Damn Ken
What an Incredibly AWESOME effort!
Well done!
All my respects

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.

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.
________________________________________

📚 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.
________________________________________

📚 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.
________________________________________

📚 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.
________________________________________

📚 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.
________________________________________

📚 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.
________________________________________

📚 ⚖️ 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.
________________________________________

📚 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.
________________________________________

📚 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.
________________________________________

📢 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

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

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.

✍️ By Kenneth J. Mullinix

Retired, Disabled, VA-Cleared Appraiser – Living on Social Security and Medicare
__________________________

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.
________________________

⚖️ 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
_____________________

🗣️ 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.
_____________________

📬 Contact Me or Share Your Story:

Email me at: kjmull@aol.com
📢 Let HUD Know: You’re Watching

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.’

I’ve had success with DOGE Using X.com @HUD_DOGE

I’ll file a request with them too.

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.

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.

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

To Flash, Consider becoming national, lol

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.

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.

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.

Are you getting that work through lawyer solicitation or from a website or other marketing?

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.

New Jeremy Bagott article hit this last Friday. Simply incredible.
____________________________________________________________

‘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…

Unfortunately, it appears there are too many Skippys completing these. After all, look at the less than stellar companies pushing them.