Hybrid Appraisals – Flawed Data or Flawed Agenda?
Brian Zitin’s self-serving interpretation of Reggora’s survey results on hybrid appraisals is a textbook example of twisting flawed data to fit a preconceived flawed narrative. He triumphantly proclaims that 60% of appraisers plan to perform hybrid appraisals, painting it as some groundbreaking shift in the industry. But the reality is far more nuanced and less flattering to his agenda.
The result was a 60/40 split with 60% saying yes they will!
That is quite the controversial result and indicates a lot more education and effort will need to go into the overall hybrid rollout to get broad adoption”
Given the choice, the vast majority of those appraisers would undoubtedly prefer to conduct their own thorough, in-person inspections rather than being chained to a desk, at the mercy of a stranger’s questionable property data collection. However, when faced with the stark choice between scraping by with hybrid work or having no work at all, it’s no surprise that many appraisers reluctantly choose the former as the lesser of two evils. Zitin conveniently glosses over this fact, instead spinning it as enthusiastic adoption of an inherently flawed system.
The truth is, the entire hybrid appraisal model is an inefficient mess, adding unnecessary middlemen, delays, and opportunities for error. Having one person collect property data, relay it to a provider, who then has to turn around and engage a separate appraiser, is stunningly convoluted when you could simply have the appraiser handle the data collection from the start. The only reason this Frankenstein process exists is to cut costs by paying rock-bottom fees to the poor soul stuck doing the property data collection. Any claims of “efficiency” or “innovation” are simply a smokescreen to obscure the real motivation: prioritizing profit maximization over consumer interests, appraisal quality, and appraiser livelihoods. It’s high time we call out this charade for what it is.
By Chief Appraiser, Certified Real Estate Appraiser
Reggora? The same company whom poached hundreds of Mercury clients? Delivering a bait and switch program which enticed appraisers to follow, to be then subjected to unlimited amc bidding spam as clients fell left and right to the amc model? The college room mates whom received tech startup funding to push two day appraisals? Tracking appraisers progress down to the minute like a ‘pizza delivery’? If they actually wanted to drive ‘impactful change’ they’d have put in the effort to attain appraiser licenses themselves instead of following the amc model to exploit American workers. / The hits never stop.
https://web.archive.org/web/20210127020127/https://www.reggora.com/about/
Article link; We put out a poll about Hybrid Appraisals across our appraiser userbase and got thousands of replies back / That’s a misleading statistic. Roughly 90% of all appraisers reject the hybrid concept. Three out of four appraisers refuse to work with amc’s. As these platforms primarily cater to amc’s, most appraisers leave or never sign up in the first place. An inadequate sampling size.
The presentation from the various order relay companies is merely a copy of a copy of Dave Biggers Mercury Network Systems (prior to Corelogic hostile buy out). An adulterated version of software originally developed to assist appraisers in avoiding appraisal management companies, to deal with lenders directly instead, to maintain full fee full service reliable appraisal assignment volume with minimal overhead expense. To save our small businesses from the tsunami of predatory interests on the horizon.
Wayback original Mercury systems page. Somebody should take notes.
https://web.archive.org/web/20081201051916/http://www.mercuryvmp.com/
Mercury Network website has been used by more than 200,000 mortgage professionals to order and manage tens of millions of appraisals, at full fee to the appraiser. And with our new update to Version 3.0, you get all the “double blind” ordering and communications that protect your legal liability, without losing access to your existing appraisers and without alienating them by inserting an appraisal management company in the middle.
Thanks for the walk back in time – web archive is a great resource!
Maybe it’s time for a new Mercury/AppraisalPort-like system for connecting appraisers and lenders directly, bypassing the ripoff AMCs and focusing on empowering appraisers, not trying to replace them like Reggora. Because right now appraisers are getting squeezed at both ends…
We agree 100%. There is NO requirement that lenders must use an AMC. They only do so since it supposed to make their jobs easier. Appraisers REALLY NEED to put a stop to AMC’s.
I was one of those victims between Mercury and Regorra – lost a great client that offered steady work. The article above is spot on – take the work and livelihood from the appraisers, pay next to nothing for a field inspection from someone who does not have an appraisal license (most likely), nor may fully understand what we do or look for at a physical inspection, and then we have to sign the appraisal with potentially faulty information thus jeopardizing our license. Of course, the person doing the signing also has a cut-rate fee because they are not completing the inspection. CoreLogic used to order appraisals years ago – they were one of the lowest paying ones during HVCC years, made their money off our backs, and now have manipulated many of the appraisal platforms used including Mercury, Alamode, and our MLS systems. I have to “work” with them, but do not like this company for the above reasons. I have to accept a few orders from AMCs – only if they will pay my minimum fee, which I rarely get in a bid – because I need to pay the bills. At this time, I’ve still not made enough to pay for my software renewal coming up in a few months. Still praying things will turn around enough to just cover business expenses and living costs – forget vacations, luxuries, etc.
Be thankful you’re not providing mortgage lending appraisals in Colorado. Statutes of limitations will no longer apply. Broad language covering any and all potential civil claims and potentially false complaints of racism based on the ambiguous term; discriminatory housing practice.
https://leg.colorado.gov/bills/sb25-035
https://mailchi.mp/rmaa.org/joann-apostol-appraiser-of-the-year-16576503
Sadly, I am in CO – not that I want to be anymore; only one of the reasons I’m desperately looking for another job. At my age, it seems nearly impossible to find anything decent, and with a partial physical disability (cannot stand or walk too long), being a Walmart greeter is not going to happen. I struggle with lengthy inspections also, but with so few received these days, I can manage. FHA inspections are the most difficult, lol.
Colorado, IMO, has gone to the garbage dump for lack of more terms that would be inappropriate.
Remember “Foster Owsley” ? Speaking if inserting into the process !!!!Truett Neathery is ret
Where are the thousands of responses he claims to have received.
You can’t get 2 thousand appraisers to respond to free money
Anyone who believes hybrids are a smart idea, really needs to do some serious research-and if you continue to believe, turn your license or cert in. I personally heard (with my own ears), and have read from numerous agents that they might not be forthcoming with accurate info if they completed the observations as it could impact their future work. That right there is enough to say NO to these. Not to mention, we all should be instructing agents/brokers and the public that allowing property access to unlicensed, insufficiently trained, unregulated and uninsured people is dangerous to consumers, property occupants, the property itself, agents and the economy.
THIS: “Not to mention, we all should be instructing agents/brokers and the public that allowing property access to unlicensed, insufficiently trained, unregulated and uninsured people is dangerous to consumers, property occupants, the property itself, agents and the economy.”
I will not be participating in Hybrid Reports. I don’t need an Uber, Lyft or a Door Dash driver’s opinion with an I phone to make an inspection of a residential property.
I only do full inspections by myself. 99% of my work is Estate Work so I don’t need to accept Hybrid Report requests.If the new 3.6 URAR requires appraisers or property data collectors to count the total number of windows in the report to assist climate change science studies, then it is a no for me on the new 26 page URAR. Non lending work only.
By Jan 2026, I will probably be at 100 % non lender work estate work.
It’s great Flash that you have transitioned to non lender work, but I am not that fortunate yet; I am trying to educate all the realtors in my market about the data collectors who are not licensed in any capacity and many times pass themselves off as the appraiser…I am also trying to go on a local well known radio morning show explaining what is happening to the appraisal process to let the general public realize that they may be letting in some jamoke from God knows where to measure and photograph the inside of their home…talkl about privacy issues…I cover 10 counties and pick & choose my assignments so I keep busy specializing in very rural and oddball properties, I let other appraiser “race to the bottom” for the ridiculous fees offered by the blood sucking AMC’s.
Some of those real estate agents and brokers are the ones doing those hybrid inspections.
It does seem the new UAD is to facilitate “Skippy” doing the inspections. I will not complete assignments with the new UAD andI will not participate in any hybrid work. I have mostly done lender work so I’ll retire and not renew my a la mode software. I was hoping with the DOGE initiative, the new UAD will be cancelled. We’ll see what happens. Happy to be almost out of this business! Business is a stretch for appraisal work; It has never been a business, only a nightmare occupation.
I do have a question about E&O insurance providers but first, I don’t believe for one minute the appraiser numbers in favor of hybrids. The concept itself goes against the whole premise of why this whole profession exists. That said, are they going to cover an appraiser who stupidly signs on to this nonsense in the event the “Uber” driver, between pick-ups, makes a “quick” stop to gather data and screws up royally, provides that faulty $50 (if that) data to the unsuspecting appraiser who then proceeds to produce a misleading report? This whole idea will, in all probability, go down in history as one of the most stupid scams of all time perpetuated on the American taxpayer because after all, that is who the buck will stop with when the mortgage industry craps the bed once again. What kind of insurance protections will the appraiser realize when some unlicensed person provides data to a licensed appraiser, and it is a whole load of horse sh!t? To survive, I’m guessing the E&O insurance companies will have a whole lot of “if this happens, you are not covered, if that happens you are not covered” disclaimers just to survive. If only this was a perfect world and those naive appraisers who are entertaining doing this work could come to their senses and understand this is not the road, they need to go down for the survival of their profession things might actually improve. Yea, it might hurt a bit, but the long-term rewards will easily outweigh the immediate pain.
EO insurers have consistently failed for many years to create separate umbrella policies and/or additional cost of coverage riders for amc work, hybrid, multi state licensing, volume of work completed, etc. One of the constant conflicts of interests is the same companies whom cover appraisers, also insure amc’s. This is but one of many industry problems which the ASC and TAF groups exist to address and mitigate, and have consistently failed to do so.
Insurers had the ability to press the appraisal industry by charging surcharges, premiums, creating distinctly separate umbrella or even individual policies for amc’s, and also for appraisers whom complete amc work and/or hybrid or pass a certain volume thresh hold. They chose not to. I’ve written letters to some explaining how hybrid appraisers stack exponential risk which is unfair for traditional full service appraisers to share in their group risk. They’re unresponsive to the issue. Appraisers may be sharing the cost burden for amc’s liability as well in some cases.
Meaningful industry reforms should also require absolute separation of amc’s and appraisers insurance, as well as more specifically refined scaling costs based on type of and volume of appraisal services performed or outright need for additional policies to complete volume, amc, or hybrid work. Twenty years. An absolutely perfect claims and complaint free record. Low volume of late. Still paying full rates. A lot of appraisers can relate to that one. Appraisal modernization.
Exactly.
🟥 Open Letter to the Appraisal Industry: Are We Being Used? It’s Time to Fight Back.
04/10/2025
From: A Veteran Appraiser Who’s Had Enough
Fellow Appraisers,
Something very wrong is happening in our industry, and it is time we speak out — together.
Over the past few years, appraisers across the country — myself included — have found ourselves cleared by state boards, cleared by the VA etc., and yet still targeted by HUD under the guise of “appraisal bias.” These cases are being filed based on un-vetted, retaliatory, and often race-based complaints with no proof, no merit, and no due process.
Let me be clear: this is not about defending racism — it’s about exposing a federal system that is “Weaponizing” it to justify money, jobs, and politics.
🚨 Here’s the Pattern We’re Seeing:
• A homeowner doesn’t like the value they receive — especially during a refinance.
• They file a race-based complaint, often after being told by the VA or state board that there was no bias.
• HUD opens a case anyway — often without checking who was even present at the inspection, or whether the complaint is credible.
• The appraiser, often white, is instantly presumed guilty.
• The case drags on for months or years. The appraiser’s name is tainted. And HUD keeps counting cases… for funding, optics, and political pressure.
This all started — and was institutionalized — under the PAVE initiative, but it hasn’t stopped. Even if PAVE is technically over, HUD has learned how to “keep the engine running” without it. That’s what makes this more than a problem — it makes it a national fraud, a civil rights abuse, and a stain on our profession.
________________________________________
🔎 It’s Time to Investigate the Investigators
I’m working on a two-part strategy:
1. A FOIA request targeting the PAVE program: who built it, who ran it, and how it’s still being used post-closure.
2. A second FOIA request targeting HUD’s failure to vet complaints — how they are using unverified racism claims to keep cases open, justify salaries, and inflate civil rights enforcement statistics.
3. I have one Freedom of Information Act already in the process about me case and the broader implications that that case will/should reveal about the real PAVE Initiative and underlying implications of how it really functions.
But I can’t do this alone — and I shouldn’t.
________________________________________
🧾 Call for Testimony: Tell Me Your Story
I’m building a national database of appraisers who have been affected by this system. If you’ve been targeted — or even if you’ve seen it happen — I want to hear from you.
Please copy, fill out, and email the following Intake Form to me at (Ken): kjmull@aol.com ADDRESS]
________________________________________
✍️ Appraiser Testimony Intake Form
Name:
Location (City, State):
Years Appraising:
Were you cleared by VA, State Board, or another agency?
☐ Yes
☐ No
☐ Not investigated
Did HUD open a case anyway?
☐ Yes
☐ No
☐ Not sure
Were you contacted by the homeowner before the complaint was filed?
☐ Yes
☐ No
Was the homeowner present at the appraisal inspection?
☐ Yes
☐ No
☐ Unknown
Do you believe the complaint was retaliatory or based solely on race and dissatisfaction with value?
☐ Yes
☐ No
Do you want your story included anonymously in a public FOIA response, report to Congress, or legal filing?
☐ Yes
☐ No
☐ Contact me first
Brief summary of your case (1–2 paragraphs):
[Paste your story here]
________________________________________
🛡️ Why This Matters
This isn’t just about fairness. It’s about saving the integrity of our profession before HUD rewrites it permanently. Appraisers have become the gear that keeps the grant money flowing, and PAVE showed HUD exactly how to do it — even if the program is gone.
Let’s show them we see what’s going on.
Let’s document it.
Let’s demand accountability — together.
Sincerely,
Kenneth Mullinix
Veteran Appraiser | Advocate for Industry Accountability
Email: kjmull@aol.com
Get on MeWe and Linkedin. Linkedin is leftist, but you can contact many appraisers there. MeWe is just a social website, but is rife with conservatives who are sick of America being pounded by these vermin. Every person who knows what’s going on is another warrior made.
Will I ever do a hybrid appraisal? No. I have something like 1,200 hours in home inspection and property insurance adjusting education. I’ve been earthquake certified, flood certified, wind storm damage certified, roof wind/hail damage certified, structural certified, etc., etc. Even with all of that, I barely trust myself to catch everything so I d****d sure don’t trust anyone else to inspect a house property. I might trust an engineer, but why would an engineer even think about inspecting/measuring a house for a hybrid appraisal?! Give me a break. Best wishes to everyone here.
Title: Appraisers Targeted: The Alarming Rise in Discrimination Allegations and HUD Injustice
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:
o 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.
Absolutely no appraiser I know is doing them. I agree it’s BS, they are probably putting ut out there thinking it would sway us to doing them. Oh sorry still NO
ya I’ll call a hardy ha ha BS on that all week and twice on sundays!
Phil Crawford is soooo right!! This garbage data being collected will infect the whole data base and system!
Greed, plain and simple.
I hope Pulte and Calabria grab the bull by the horns!
CL, try doing review appraisals! Try getting VA approved as a review appraiser for them, they pay great and you can work from home. And you are partial disabled they take that into account and you get hire up on the ladder to get possibly hired. Go to USA Jobs the website and look at government jobs that are remote in the appraisal field. Try that! Ken
Brian Zitin and his Regorra… this guy is the NEW BRIAN COESTER. do you all know that his partners and himself developed this company to get data to serve there behind the scenes company to help investors and their private money lending in New England? They started off as a form filling software only to morph into an AMC in order to gather data and sell it off etc. Y’all think this is just another AMC, when in fact they are using this for their advantage.
Brian zitin knows nothing about appraising. He has no license, and he’s been fooling yall for years. This guy is getting rich off yall and yet you still continue to support this company. It’s clear appraisers NEVER do their homework on who they work for. They just sign up and do as told. Shame.
Do your homework people and stop making other rich of your backs. Regorra is the new coester VMs and you have been warned.
📢 OPEN CALL TO APPRAISERS NATIONWIDE: IS HUD USING ZIP CODE PROFILING TO FABRICATE RACIAL BIAS CASES?
By Kenneth J. Mullinix
Real Estate Appraiser | VA Approved | Civil Rights Advocate
________________________________________
In recent years, we’ve seen a growing number of appraisers facing allegations of racial bias without clear justification — often driven by ambiguous complaints and vague accusations. But now, a troubling investigative pattern is beginning to emerge:
HUD appears to be engaging in ZIP code profiling to manufacture or justify these racial bias cases — even when no credible evidence of discrimination exists.
In my own case, I was cleared by the U.S. Department of Veterans Affairs (VA) after a formal review of an appraisal that had been questioned. Yet despite that clearance, HUD chose to pursue a second investigation. As part of that effort, HUD requested that I submit additional appraisals I had completed in ZIP codes that were predominantly white, including ten from Laguna Beach — while simultaneously requesting appraisals from areas around the subject property in a predominantly minority community.
Why would HUD request appraisals from two different racialized ZIP codes?
What purpose would this serve except to go fishing for evidence that they did not already have?
Why compare appraisals based on the demographics of a neighborhood, instead of the merits of the original complaint?
It appears to be true, then this tactic is deeply concerning — and possibly illegal.
________________________________________
⚖️ Why This Matters
ZIP code profiling is a form of racial proxying — using geographic areas as stand-ins for race. When done by a federal agency in an effort to build or sustain a civil rights charge, it may constitute:
• Investigatory bias (when they are supposedly investigating bias?)
• Retaliation
• Civil rights violations
• Misuse of federal investigative authority
• ADA and due process violations for those of us subjected to emotional and financial harm without cause
________________________________________
📣 Calling on Fellow Appraisers
If you are an appraiser who:
• Has been asked by HUD to submit appraisal reports from ZIP codes that do not relate directly to the subject property
• Was asked for appraisals from predominantly white areas like Laguna Beach (your area or state), Orange County, or affluent ZIPs
• Has emails or letters from HUD making such requests
• Believes HUD used ZIP code-based evidence fishing in your investigation
📬 Please contact me directly and confidentially.
Together, we may be able to demonstrate a systemic investigative pattern that violates agency guidelines and fundamental civil rights protections.
________________________________________
🛡️ Legal Notice
This public statement reflects my personal experience, supported by written communications I have received from HUD, and is protected under the First Amendment, the Whistleblower Protection Act, and applicable federal free speech doctrines. My intention is to bring to light investigatory practices that may impact licensed professionals across the country and to protect the integrity of the real estate appraisal profession.
________________________________________
The clock is ticking.
Kenneth J. Mullinix
Newport Beach, CA
kjmull@aol.com