furthermore, my office was broken into, files stolen, and my computer system altered—critical evidence tampered with or destroyed. HUD has refused to acknowledge this breach, despite clear implications for my case.
What Needs to Change?

HUD’s investigative process must be overhauled to ensure fairness, transparency, and adherence to due process. Specifically:

• Mandatory Notification Compliance: HUD must follow its own rules and provide formal written notification to appraisers under investigation.
• Independent Oversight: Investigations should be subject to independent review to prevent abuses of power.
• Full Disclosure of Evidence: Appraisers must be provided with all evidence against them, including recorded communications and past appraisal records.
• Protection Against Retaliation: Appraisers should not face politically motivated investigations or procedural entrapment.

The Bigger Picture: Why This Matters

If HUD is allowed to continue its unchecked investigations, the consequences extend beyond individual appraisers. The integrity of property valuation nationwide is at stake. Homebuyers, lenders, and the entire real estate market rely on fair and impartial appraisals. If government agencies can target professionals without accountability, trust in the system will erode.

Appraisers under investigation must know their rights, demand due process, and hold HUD accountable for its procedural failures. If HUD refuses to follow its own rules, it’s time for Congress and the courts to step in and ensure fairness in regulatory enforcement.
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Kenneth J. Mullinix is a certified real estate appraiser with extensive experience in the industry. He is currently engaged in a legal battle against HUD over procedural violations in its investigative process.

the war was not meant to be won…it is meant to be continuous