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.
Hello Joseph
I have considered a spot on a local radio show for real estate topics. On the radio and newspapers. I have also heard and read about real estate commentary that attempts to inform the general public about all things in real estate.
Covering 10 counties is a lot of mileage to cover. I have covered up to 5-6 but these days 1-3 county’s is all I need.
I am a real estate broker owner that just works for myself, manage my own rental property and an appraiser. When Covid hit and there were 40 calls a day, my business plan was now nothing but the rush assignment with large fees for 2-3 day turnaround when others had a 3 month wait.
Overall I stay busy with 4-5 reports per month but during Covid I did 15-20 reports a month of rush work only with stats and graphs with minimal ROV requests. A simple plan for the time and it worked. Boomer Estate work is where I have been focusing on for last 5 years.
2026 will be a whole new game with new form reports, but my Boomer Estate work should keep me busy enough.
Flash
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 don’t want to work with the new UAD either – although I haven’t had a chance to view it. It just seems it’s more BS that they want us to put up with. I sincerely wish this would be investigated by DOGE, but they seem to have other things with priority. I did sent a request to DOGE via the government website, and if enough of us also contact them, perhaps they’ll put it on their list.
I’ve had success with DOGE Using X.com @HUD_DOGE
I’ll file a request with them too.
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
Thank you, 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
Much a do about nothing. There will be very little work going forward. Has anyone noticed the bond rates spiking? That goofy old syphilitic who is the POTUS is crashing the markets. Look for mortgage rates to go past 8%.
in 1974 of the Oil Embargo time period the real estate world and markets still survived, An FHA loan to purchase a home at that time was 22.5 % loan for 20 year mtg. I bought my first house in 1974 and made double monthly payments on it and still came out a winner on that investment.
There probably wont be much work nor has there been over the last 18 months. Many sellers have side lined their real estate to sell until markets improve or must sell due to death or taxes.
Since I focus my simple business plan on Estates and Inherited Homes, the mortgages rates, Refinance or Purchase Reports do not matter to me.
My market is Boomers, Legal Work, Non Lending Estate Purpose Reports and I am busy. I started marketing non lender work over 5 years ago. Now when the phone rings and it spam or another Estate Purpose Report request.
Life is good.
Are you getting that work through lawyer solicitation or from a website or other marketing?
Hello Baggins
I have an appraisal website, I write blogs and the majority of the work is private parties needing an Appraisal for Estate Purposes. Court Room Lawyer work can be a combined 100-150 hours of work if required to prep for court trial. I just put it out there .. my credentials, what i can offer on the internet and like magic the phone rings. Lawyers just call me out of the blue, I dont chase them down for work.
To Flash, Consider becoming national, lol
📢 OPEN CALL TO APPRAISERS NATIONWIDE: IS HUD USING ZIP CODE PROFILING TO FABRICATE RACIAL BIAS CASES?
By Kenneth J. Mullinix
Real Estate Appraiser | 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 radicalized 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.
I am filing a scond Freedom of Information Act Request soon and need as many appraiser statements as possible to show the FOIA Division that this is not just happening to me but is a nationwide phenomena. Therefore I can get data on the entire PAVE program with this and other details that are yet to be discovered at the PAVE Initiative.
Kenneth J. Mullinix
Newport Beach, CA
kjmull@aol.com (contact me)
FOIA for PAVE. That will be very interesting to look through. PAVE is now offline via Trump’s merit based modeling which scales down DEI policies. I think NFHA may have had some funds cut as well but I’m not quite sure of that second point.
More people need to understand that the main goal of PAVE and NFHA working with bad actors in HUD has already been achieved. This comes in the form of the ‘AVM final rule’, which has DEI principals baked into the technology. Via the ‘disparate valuation outcomes along racial or ethnic lines’, and associated value alterations the avm systems will then apply.
This goes hand in hand with the expansion of appraisal waivers and compulsory lender participation. Because the only way to apply socialist type equalization systems to American housing was to remove the independent appraiser. Obviously if people in the USA want to re establish merit based systems, independent real estate appraisers need brought back into the picture. Like how things were in the 90’s, basically almost everything mortgage lending related had required the use of an independent appraiser.
https://www.consumerfinance.gov/about-us/newsroom/agencies-issue-final-rule-to-help-ensure-credibility-and-integrity-of-automated-valuation-models/
https://appraisersblogs.com/appraisal-institute-scandal-widespread-fraud-uncovered/#comment-44943
https://appraisersblogs.com/appraisal-institute-scandal-widespread-fraud-uncovered/#comment-44944
https://appraisersblogs.com/the-appraisal-foundation-turns-down-free-grant-money-counting-on-appraisers-2-foot-the-bill/#comment-31045
https://appraisersblogs.com/national-fair-housing-alliance-nfha-funding-dries-up/#comment-44810
https://appraisersblogs.com/national-fair-housing-alliance-nfha-funding-dries-up/#comment-44773
Anyone performing hybrids is an order taker, not an appraiser. Don,’t do them. Don’t be a sap! Some stiff collecting data for my reports? Someone better duck! LOL!
All kidding aside, any licensed or certified appraiser knows this whole hybrid dynamic to be suspect. DO NOT DO THEM!! Call their bluff. Get loud! These are GSEs’ still under conservatorship trying to blackmail you into doing something that you know will result in a misleading appraisal.
Well said!
Unfortunately, it appears there are too many Skippys completing these. After all, look at the less than stellar companies pushing them.
New Jeremy Bagott article hit this last Friday. Simply incredible.
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‘Where to look for more fraud at Fannie Mae’.
VENTURA, Calif. (April 11, 2025) – Fannie Mae reported this week it had fired more than 100 employees for unethical conduct, including facilitation of fraud. Expect more such news as the truth emerges about this organization’s activities over the past half-decade.
At the beginning of the decade, under the protective camouflage of its federal conservatorship and Covid-19, Fannie began eliminating critical checks and balances in a radical experiment with U.S. taxpayers’ money and the U.S. economy. The mortgage giant began scrapping or weakening long-accepted underwriting safeguards like…
This is why I’m so happy that I built up a private appraisal business years ago and have a big stronghold in my Atlanta market. Good SEO, good reviews, good marketing and more. No more dealing with AMCS, lenders, hybrids, etc. doesn’t effect my work period and I’m busy as can be.
2025 has been great. Hell 2024 was one of my best ever. Averaging 20-30 private jobs at my fees and it’s still going strong. Most work is for the consumer and I go a lot of private work for agents as well as estates.
I do feel bad for those that rely on only lender work and are being subjected to all this crap. But at the same time it’s helped me.
Y’all are trying to fight something you can’t win. Something that you won’t change. We tried for many years. You have to make a decision on either to move on or suffer. No one here or anywhere else is going to change things soon. I do applaud the AARC or whatever it’s called for what they are doing as they will make change but it will take time.
Thank you flash, thank you mark. One day if things turn around, I hope to be able to explore those opportunities.
I will personally never be able to reconcile the fact that the vast majority of citizens whom utilize mortgage lending are not receiving equal protection, or equivalently competent and fair service engagements.
The FNMA wholesale lending program is the grand cover. This has thus far redirected and buried scrutiny surrounding fifteen years of unethical amc engagement and aggressive origination activity from investigation discovery and civil and legal claims. Housing which would otherwise have long since been redirected to the open market, sustained countless small businesses, resulted in substantial housing correction, would have solved housing affordability and availability issues in the same note, and prevented untold hardship but rather provided substantial opportunity.
There is far too much self-serving bias with the “major” mortgage players. I think it is fair to say their biases can be proven however if no one in the government ranks is willing to take up the cause these practices will continue. Despite the steps being taken to curb government overreach we, the appraisers on the front line, still see them perpetuate the woke agenda on a daily basis because it suits their cause. Not until this behavior is rooted out and dealt with will meaningful changes take place. From what I’m seeing, Trumps administration order against this type of behavior is being tossed to the side openly defying what is acceptable SOP. I guess it is so engrained it will take a wake-up call from the administration to remind them it’s their way or the highway. They have made a good start by identifying the problems within Fannie and Freddie and taken swift action but much more needs to be done as we head down this road of the mortgage industry failure. The American people are getting shortchanged in the name of profits, and they have no clue what is happening to them. So too are the appraisers who love what they do yet are being demeaned and sent to the poor house defending themselves and possibly worse, incarceration. Ridiculous. I agree whole heartedly that removing oneself from the mortgage industry is perhaps the best appraiser option short of retirement but how much private work is there to support an entire industry? But this should not be a move of necessity and desperation for any appraiser. It should be a personal decision based on choice. It has become an “us and them” industry and that is just plain wrong. However, it does fit their plan to eliminate one more stumbling block to free-fall mortgage lending.
Blog Update: Second FOIA Filing with the VA – Closing in on the Truth
As part of my ongoing effort to expose misconduct and protect the rights of independent appraisers, I’ve just submitted a second Freedom of Information Act (FOIA) request, this time directed to the U.S. Department of Veterans Affairs (VA). This follows an earlier request tied to the larger picture of how federal agencies are handling appraisal-related investigations.
To be clear, the VA acted professionally and cooperatively in my case, ultimately clearing me of any wrongdoing. They continue to assign me work, and I respect how they approached the matter. This FOIA filing is not a challenge to them—it’s a strategic move to collect data on the totality of cases across the country and identify any patterns or discrepancies in investigatory practices.
The real target of this investigation is HUD—specifically, how the agency has used ZIP code profiling, prolonged investigations, and questionable methods to accuse appraisers of bias without substantial evidence. With this new FOIA request, along with others already filed, I am collecting the undeniable evidence needed to reveal what many of us already suspect: a systemic abuse of power hiding behind the PAVE initiative and DEI rhetoric.
Importantly, this FOIA request has been granted expedited processing—a major win that suggests someone inside the system sees what we all know is happening. It confirms that our concerns are real and worthy of immediate attention.
I am also continuing to build a possible class action lawsuit against HUD. If you are an appraiser who has been investigated, charged, or unfairly targeted, I want to hear from you. Your experience may help expose the full scope of this issue. Please reach out and share your story—you are not alone.
Together, we’re building a record that can no longer be ignored.
More updates to follow.
— Kenneth J. Mullinix
Oh my goodness! Another Woe is me article. The #1problem Appraisers have is they have allowed a PROFESSION to become a SERVICE. You don’t want to do hybrids? Don’t do hybrids. If you want to do hybrids, chage YOUR PRICE. If you want to drive by to look at the hybrid, DRIVE BY. I’m swamped in all types of valuations. I charge MY PRICE. I miss those who don’t value my service and I’m okay with that.
And the whole hybrids are wrong, aren’t USPAP compliant…all those arguments went out the window during COVID. This is exactly what those 1004 exteriors were. Different name; same work.
The issue is more complicated than a personal take. These companies are forming and imposing tools and programs which entice unethical and arguably incompetent practice. A national model where somewhere in the mix, there are appraisers whom will claim multi state licenses and use property data collectors, outsource the report writing, and put their program and service on autopilot. Amc’s are chalked full of these guys, many sit in management positions.
This is very harmful to consumers as they get a tenth of the attention and insufficient professional service. For appraisers whom coincidentally become wedged out by other appraisers providing this type of service in their area, the work dries up and they don’t get to just demand their price as you say.
If there was a rogue dentist doctor plumber or other person in your area swindling people left and right, would you still be so cavalier as to say you should have called the other guy, to all the people harmed by the practice? When the city embezzles money from citizens due to fraudulent billing practices, would you give them a free pass as well?
An important consideration is this activity is rampant in mortgage lending, because consumers are powerless to select who their appraiser is, and subsequently do not bother putting in research to promote quality valuation servicers. So instead we get a substantial portion of the appraisal industry, the side which focuses on mortgage lending, having serious deficiencies, and everyone whom wants or needs a mortgage loan ends up dealing with this in one form or another.
The practice of rubber stamping everything also pollutes the data well and causes systemic over valuation and other harms. You’re not actually doing appraisals with truthful free market data anymore, you just think you are because you’re looking the other way on these vital and concerning issues. We’re not woe is me hand wringing as you so cavalierly claim. Go get your big fees. Look the other way when you, your family, your neighbors, and other people near and dear to you in your community need to access mortgage lending in the future. Appraisers whom do not play along will not be selected for their valuation service needs in the future. ‘Appraisal modernization.’
Spot on Baggins. This is not about the money yet there are those that live in a vacuum or worse, have an agenda and spew their rhetoric. You are much more diplomatic than me and I call it like I see it as offending as that may be. This is about unwarranted persecution against individuals,, demonized by a minority of hateful, despicable individuals who find some bazarre satisfaction in terrorizing Americans simply because they can abuse their position. I pray these messengers of hate are rooted out and pay a price for their unwarranted persecution. The nay sayers such as this don’t see the big picture and never will. That, or they ARE the ones with the agenda. They are part of the problem and not the solution.
HUD Is Targeting a Disabled Senior Citizen to Protect Its Political Agenda – I Am That Appraiser
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✍️ By Kenneth J. Mullinix
Retired, Disabled, VA-Cleared Appraiser – Living on Social Security and Medicare
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I never thought I’d be here—writing a blog post just to defend myself from a federal agency.
I’m a 67-year-old, disabled senior, retired, living mostly on Social Security and Medicare. I’ve worked for decades as a certified real estate appraiser, a general contractor, and a law-abiding professional. I served the public. I followed the rules. I passed every class to keep my appraisal license in good standing, completed thousands of appraisals, and received full clearance from the Department of Veterans Affairs after a wrongful racist complaint was filed against me in 2022.
But HUD didn’t care that I had been cleared. They didn’t care that I’m disabled. They didn’t care that I live in a mobile home park or that I survived a stroke, a heart attack and have PTSD. Instead, they chose to keep coming after me.
Why?
Because I challenged them. Because I asked questions about the PAVE Task Force and whether it was being misused. Because I pushed back on being coerced to do appraisals in “ZIP codes” that aligned with a racial narrative. Because I refused to lie.
And now, I believe HUD is using my case as a tool to prop up their political agenda—to show action, pad their metrics, and justify their budget… at my expense.
This is not just an attack on me—this is a broader pattern of what happens when federal power is abused. When “diversity” becomes a weapon. When “equity” becomes code for coercion. When a government agency picks on the most vulnerable person it can find: a disabled senior citizen making about $15,000 a year from their appraisal business.
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⚖️ Calling All Appraisers: The Class Action Is Forming
I’ve spoken to more than a dozen other appraisers who have experienced something similar—un-vetted complaints, double jeopardy investigations, PAVE-related pressure, or racial profiling based on ZIP codes. Some were cleared by the VA or other agencies and still pursued by HUD.
Enough is enough.
We’re exploring a class action lawsuit against HUD for:
• Civil rights violations
• Retaliation
• Due process violations
• Abuse of the PAVE program
• Violations of the HUD Handbook
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🗣️ What I Want You to Know
• I am not ashamed.
• I am not giving up.
• I want people to see this for what it is: a modern-day government witch hunt against hardworking, honest appraisers/Americans.
If you’re reading this and you’re:
• A journalist
• A whistleblower advocate
• A civil rights attorney
• Or another appraiser who’s been targeted
Reach out to me. You’re not alone. And neither am I.
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📬 Contact Me or Share Your Story:
Email me at: kjmull@aol.com
📢 Let HUD Know: You’re Watching
🚨 HUD Had No Legal Authority to Investigate Most Appraisers — and They Knew It!
By: Kenneth Mullinix (Appraiser/ Advocate/ Activist)
From the very beginning, HUD’s bias investigations under the PAVE Task Force were illegal for one simple reason:
“HUD only has legal jurisdiction to start racial bias/discrimination-motivated investigations over FHA-insured loans”!!
🔹 They have no authority over VA loans.
🔹 They have no authority over conventional loans.
🔹 They have no authority over private transactions.
Yet HUD opened hundreds — possibly nearly 900–1,200 or more — investigations anyway.
Yet statistics show that an estimated only 12% or less of these cases involved FHA-backed loans.
Additionally, it appears that HUD deliberately kept many of these investigations open rather than referring them to an Administrative Law Judge (ALJ) for formal review or closure. The likely reason: HUD lacked legal standing to prosecute these cases. Had any of these investigations been forwarded to an ALJ, the first question asked would have been whether HUD had proper jurisdiction over the transaction. Because most involved non-FHA loans — VA, conventional, or private — the ALJ would have immediately recognized the jurisdictional defect and thrown the cases out. Rather than expose their unlawful overreach to judicial scrutiny, HUD chose to leave cases open indefinitely. In doing so, they artificially padded the number of “active investigations” to justify continued funding, political talking points, and media narratives — even though many of these cases were legally invalid from the start. This left hundreds of appraisers trapped for years in a system that knowingly denied them due process and weaponized investigations as a political tool rather than a lawful enforcement action.
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📚 Exact Laws and Handbook Sections HUD Violated:
• Fair Housing Act (42 U.S.C. § 3608): HUD must only enforce fair housing in programs it administers — primarily FHA loans.
• HUD Handbook 8024.1 REV-2, Page 1-5, Section 1-9 (“Jurisdictional Requirements”): HUD must verify jurisdiction BEFORE opening an investigation. Complaints involving VA or conventional loans are typically outside HUD’s authority.
• HUD Regulation 24 CFR § 103.25: Complaints outside HUD’s jurisdiction must be referred or closed immediately — not investigated.
✅ This means every non-FHA loan investigation HUD opened was illegal from the start.
✅ It means every appraiser dragged through years of baseless investigations was denied due process and had their civil rights violated.
✅ It means HUD weaponized government power without legal authority — and appraisers across America paid the price.
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📚 Civil Rights Violations by HUD’s PAVE Task Force
HUD’s illegal overreach is not a technicality — it is a direct violation of civil rights, protected under:
• The Fifth Amendment of the U.S. Constitution (Due Process Clause)
• The Fair Housing Act (requires jurisdiction and fair process)
• The Americans with Disabilities Act (ADA) (for disabled appraisers, including myself, targeted without accommodations)
But the violations didn’t stop there.
HUD conducted biased fishing expeditions, including:
• ZIP code fishing — asking for appraisals by neighborhood or city without a specific discriminatory allegation.
HUD Handbook 8024.1 REV-2, Chapter 2, Page 2-2 (“Investigation Planning and Scope”):
“Investigations must be based on specific, articulated allegations.
Investigations must not be used for broad inquiries or searches without a specific factual basis.”
And under:
24 CFR § 103.400:
“Investigations must develop specific facts relevant to the particular allegations of discrimination.
Investigations shall not be general searches without factual foundations.”
✅ ZIP code fishing was illegal under HUD’s own handbook and federal law.
HUD pressured appraisers for settlements before real investigations,
ignored disability protections, and buried jurisdictional failures —all to create a political narrative.
This wasn’t enforcement. It was government abuse — funded by taxpayer dollars — and now exposed.
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📚 The Bigger Picture: How PAVE Was Built on a Lie
In 2021, under an Executive Order by President Biden, the Property Appraisal and Valuation Equity (PAVE) Task Force was created.
It was marketed as a civil rights initiative — but from the start:
• Investigations were rushed.
• Jurisdictional checks were skipped.
• Political headlines were prioritized over legal compliance.
• Appraisers were sacrificed to produce “bias findings” without evidence.
By Fall 2021, HUD had committed millions to expanding PAVE —many investigations involving VA, conventional, or private loans HUD had no legal right to touch.
In March 2022, HUD celebrated supposed “findings” of bias —while hundreds of appraisers were being illegally targeted. Today, while PAVE has effectively collapsed, the civil rights violations it unleashed are still fresh — and accountability is coming.
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📚 Documented Violations of Law and Handbook HUD’s misconduct violated:
• HUD Handbook 8024.1 REV-2, Page 1-5 (Jurisdictional Requirements)
• HUD Handbook 8024.1 REV-2, Page 2-2 (No broad fishing expeditions without specific allegations)
• 24 CFR § 103.25 (Must close or refer out-of-jurisdiction complaints)
• 24 CFR § 103.400 (Specific facts required for investigations)
• Fair Housing Act (42 U.S.C. § 3608)
• Americans with Disabilities Act (42 U.S.C. § 12101 et seq.)
• Fifth Amendment Due Process Rights
Every non-FHA case opened was a direct violation of federal law and civil rights.
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📚 My Story: Fighting Back Against an Illegal Investigation
I was targeted under HUD’s illegal PAVE initiative — despite working on VA loans HUD had no right to investigate.
For four years: (1 year after appraisal on 11-0-2021homeowner filed racial case/ 1 year for VA investigation to conclude/ homeowner filed again with HUD now a 27-month long investigation from HUD- still open):
An estimation:
• Wrote and estimated 500-750 pages defending myself.
• Filed multiple FOIA requests to uncover the truth with HUD/ VA.
• Filed a whistleblower complaint with the U.S. Office of Special Counsel.
• Filed a case with the Department of Justice
• Informed the Legal Counsel of HUD about the abuse/case
• Filed a police report- break in of my office
• Contacted numerous media outlets
• Contacted congressmen and other government agencies
• Wrote the Inspector General’s Office at HUD multiple times
• Filed a GAO FraudNet report exposing HUD’s misuse of taxpayer funds.
• Filed an EEOC disability retaliation complaint.
Through it all, I endured:
• Constant emotional stress
• Worsening PTSD
• Insomnia/ sleep disorders
• Shingles outbreaks
• Anxiety/ panic attacks
• Financial damage
• Reputational harm
I am not alone.
Appraisers across the country have been contacting me with similar stories. I have an estimated 20-25 personal stories about HUD investigations so far.
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📚 ⚖️ Building Toward Class Action Status
Because HUD’s illegal actions affected hundreds — possibly thousands — of appraisers,
I am actively preparing for future class action litigation.
✅ If you were investigated by HUD for a VA, conventional, or private loan or were investigated and cleared by your own state agency then investigated a second time by HUD
✅ If you were pressured without evidence, especially to settle early
✅ If you suffered damages or retaliation…
📧 Please contact me at kjmull@aol.com
Include:
• Loan type (VA, conventional, private)
• Dates of HUD contact
• Any settlement pressure
• Description of damages (emotional, professional, financial)
Together, we will make history — and hold HUD accountable.
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📚 FOIA Reports Are Coming: HUD’s Illegal Numbers Will Be Public Soon
Pending FOIA requests will soon reveal:
• How many cases HUD opened, and closed, how long they were open for etc…?
• How many involved FHA loans.
• How many were illegally opened without jurisdiction.
The evidence is coming — and HUD will not be able to spin it away.
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📚 Legal Disclosure
This article constitutes protected whistleblower activity under:
• Whistleblower Protection Act (5 U.S.C. § 2302(b)(8))
• First Amendment of the U.S. Constitution
• Federal Civil Rights Laws
Any retaliation will be immediately reported to federal oversight agencies.
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📢 The Reckoning Has Just Begun
HUD gambled that no one would notice.
That appraisers would stay silent.
That PAVE could hide behind headlines and slogans.
They were wrong.
The era of silence is over.
The era of reckoning has begun.
📧 Contact me: kjmull@aol.com
Ken, this is your best update yet. Great job.
The whole thing was cover to install technical systems, the end result being the ‘avm final rule’, which was approved. Their end goal may not have been embroiling appraisers in lawsuits, but passing that avm rule, expanding waiver programs and loan modification programs, eliminating the appraisal safeguard so that lenders could be in total control, previous and future predatory lending would be more difficult to prove.
So from their perspective; mission accomplished. That’s a likely reason why nobody is following up with anything. They never cared about the complaints. They were rather justifying some of the most disruptive policy and procedure changes to the GSE’s and mortgage lending systems ever before seen.
We’re all harmed to this day, every single day. The waiver programs expanded, the property data collection systems put in place, the work dried up and unless Mr Pulte makes radical changes via his FHFA authority, it’s never coming back, not to anywhere near it’s previous potential for FRT’s.
Damn Ken
What an Incredibly AWESOME effort!
Well done!
All my respects
.