TEAPOTS Exposed: The PAVE Initiative’s Illusion of Justice
The Biden administration’s PAVE Task Force initiative was never a legally engineered program to uncover racial bias in the appraisal industry. It was, as I have now uncovered, a systemic administrative illusion: a complex, bureaucratic apparatus designed to justify federal grant funding, inflate internal performance metrics, and maintain political optics — not to administer justice.
This wasn’t enforcement. This was theft of government funds dressed in legal theater. Homeowners were deceived. Appraisers were targeted. The law was sidestepped. And no one, until now, has exposed the machinery behind the curtain.
“I Knew Something Was Wrong — Because I’d Already Been Through a Real Investigation”
I went through a formal racist/discrimination investigation with the Department of Veterans Affairs years ago as an appraiser accused of racism by a disgruntled homeowner that did not get a refinance of his home, an appraised value of his home to make the numbers work. It was year-long investigation that was tough, but it followed the law: proper jurisdictional review, an investigative plan, interviews, and a formal closure letter generated.
When HUD began a mirrored investigating of me under the PAVE initiative (Thus Double Jeopardy), I immediately knew something was off. There was no TEAPOTS case number. No Administrative Law Judge (ALJ) referral. No recorded interviews. Just vague emails and a completely fabricated “second charge” — later disavowed. And worst of all, HUD repeatedly denied my requests for procedural transparency. I was being dragged through a fake legal process — and they assumed I wouldn’t notice.
No law firm would take my case. HUD officials refused to explain what was happening. So I did what no appraiser should ever have to do: I investigated them. And what I found is bigger than me — it implicates HUD’s own lawyers, leadership, and potentially members of Congress.
What Is the TEAPOTS System — and Why Does It Matter?
TEAPOTS (Title Eight Automated Paperless Office Tracking System) is HUD’s official case tracking system for fair housing complaints. Every legitimate investigation must be:
- Opened in TEAPOTS
- Assigned a tracking number
- Include an investigative plan (HUD Handbook 8024.1 REV-2)
- Be subject to jurisdictional review under 24 CFR § 103.25
In my case — and potentially hundreds of others — no TEAPOTS entry was ever made. That means:
- No formal cases existed
- No legal processes were triggered
- No oversight bodies could audit it
If it’s not in TEAPOTS, it’s not real — and that’s why HUD’s Office of Inspector General (OIG), FOIA office, and others never responded to my certified letters or emails, my pleas for legal interventions: they had no legal record to examine.
Marcia Fudge’s False Statements to Congress and the Public
Former HUD Secretary Marcia Fudge repeatedly testified under oath and gave public statements suggesting that PAVE was actively investigating hundreds of appraisers for racial bias:
“We are investigating over 800 appraisal bias cases. We are serious about enforcement.” — Secretary Marcia Fudge, House Financial Services Committee, March 2022
“These are real cases with real people. We are holding appraisers accountable.” — Fudge, PAVE Public Briefing, June 2022
“We are seeing patterns of bias, and we’re launching enforcement actions across the country.” — Fudge, White House Equity Roundtable, 2022
But based on my experience, my FOIA records, and internal documentation — these claims were categorically false:
- These were not “cases.” They were intake-only inquiries, never reviewed by attorneys or entered into TEAPOTS.
- No formal charges were filed in the vast majority of claims.
- Homeowners were never notified of any resolution.
- Appraisers were threatened, manipulated, and often left in limbo with no due process.
This is more than misrepresentation. It may constitute a violation of 18 U.S.C. § 1001 — making false statements to Congress.
How PAVE Was Built to Bypass the Law
The legal foundation of PAVE was not built in public. It was likely authored by:
- Attorneys inside HUD’s Office of General Counsel (OGC)
- Coordinated with the DOJ Civil Rights Division
- With political pressure from the White House Domestic Policy Council
- And justified by policy advisors or civil rights think tanks
Instead of creating a lawful civil rights enforcement mechanism, they created a procedural illusion:
- No real case files
- No administrative law judge referrals
- No proper jurisdictional vetting (especially of homeowners)
- No recording of interviews (despite HUD Handbook guidance)
This allowed staff and contractors like Theresa Muley and investigator and Sally Pai her Supervisor (both ex-attorneys) in the San Francisco office of HUD to simulate enforcement without creating accountability.
Legal and Civil Rights Violations Potentially Committed
- Administrative Procedure Act (APA) – 5 U.S.C. § 551–559
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- HUD failed to open a legal case, notify the accused, or offer a right to reply.
- Fifth Amendment – Denial of Due Process
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- I and many appraisers suffered reputational and professional harm without lawful process.
- False Statements Act & Grant Fraud – 18 U.S.C. § 1001; 31 U.S.C. § 3729 (False Claims Act)
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- HUD reported fake case numbers to justify PAVE funding, staff salaries, and contractor billing or get year-end bonuses due to volume of cases open(ed).
- Americans with Disabilities Act (ADA Title I & V)
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- As an ADA-protected contractor, I was denied requested accommodations and retaliated against after disclosure of my stroke and PTSD.
- Fair Housing Act – Misuse of Section 818 (42 U.S.C. § 3617)
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- HUD fabricated a “coercion” (818 handbook charge) charge against me despite instructing me to contact the complainant.
- HUD Handbook 8024.1 REV-2 and 24 CFR § 103
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- No jurisdictional review, investigative plan, Notice of Rights, or formal findings. No TEAPOTS entry.
- Civil Service Reform Act (5 U.S.C. § 2302)
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- HUD staff engaged in retaliation, coercion, and procedural manipulation.
- Title VI of the Civil Rights Act of 1964
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- PAVE’s ZIP code-based targeting may amount to discriminatory enforcement and profiling.
Everyone Was Feeding at the Trough
The PAVE program succeeded — just not at protecting civil rights. It succeeded in:
- Justifying massive HUD and contractor salaries
- Providing political cover to leadership
- Generating favorable headlines
- Avoiding legal liability
No one was held accountable. And no one got justice. Everyone involved benefited — except the homeowner, the appraiser and the general public.
What Happens Now?
I’ve submitted a comprehensive FOIA request demanding the real numbers:
- Total number of PAVE cases opened in TEAPOTS
- Number referred to ALJs
- Number with formal findings
- Jurisdictional breakdown (FHA vs. VA vs. conventional)
If, as I suspect, these numbers come back confirming what I’ve seen — then Marcia Fudge, HUD Legal, and the enforcement teams under PAVE have misled Congress, the industry, and the American people.
The appraisal community deserves better. So do homeowners who were told their complaints mattered. And so does every federal appraiser subjected to fear, silence, and retaliation.
Let this article be the start of the reckoning.
Respectfully submitted,
Kenneth J. Mullinix
Appraiser, Veteran, Whistleblower
Very very interesting. What is the next step? Will someone take up a case now?
if someone was to contact HUD and ask if there was any complaints against you as an appraiser would your name popup as being under investigation ?
Seek the truth!
I also have a “case” pending with my state that was referred by FNMA “word police”. Can we say Class Action boys and girls ?
Marcia Fudge’s false claims about PAVE investigations weren’t just hollow promises; they propped up a shameful scam that enriched connected consultants and minority-owned firms through grants and mandatory “anti-racism” workshops, while leaving honest appraisers in tatters. Countless professionals saw their businesses collapse, reputations destroyed, and lives upended by threats, with some enduring serious health declines under the weight of baseless accusations. Many were pressured into settlements by insurers despite no evidence of wrongdoing, all to sustain this bureaucratic facade. Fudge’s role in this fraud demands she face a courtroom or Congress, if not prison, for betraying appraisers and homeowners alike. Thank you, Ken, for the tireless work you poured into unraveling your own case—your triumph is the foundation we’ll all build upon.
Thanks Desiree. Think it’s safe to place a substantial portion of the blame on the amc industry. The open doors for abuse they’ve created are substantial. Now this Ken Mullinix guy and other appraisers like him, find themselves caught up in the aftermath of the appraisal industries and amc industries long term ineffective and counter productive management strategies, co opted positioning and leadership, beholden to ‘stake holder interests.’ The PAVE task force and all the agencies and organizations that worked with them or parroted their messaging appears to have been a ruse to usher in an appraisal modernization program that puts half the appraisal industry almost completely out of work.
Wrote another lengthy post detailing how the appraisal management companies activities and focus has decimated the integrity and viability of the appraisal industry and all of it’s swiftly diminishing licensees.
https://appraisersblogs.com/bye-bye-amc-a-script-2-sideline-appraisal-middlemen/#comment-45431
Thank you Ken
Let us know if we can assist in anyway
HUD repeatedly denied my requests for procedural transparency. I was being dragged through a fake legal process — and they assumed I wouldn’t notice.
No law firm would take my case. HUD officials refused to explain what was happening. So I did what no appraiser should ever have to do: I investigated them. And what I found is bigger than me — it implicates HUD’s own lawyers, leadership, and potentially members of Congress.
EXACTLY! ITS NOT JUST WITH APPRAISERS. HUD HAS ZERO TRANSPARENCY AND REFUSE TO ACKNOWLEDGE THEIR OWN POLICIES AND PROCEDURES THAT ARE INSULTINGLY PUBLICLY AVAILABLE TO READ. CURRENTLY WAITING ON A FOIA REQUEST TO PROVE THEY CLOSE LOAN REVIEWS AT THE LOWEST SEVERITY LEVEL WITHOUT REQUIRED FIELD REVIEWS TO COVER FOR AND EXCUSE LENDERS FROM FRAUD.
https://appraisersblogs.com/uncovering-flaws-in-fha-appraisal-n-loan-review-process/
What is the new head honcho of HUD doing about this?
“show me the man and I’ll show you the crime”[4]) is a saying that was popularized in the Soviet Union and in Poland in the period of the People’s Republic of Poland, attributed to the Stalinist-era Soviet jurist Andrey Vyshinsky,[2][5]: 200 [6] or the Soviet secret police chief Lavrentiy Beria.[3][4] It refers to the miscarriage of justice in the form of the abuse of power by the jurists, who could find any defendant guilty of “something”, if they so desired.[5][6][7]: 179 [8]: 85 ”
From Wiki
Communists typically destroy the farmers first. “Farmers” meaning actual farmers and those most closely associated with reality. We see, feel, touch and sometimes smell the properties and the markets they’re in. We are the primary reality observers. Much or most of the time, we’re told to not believe our lying senses and to believe the words, thoughts and requirements of “a/the party” off in a cubicle in some other part of the world with a “heat map” and the correct words and thoughts which we are, somehow, supposed to know intuitively. Some of the most recent attacks on appraisers by communists involve the removal of common words or the changing of the meaning of words or the removal of normal procedures or the changing of normal/rational/logical procedures. Regardless of our education, training and experience, which is most of the time much greater than the bureaucrats we serve, we’ve been relegated to the role of “vendor”, which, in and of itself, is a derogatory term. But, what do I know? Read “1984”. You decide. It’s not just us. America is in a chokehold and fighting for its life.
Kick back a victory pdc hybrid request and feel the satisfying burn.
The price of appraisals just went up. That’s why you, our dear citizens will now pay less.
Winston, how many fingers am I holding up now?
Have you ever read about Foucauldian Discourse? When an entity, organization, political body or in this case, regulatory body uses their stature to shift societal trends, language, and basically diminish independent thinking. The UN has pulled it for decades. Marcia Fudge and Co. were trying to pull it off here as well. The influence the ‘respected body or entity’ wields can shift minds and culture to the point where, yes, even the language that is or isn’t acceptable is changed. What they continue to chant becomes ‘common knowledge’ and anyone who challenges such is relegated to being a ‘flat earther’.
One of the more blatant examples I can recall is Galileo, who stood by science and evidence that the Earth wasn’t the center of the solar system, and he was castigated by the Catholic leaders of the day.
“HUD Had No Jurisdiction — And Many PAVE Cases Were Never Legal Investigations”
By Kenneth J. Mullinix
The flood of responses I received after the release of my recent article on the PAVE Task Force initiative has confirmed what many of us already knew: appraisers across the country have been unjustly targeted, pressured, and investigated outside the boundaries of law and jurisdiction.
This is not an isolated error. It’s a systemic breach of federal procedure and appraiser rights. And now, we have enough evidence to push forward.
NO FHA LOAN = NO HUD JURISDICTION
Let’s be crystal clear: If your appraisal was not for an FHA-insured loan, HUD had no legal jurisdiction to investigate you.
“FHA appraiser oversight is limited to properties securing FHA-insured mortgages.”
— HUD Handbook 4000.1, Section I.D.1.b
Under 42 U.S.C. § 3608(e)(5), HUD’s Fair Housing enforcement powers are only triggered when it has statutory or contractual authority, such as in programs it funds, insures, or directly oversees. If your assignment was for a conventional loan, VA loan, or private appraisal, HUD is legally barred from initiating an enforcement investigation.
Appraisers in these cases have every right to refuse to cooperate, decline settlement, and ignore further contact, as no legal jurisdiction exists
NO TEAPOTS CASE NUMBER = NO LEGAL CASE
Here’s another red flag: If your original charge letter from HUD does not include a TEAPOTS case number, then your file was never entered into the official HUD investigative database.
Without a TEAPOTS case ID, your file is most likely classified as:
An intake review, or
A risk assessment evaluation
These are not legal investigations.
They do not trigger due process protections, nor do they legally require your participation or cooperation.
“Only cases officially opened in the Title Eight Automated Paperless Office Tracking System (TEAPOTS) and assigned a Case Number are considered formal HUD investigations.”
— FHEO Investigative Handbook 8024.1 REV-2, Chapter 2-3
If there is no TEAPOTS number:
You are not under formal investigation.
There is no valid cause for conciliation.
You have no obligation to respond, settle, or defend.
HUD is required by its own policies to follow formal procedures. If they skipped those steps, then your file is not a legitimate enforcement action—it’s a fishing expedition. Don’t fall for it.
Class Action Lawsuit: The Next Step
We now have documented cases from appraisers nationwide who were:
Investigated without jurisdiction
Sent charge letters without TEAPOTS case IDs
Locked out of HUD systems or denied due process
Targeted for appraisals on VA, private, or conventional loans
We are preparing the foundation for a national class action lawsuit. This case will challenge HUD’s authority, expose systemic abuse under the PAVE initiative, and seek restitution for careers damaged, rights violated, and procedures ignored.
FOIA Round Two & Evidence Mounting
I am currently awaiting the second FOIA response from HUD, which will further reveal:
Internal risk scoring criteria
Misuse of ZIP code targeting
Improper assignment of investigators
The complete list of TEAPOTS file openings vs. intake reviews
This evidence will support not only legal action but potential Congressional oversight, OIG intervention, and media accountability
Call to Appraisers Nationwide
If you received a charge letter without a TEAPOTS case number,
If your appraisal was not tied to an FHA loan,
If you were never officially assigned a case investigator,
Then:
You are not legally obligated to respond or cooperate with HUD.
You have a strong case for dismissal, restitution, or relief.
You may qualify to join the class action now being assembled.
The time to stay silent is over. The PAVE initiative might have ended, but its damage continues—unless we stop it. Together, we will.
Contact me via email with your story. I am keeping a record of appraisers nationwide that this illegality has effected for a possible future class action suit.
Kenneth J. Mullinix
HUD/VA Whistleblower
VA-Certified Real Estate Appraiser
Advocate for Appraiser Civil Rights
Question; Did those few nationally publicized cases, specifically the ones involving amc’s where the amc and the lender settled out and left the appraiser to represent themselves without assistance from their client, where they by chance FHA appraisals for hud? Or were they fannie freddie bound appraisals?
The harm of these events went well beyond just appraisers whom were investigated. We’re all losing our livelihoods in the gse realm as a result. How many fewer full appraisal orders have come through the pipeline with the fhfa mandates to use appraisers less, the waivers, the hybrids, everything that came from the PAVE task force recommendations on valuation bias? That’s a minimum target re compensation number with a class action, and that’s just for lost wages. Then add distress, reputation harm, punitive damages, etc, etc.
Thanks for your work Ken, I turly hope you are vindicated and your work is recognized.
I kind of thought this might be happening. I sent in multiple FOIA requests for information about the main cases that I knew about. They tried to shake and evade me. They told me I had to get a signed statement from Plaintiff allowing me to have the documents. They even said I needed to know the birth date and nation of origin of the Plaintiffs. That’s not how FOIA works. Needless to say I got nothing.
We’ll call that the FOIA modernization routine. Appraisal modernization. Lending modernization. Now with FOIA. Modernization in this realm appears to be a flimsy excuse to make up new rules and dodge all previously established accountability. Apparently.
The difference with an effort like DOGE to force modernization on antiquated systems is completely different than what appraisers are dealing with. That’s because as a group of independent workers, we’ve all modernized to the best of our ability, for what works and does not erode trust or confidence in the product. Of course some took this too far like those whom use outsourced services, ghost writers, and complete junk appraisals at extra ordinarily faster rates than most other appraisers. But aside from those people, appraisal is constantly sensibly modernized, when the appraisers themselves choose what works and what does not. Look what a mess the central planners made of things yet again. They can call it appraisal modernization but really it’s a step back to before the days of applied rigid oversight. Longer post coming later. Thanks.
Thank you for continuing your efforts for truth, Mary. I know this has been a project of your’s and you are appreciated .
Kenneth, first of all, I am so sorry you are being put through this. Your resolve and tenacity is hugely commendable. Have you contacted any of the media to discuss your findings? Our muckraker type bloggers, Glenn Beck, Tucker Carlson, etc. This isn’t small potatoes.
I can’t help but think back to the Housing Subcommittee Hearing of June 2019, when Andre Perry sat on the panel with 4 other appraisers and launched his faux study.
This has been in the works for some time. And when you get rid of boots on the ground appraisers, nothing stands in the way of the GSEs big data machines to pump the profit from the mortgage market, and the Treasury still profits from them. I’ve been connecting these dots for several years, but your information here places a whole new foundation.
Title: Thank You, Baggins — And to the Entire Appraisal Industry: It’s Time to Demand Clawbacks
By Kenneth J. Mullinix
This week, Baggins published a powerful statement that cut through the noise and named the uncomfortable truth: the appraisal profession, its institutions, and its regulators failed to stand up when it mattered most. And now, one appraiser — myself — has been left to do the work that eight federal agencies, four regulatory boards, and multiple national organizations should have done years ago.
Baggins wrote that I was “caught in the cross fire hurricane” of HUD’s reckless and unlawful appraisal bias crusade. He’s right.
I have spent years gathering evidence, submitting FOIA requests, filing legal and civil rights complaints, and sharing my findings publicly. And now, I am being contacted by appraisers across the country — and legal professionals, insurers, and policy observers — who are beginning to realize the same thing: what HUD did under the PAVE Task Force was not just administratively sloppy. It was illegal, damaging, and built on a foundation of misrepresentation.
I want to publicly thank Baggins for standing up, for naming names, and for pointing the finger where it belongs: not at the appraisers who’ve been targeted, but at the institutions that let it happen.
Here’s what we now know:
HUD opened hundreds of what they called “appraisal bias cases” with no TEAPOTS case numbers, no formal investigations, and in many cases, no jurisdiction — especially where the loans were VA, conventional, or private.
Appraisers were pushed to settle, pressured to admit wrongdoing, or handed over to legal departments under the threat of reputational ruin.
E&O insurance carriers paid settlements that were never justified.
Homeowners were manipulated into believing they were victims of bias — and then used to trigger enforcement actions against appraisers who had done nothing wrong.
And worst of all, the industry’s leading institutions — the Appraisal Institute, The Appraisal Foundation, state boards, and the GSEs — fell in line with HUD’s narrative and failed to question its legitimacy.
I have now formally contacted American Oversight and the Appraisal Institute, urging them to examine the funding, policy agreements, and legal implications of this campaign. If their organizations were misled by HUD, they owe it to their members to reverse course and demand accountability.
Here’s what must happen next:
Any E&O carrier who paid a settlement under false pretenses should demand full recovery.
Any appraiser who was coerced into bias training, settlement, or a gag order under HUD’s PAVE narrative should be legally absolved — and refunded where possible.
Any attorney who paid HUD on behalf of a client to settle a case based on “bias” that was never proven — and never should have been prosecuted — should consider suing HUD for reimbursement.
Every homeowner who was used as a prop in this scheme deserves transparency. Many of them were told they were harmed when in fact they were part of a broader statistical manipulation.
And finally, any appraisal organization that pushed PAVE-aligned policy or training mandates without understanding the legal deception behind it — should reconsider those positions now.
This wasn’t about equity. This was about control. It was about money. And it was about federal power being used to coerce and silence professionals who had no due process and no way to fight back — until now.
The time for passive compliance is over.
The time for refunds, clawbacks, apologies, and investigations is here.
And to those reading this — if your company, insurer, law firm, or regulatory board was involved in any of these settlements or enforcement actions — I invite you to contact me. I have the documentation. I have the emails. And now, I have the public and professional backing to keep going.
Thank you again, Baggins, for your courage and clarity. Let’s finish what’s been started.
Sincerely,
Kenneth J. Mullinix
VA-Approved Fee Panel Appraiser
HUD Whistleblower
Newport Beach, CA
Thanks again Kenneth, we look forward to following your story and hope we can all be a part of it.
MISREPRESENTATION TO THE HOMEOWNER
“HUD Misled the Complainant (Homeowner) Too — A Two-Sided Deception”
Prepared for EEOC Review | Kenneth J. Mullinix | May 2025
While this report primarily outlines the civil rights violations and procedural abuse committed against me as a disabled federal contractor, this addendum documents how the homeowner who filed the complaint was also misled by HUD — in many of the same ways. This two-sided deception implicates HUD in not only violating due process for the accused but also undermining the rights and expectations of the complainant.
________________________________________
1. What the Law Requires in a Legal Complaint
Under the Fair Housing Act (FHA), 42 U.S.C. §§ 3601–3619, any person who believes they have been subjected to housing discrimination must file a formal complaint with HUD using Form HUD-903.1. A valid complaint must:
• Identify a basis for discrimination under a protected class (e.g., race, color, religion, national origin, sex, familial status, or disability)
• Be signed under penalty of perjury
• Trigger a jurisdictional review per 24 CFR § 103.25
• If found valid, be entered into TEAPOTS (Government Evidence Storage)(Title Eight Automated Paperless Office Tracking System)
• Be assigned a formal HUD case number
• Be investigated under an official plan as required by HUD Handbook 8024.1 REV-2, Chapter 5
HUD must also notify the complainant of:
• Their rights and responsibilities
• Whether the case has jurisdiction
• The eventual outcome of the case (via written closure or referral to an ALJ or DOJ)
________________________________________
2. What the Homeowner Likely Signed Under PAVE
In my case — and based on FOIA disclosures — the complainant did not submit a sworn HUD-903.1 complaint. Instead, HUD appears to have conducted a verbal or informal intake interview and used it to create a risk assessment file, not a legal complaint.
• No TEAPOTS case number was ever assigned
• No Administrative Law Judge (ALJ) referral or final findings were issued
• No formal notification of closure was ever sent to the homeowner
• To date, no HUD-903.1 Fair Housing Complaint Form signed by the complainant has been produced. Under 24 CFR § 103.25 and HUD Handbook 8024.1 REV-2, a signed complaint form is legally required before a jurisdictional review, TEAPOTS case opening, or investigative action can be taken.
• The absence of this document — confirmed by FOIA — establishes that no legal complaint was filed, and therefore no lawful investigation ever commenced. This raises serious questions about HUD’s invocation of FOIA Exemption 7(A) and the legitimacy of the PAVE program’s enforcement metrics.”
The homeowner was never advised that their claim would not be reviewed under federal law or that HUD had no jurisdiction due to the property being appraised under a VA loan, which falls under the jurisdiction of the U.S. Department of Veterans Affairs — not HUD.
________________________________________
3. Why This Was Misleading and Harmful
HUD misrepresented to the homeowner that their complaint was being addressed under federal civil rights law. In fact:
• There was no formal complaint on file
• No legal action could ever occur due to jurisdictional ineligibility
• The homeowner was never told this truth
• They were used to create an “open case” metric for the PAVE Task Force
This not only harmed me as the appraiser but defrauded the complainant, who likely believed justice was being pursued on their behalf. That complaint became nothing more than an intake record, abandoned once its administrative purpose was fulfilled.
________________________________________
4. Relevant Legal and Policy Violations
The misrepresentation to the homeowner may constitute violations of:
• Fair Housing Act procedural obligations (24 CFR § 103.25 and § 103.400)
• 18 U.S.C. § 1001 – False statements to federal officials or the public (e.g., if HUD publicly claimed these were active legal cases)
• 31 U.S.C. §§ 3729–3733 (False Claims Act) – Misusing complaint data to justify federal grant funding under PAVE
• Section 504 of the Rehabilitation Act (29 U.S.C. § 794) – If disabled complainants were similarly deceived
• 5 U.S.C. § 552a (Privacy Act) – If complaint data was used outside its lawful purpose
• HUD Handbook 8024.1 REV-2 – For failure to open a legal case, issue findings, or close the file properly
________________________________________
5. Conclusion: A Double Deception
This case is no longer about just me, the appraiser. The entire structure of the PAVE enforcement program — as applied by HUD Region IX — appears to have been built on administrative illusions that harmed both the accused and the accuser.
The homeowner believed they were filing a real complaint. I believed I was under real investigation.
Neither of us were told the truth.
This double-deception strategy reveals the PAVE initiative as not a civil rights enforcement program, but a data fabrication and grant-justification engine. The harm done to homeowners — by raising false expectations and delivering no closure — deserves the same attention and accountability as the harm done to appraisers.
This matter should be referred to:
• The EEOC for systemic civil rights abuse
• The HUD Office of Inspector General (OIG) for audit and fraud review
• The U.S. Department of Justice for potential False Claims Act violations
________________________________________
Interested to follow…
Sigh….this horse is dead. Let’s talk about raising assignment prices for the appraiser.
This is NOT dead, I have a pending case open with my State now because of the FNMA word police. I think most States would have declined to open a case but NC does regardless of merit.
C Vaughn- this case is not dead, what HUD and the Pave Initiative did to the appraisal industry is criminal and will not be forgotten for years. Appraisers are still being investigated illegally causing financial, emotional and career ending harm. Pave took about $80M dollar estimated in a possible Theft of Government Funds Scheme. So no this is not over just because you say so or think it is.
Sure it is. This current administration has pretty much made this a moot point. No, It doesn’t change the angst and financial impact for the party investigated. But they unlikely to continue to pursue appraisers IMO. I wouldn’t be shocked if Fair Housing went to the wayside.
Ken,
What do we do?
Pat, what I have compiled is a ongoing list of appraisers that are caught up in HUD investigation. If you investigation from HUD does not involve a FHA loan then HUD has no legal jurisdiction to investigate you, what they are doing are “intake” or “risk assessment” investigations not real legal cases by law so if you have been investigated contact me by email with; you name, phone number, email address and few paragraphs about your story and what has happened. I am putting together a detailed list of fellow appraisers who have been investigated illegally so when the time comes was add those affected in a class action suit or demand restitution with monetary damages in any negotiated settlements. Send that information to: kjmull@aol.com. Ken