This is a good post. And who was behind all of it? The appraisal trade group leaders whom failed to do anything about this from the very beginning. re congressional hearing with brookings and andre perry. They’re all incompetent or on the take, directed by either amc’s, lenders, other investment companies like corelogic. Corelogic like many ohters has a stake in patented automated software for automatic loan generation and automatic loan handling including automated valuation process. The TAF, AI, ASC, AQB, the Comptroller asleep at the wheel. The AVM final rule is on the books. It’s why there is so little mortgage lending work today for appraisers. Why despite a historical rush in mortgage lending, appraiser licensee head count only went down not up. The valuation bias correction algorithms are most likely already incorporated into the avm processes now. Social credit scoring is here. All lending is soon to be based on mass data analysis models for valuation.

Appraisers and most others are not seeing the bigger picture here. PAVE was created with a specific goal in mind. That specific goal was justification to circumvent decades worth of regulatory guidance and operate using these tools instead. They backed into the argument of valuation bias with a predetermined goal in mind; to push the avm final rule. They ran that across the finish line at the last minute with minimal attention and no fanfare. They had millions of people through the realty spectrum looking at other things while they snuck the avm final rule in. Lender participation with the AVM final rule is mandatory. FHFA remains asleep at the wheel. Palantir is not going to solve anything. The fraud is baked in via automated process now. The incompetency and wholesale sell out of any remaining thread of ethical principals by the appraisal trade groups in coordination with the appraisal management company industry, has resulted in a near complete departure from traditional and sound independent checks and balances systems. The general public will just have to trust the lenders and investment industry that they’re honest. Higher prices for everyone. Forever.

https://patents.google.com/patent/US8775300B2/en?oq=us8775300b2
They’re all into these sorts of patented automatic utilities. From FNMA down to individual amc’s. Class applied over and over again for years until they finally got their patented works through recently. The reason Corelogic rushed the appraisal industry was they needed the massive database of appraisers intellectual property as their own, in order to make these tools work.

Why the Damage Isn’t Over—Even if the Program Is Out of the Headlines
Even though the PAVE initiative has faded from news cycles, its national damage lingers—and it’s still being quietly paid for.

The U.S. Department of Housing and Urban Development (HUD), through its PAVE (Property Appraisal and Valuation Equity) task force, launched a sweeping campaign to root out racial bias in home appraisals. But behind the headlines and the policy speeches was a darker reality: thousands of appraisers, insurers, homeowners, and legal professionals were swept into a national enforcement scheme—without legal foundation, oversight, or jurisdiction.
And the final bill? Easily over $750 million—and still climbing.
________________________________________

What Happened

HUD pursued hundreds, possibly thousands, of appraisers—many of whom were not working on FHA-backed loans. That’s critical, because HUD only has enforcement jurisdiction in housing discrimination cases involving FHA or HUD-funded programs.

Instead of following the law, HUD blurred jurisdictional lines, pressured appraisers into settlements, misclassified “risk assessments” as civil rights cases, and pushed insurers to pay out on cases that were never legally filed in TEAPOTS (HUD’s tracking system for legitimate enforcement).

The result? A manufactured crisis—designed more for optics and funding than for justice.
________________________________________

Who Paid the Price?

1. Appraisers

• Many were forced to hire legal counsel just to defend themselves from a federal agency they never legally fell under.

• Others paid settlements just to make the problem go away—whether or not they were ever charged.
• Hundreds were forced into “bias training” programs, publicly humiliated, and labeled as discriminatory based on nothing more than suspicion or ZIP code profiling.

• Still others lost clients, insurance coverage, or years of income.

Estimated losses: $60M–$100M
________________________________________

2. Insurance Companies

• Carriers absorbed the cost of defending or settling cases that HUD often had no jurisdiction to pursue.
• These payouts, in turn, led to higher premiums or dropped coverage for appraisers across the country.

Estimated losses: $40M–$80M
________________________________________

3. Homeowners

• Ironically, many homeowners who submitted complaints to HUD suffered financial harm as well.
• Loan delays, higher interest rates, and appraisal replacements during a rising rate environment caused tens of thousands of dollars in added cost per household.

Estimated losses: $15M–$35M
________________________________________

4. Law Firms

• Both plaintiffs’ and defense firms billed millions during years of unnecessary litigation and negotiations.
• Many appraisers were targeted by private lawyers piggybacking on PAVE policy language—even without a valid legal claim.

Estimated legal expenditures: $100M+
________________________________________

5. Bias Class Vendors

• HUD and associated agencies funneled millions into diversity and bias training programs that were often mandated as part of settlement agreements.

• These programs profited while appraisers—many of whom were not guilty of anything—were forced to pay and attend.

Estimated program revenue: $25M–$50M
________________________________________

6. The Appraisal Institute

• In one high-profile example, the Appraisal Institute reportedly settled with HUD for $20 million, admitting no wrongdoing but absorbing substantial reputational and financial damage.

Direct settlement: $20M
________________________________________

Estimated National Total: $750 Million+

And this is just the visible portion. What’s still hidden includes:

• The full number of cases never formally filed but quietly resolved through threat and pressure
• HUD’s internal costs, misused federal funds, and contractor expenses
• The emotional toll on professionals falsely accused, blacklisted, or driven out of the industry
________________________________________

This Is Not Over

The PAVE program may not be front-page news anymore, but:

• Settlements are still happening
• FOIA requests are still being denied with a 7a denial
• Retaliation against whistleblowers is ongoing
• And the damage to the appraisal profession and public trust remains unresolved

HUD brought this damage onto the public—knowingly, and without proper legal authority.
________________________________________

What Needs to Happen Next

• Congress and the DOJ must subpoena HUD’s case records, internal emails, and PAVE funding justifications.
• A full audit must determine how many cases were illegitimate or lacked jurisdiction.
• Restitution must be considered for appraisers, homeowners, and insurers who were financially harmed.

This wasn’t just a policy overreach. It was a nationwide scheme with real victims—and a real price tag.
________________________________________

Want to help expose this?

Share this article.
Write your representative.
And if you’re an appraiser or homeowner affected by the PAVE initiative, it’s time to come forward.
Email me with your story I am saving all data for DOJ referrals as my case moves forward; Kenneth Mullinix at: kjmull@aol.com
________________________________________

I see you’ve asked different questions of the AI and given it an expanded operational peramiter. Another AI summary. But what is an AI program doing about anything? That’s the limitation of the tech. There are millions of people online right now running in a never ending circle, asking AI to figure out all these questions and find solutions to problems. Then nothing happens in terms of real change in the real world. Because everyone is lost in the tech and nobody is actually making any personal dedicated effort to effect change.

Think of the limitations of AI as something similar to a math equation in an educational book. All the software is capable of doing is repeating already known information to educate a student. The AI does not think per se, it is only trained on existing data, able to use existing formulas. What many people online end up doing is believing they are somehow more capable when using the AI tech, despite their inability or reluctance to form these arguments themselves in person without the AI tech assistants presence.

That’s where it’s capability ends and the responsibility to actually do something with the information falls on the human. So for every minute people spend quizzing AI tech systems about all their real world problems, is another minute gone by that nobody is making any real world effort to actually solve the problem. AI is nothing new, it never brings anything new to the table other than the occasional note of a human using it becoming slightly better educated on topic matter they were not equipped to use prior based on their own previous personal education.

Wake me when the AI system forms a legal argument, writes an official case file complaint, whatever it is lawyers actually do, pays the court fees, officially represents the appraisal industry and takes the amc industry down for known violations of multitudes of legal and procedural violations over the past two decades if not more. Can you program it to make phone calls and send two billion outbound calls and emails to amc’s asking them for their best fee and turn time, give them a taste of their own medicine? Can it reach into their bank accounts and transfer the stolen 12 billion of market potential appraisers were deprived of and return this to the appraisal industry? Can it solve the problem of the existing market forces which drive the appraisers out whom are not replenished, and provide balance to the industry?

I’m not impressed with AI tech. Never will be either. There is more value in being independently capable without having to rely on these sorts of tools. We need an advocate. That’s what the appraisal trade groups are supposed to be doing, but they refuse to do so. We know that’s not happening, as amc executives apparently pull the strings over there in a clear as day conflict of interest scenario.

If the masses of appraisers whom have serviced and continue to service the amc industry would have been much better educated on the principals of what ethics are, regulatory guidance and the spirit and reason why the guidance was formed and implemented in the first place, they would have collectively stopped the plunder. But they don’t actually understand ethic, or the regulation, or the reasoning behind it. Which is why they have been and continue to be complicit in consumer fraud, industry wide unethical behavior, and the amc industry has become the dominant market force in appraisal.

The amc industry and appraisers whom continue to accept their practices have commandeered the majority workload from the largest client set on the planet, the gse twins. The amc industry will be be moving into other spaces next. The amc industry has formed back room alliances with key appraiser persons, they’ve conspired to successfully plunder the hell out of the appraisal industry for decades.

The TAF and other groups basically begged the amc industry to take this approach, as their own long standing procedural violations were proof positive they prioritized the value of their personal wealth and self dealing far ahead of the needs of the majority of persons holding appraisers licenses. They ignored some of the most basic principals of ethics; to always be fair and honest and never deceive or take advantage of positions of power and trust.

That’s where Jeremy Bagott came in and blew the lid off the cosmic cobra, with the never ending institutionalized violations of states administrative procedural acts. The damned rules change so often in the appraisal industry, nobody bothers to keep up. The notion of ethical compliance in appraisal is an illusion. The top people are aligned with corporations whom function as agents of lenders, and made a fortune deceiving consumers and raking junk fee’s to the tune of billions of dollars over so many years. They willingly supported every action of ‘stake holders’ when those actions were clearly contradictory to the spirit of regulation and the needs of honest consumer protection apparatuses.

Additionally the training data for the AI’s summary is in question. / Mortgage rates have nearly tripled in four years, crushing affordability and stalling refinances. / What about the federal reserve, the devaluing dollar, the taxation on the money itself with artificially low interest rates? The inverse is true that the artificially low rate caused unnecessary inflation in housing. That the higher lending rate is not only appropriate, but absolutely necessary and should go much higher. That the cpi index is worthless, our actual relative value of our own money continues to decline at a much faster rate than inflation, aka; ever diminishing purchasing power. If they fire up housing with another round of low rates, will only make things that much worse. Or as some of us old fashioned humans whom understand keynesian economics might say; They buried multiple rounds of QE (quantitative easing) in the housing market but there is no room left to bury anymore.

The plunder continues.
_________________________________

Writing that myself without any computerized assistance other than being online with a computer took me about an hour out of my day. They key take away is it’s not about the time. It’s about the ability to be educated and know what’s actually going on. I can make these arguments in person, and I routinely do. That’s what real representation and real debate looks like. There is simply no substitute for the real thing. I keep writing letters asking important people out there in the world to take a serious look at the appraisal industry and save this thing before we hit the bottom of the cliff. Although some efforts have been made, they do not appear to be moving the line even a single inch. That’s because people at the very top of the ladder will not relinquish their power or ill gotten gains willingly. They’ll burn the whole thing down and eliminate the entire program before they allow that to happen. And that’s precisely what they did. Appraisal modernization. Again; the plunder continues.

Ken, put down the AI. You’re not bringing anything new to the table, and it’s rather distracting. You like the rest of the general public are not being told truthful information why AI systems are being put into place. Use of AI systems decreases cognitive abilities in humans. It is in no way a substitute for legitimate human effort and legitimate human conversation. I can see why many online now refuse to even read AI llm text. You know you can ask the thing to be relentless and never accept no for an answer? You can ask the AI system to do that. That’s when it gets really entertaining and even more frightening.

Want to play a game?

Thanks Bill.

https://homeappraisalhelp.progressive.com/

Anyone care to dive into this? I’m not even sure I want to invest the time anymore. Twenty years later, pretending to care. Betcha a pepsi that through all this new web content, if there is scant mention of the amc industry, they’ll be painted in a positive light.

New Appraisal Foundation guidance
_______________________

Greetings!

The first half of this year has gone by in a flash. As I’m writing our July newsletter, I cannot believe all of the incredible progress that has been made across our boards, councils, and Foundation team in the last six months.

Today I want to highlight the launch of two new resources the Foundation has been involved in.

First off, I am so pleased to announce the release of Home Appraisal Help by Progressive Insurance. The Foundation team, along with the Subject Matter Experts we contracted with, provided the appraisal expertise as we worked with the Progressive team over the last eighteen months.

These resources are precisely the type of interactive consumer tools that will help the public better understand the appraisal process. We are looking forward to expanding their use throughout our networks. Be sure to check out Home Appraisal Help here.

Our team is also delighted to share our new and improved website and webstore. We hope you’ll take some time this week to check it out. Be sure to check back throughout the rest of the year as we continue to add new content and tools to improve your experience!

These are just two examples of the types of innovative projects we plan to undertake to advance the appraisal profession and build public trust. If you have a bold impactful idea for where we can go next, we want to hear it! Reach out anytime.

The real estate appraisal industry isn’t collapsing—it’s eroding. Slowly. Quietly. And many of us still practicing can feel it more than we can see it. This isn’t just about technology, markets, or the economy. It’s also about trust, independence, and the ever-growing weight of political scrutiny.
________________________________________

Profession by the Numbers

• As of 2025, there are approximately 67,000 active appraisers holding over 91,000
• icenses nationwide.
• The Bureau of Labor Statistics projects only 4% job growth through 2033 — and nearly all of that is to replace those retiring.
• That equates to just 6,900 new appraisers a year — and not enough are entering the field to fill those shoes.
________________________________________

National Market Overview:

• May 2025: 4.03 million existing homes sold — the lowest May performance since 2009.
• Median U.S. home price: $422,800.
• Buyers now need $92,000/year income to afford a typical home; in 2018 it was $65,000.

Regional Trends:

• West: Median list price down ~2% YoY.
• South: Modest price declines as inventory builds.
• Midwest & Northeast: Days on market now 8–24 days longer than pre-pandemic.
________________________________________

Interest Rates: A Decade of Volatility

• 2015: ~3.4%
• 2021: ~2.7% (pandemic low)
• 2025: ~6.75% and rising

Mortgage rates have nearly tripled in four years, crushing affordability and stalling refinances.
________________________________________

Government, State & Agency Pressure: The Breaking Point

More appraisers are leaving the profession not because of tech or volume, but because of relentless scrutiny.

• Appraisers are increasingly investigated for political purposes.
• Agencies like HUD, the Federal Housing Finance Agency (FHFA), State Licensing Boards, Freddie Mac, Federal Home Loan Banks, and Consumer Financial Protection Bureau (CFPB) allowed appraisers to become scapegoats for policy failures.
• Appraisers are tired of being the target of high-profile bias campaigns while the systems that create inequities go unchecked.

We’re not just doing less work. We’re losing the will to keep doing it at all.
________________________________________

Appraiser Fees vs. AMC Cuts

• Customary and reasonable appraisal fees for a single-family home range from $450–700, depending on the market.
• Appraisal Management Companies (AMCs) may take 30–50% of that fee, paying appraisers as little as $250–300.
• AMCs add layers of bureaucracy, delay payment, and strip the appraiser of client contact—while pocketing the margin.
• Appraisers are now fighting back in court over violations of Dodd-Frank’s customary and reasonable fee requirements.
________________________________________

Automation: Replacing Expertise with Speed

Automated Valuation Models (AVMs), hybrid products, and desktop reports now dominate lender strategy.
But:
• A spreadsheet can’t see roof rot.
• A drone doesn’t hear freeway noise.
• A checkbox doesn’t weigh gentrification, zoning disputes, or community instability.

We’re told that automation is objective. But without boots on the ground, we’re losing the very thing that made the appraisal profession worth defending: human judgment.
________________________________________

Where Are We Going?

• The profession isn’t dying. It’s being redefined without us.
• If appraisers don’t speak up, we’ll be written out of relevance.

What Needs to Change

1. Protect independence in regulatory and lending policy.
2. Enforce customary and reasonable fees under federal law.
3. Stop political targeting and restore due process.
4. Involve appraisers in reform, not just automation developers.
________________________________________

About the Author

Kenneth Mullinix is a veteran VA appraiser and industry advocate based in California. He has completed thousands of residential assignments and writes frequently about the intersection of policy, practice, and professionalism in real estate valuation, along with advocating for ending racial bias and government overreach.

Over the years, seeing as most lenders fast track instructions to the appraiser when more is added to the scope of work, I wonder how fast they are going to communicate these new reduced standards.

My guess, like the MC form (not required) they won’t care and will still demand all of the now retired info still go in the report.

Seek the truth.
All of CA – Active Appraisers
05/21/2025 – = 7,790
06/30/2025 – = 7,717
On pace to lose 665 appraisers over 12 months

Thanks Todd. Just read that this morning in the FHA email and posted about it as well in the recent thread. / There should be a medal or award for which group can mis manage their appraisal program the worst possible way. It would be very tough decision to choose the winner, long lists of nominees. Yet again, people whom are not qualified working appraisers, decided what’s best for the appraisal industry and consumers whom relied on the programs.

https://appraisersblogs.com/baghdad-bob-of-freddie-mac-merits-mention-as-mideast-erupts/#comment-45535

Your looking at the PIH notice, this is the mortgagee letter notice. Here is the link.

https://www.hud.gov/sites/default/files/OCHCO/documents/2025-18hsgml.pdf

https://www.hud.gov/sites/default/files/OCHCO/documents/PIH_2025-18.pdf

This? Not seeing what you mentioned. Please clarify.

Changes in FHA policy are as of the effective date of the announcement, and do not apply to previous acts.

https://www.hud.gov/hudclips/letters/mortgagee

Still not seeing it.

I am also going through this. I am told they would drag it out ad cost me up toward 100k in attorney fees. Yet I hired all the correct specialist to help me and not one of them looked out for me.

Appraiser cropped out 50k in damage on chimney. Now I can’t replace the roof that he also failed to report and let’s not forget the electrical. I am not living in safe conditions nor do have money for the repairs or attorney fees.

Hey but I can walk away lose the 401k we invested at 60 + and try to find a cheap 1 bedroom apartment? Sure where is the consumer protection laws?

The Growing Fight for Appraisers’ Civil Rights and Due Process
By Kenneth Mullinix AR Appraiser

Across the country, appraisers are quietly enduring what many are now calling a campaign of intimidation. If you’ve been investigated by HUD — accused without a fair hearing, pressured without proper protocol, and left in limbo for months or even years — you’re not alone.

I know, because it happened to me.
And I now know I’m not the only one.
________________________________________

The Numbers Don’t Lie

As of today, I’ve personally been contacted by over 30 to 50 licensed appraisers who’ve had similar or nearly identical experiences. They tell stories of:

• HUD investigators opening cases with no meaningful explanation;
• Investigators seemingly operating from a script: “You’re guilty. Now prove you’re innocent.”
• Clear, documented evidence of compliance and fairness being outright ignored;
• Cases kept open indefinitely, often with no communication — yet remaining “active” on paper.

Why? Many of us believe these prolonged investigations allow certain agencies or departments to inflate the appearance of enforcement — possibly to meet internal funding metrics. Some are calling it a “pay-to-play” culture masked as policy enforcement.

HUD isn’t following its own Handbook protocols. They’re disregarding due process rights, and it’s creating real financial, reputational, and emotional damage to appraisers who have spent decades serving communities with integrity.
________________________________________

My Case — And What It Represents

In my own case, I’ve been repeatedly subjected to these tactics — despite clear and compelling evidence of compliance. I was cleared by the VA of racism/discrimination but HUD opened a case on me anyway. I gave them proof of this and they still persisted instead of closing the case, they’ve kept it open, made vague accusations, and declined to formally engage with the facts.

I have filed cases with both HUD and the VA. Some cases have been closed without explanation. Others are still open. I am currently awaiting the results of a formal Freedom of Information Act (FOIA) request about my case and the overall PAVE Initiative, which I believe will shed further light on just how these cases have been mishandled — not just in mine, but across the board.
________________________________________

This Is Bigger Than Just One Appraiser

The appraisers reaching out to me aren’t angry — they’re exhausted. Many have stopped responding to HUD entirely because they see no due process in sight. This is not justice. It’s not how federal oversight should work. And we’ve had enough!!

I have contacted many congressmen, government oversight committees, the DOJ, two Inspector General’s Offices at HUD and the VA, many media organizations, civil rights law firms, DOGE, right-leaning news outlets, and investigative journalist. I cannot tell you yet about my responses yet…but soon!

We’re now in the early stages of organizing a class action effort to defend our civil rights, to demand accountability, and to restore the integrity of our profession. If HUD is reading this — and we know you are — this is your notice:

We are still here!
We are growing!
And we are not backing down!

Are physical deficiencies noted on page 1 of the report? If yes, are
those deficiencies noted in the report with an itemized cost-to-cure
and is the report completed subject to those repairs?

Yet the copy of the report provided listed no subject to repairs.

Reminds me of a time that a seller listed ‘as is’, and the buyer in a desperate attempt to make a purchase opportunity, the buyers agent wrote into the contract something about agreeing to accept the property in as is condition. Alongside their FHA loan request from a nations top conventional loan lender.

I’ve got to show up as the appraiser and be the bad guy. ‘You can not write away GSE program requirements with your contractual language. The appraiser has independent requirements and I am not relieved of my responsibility or liability based on what sales agents write in their contracts. The selling guide clearly states (etc etc). The appraisal has conditioned these items as subject to meeting minimum property standards per the standard FHA rules and FHA handbook.’ I forget exactly but something with actively leaking pipes and a flooded crawl space, water delivery components in the bath turned off.

Had an agent from Better Mortgage pull that on me once too. A lady was upset that I called her electric panel as subject to repair, as someone had hot wired the thing, there were shock hazards, tabs missing, double loaded circuits. It would have only cost a thousand or two for proper corrections. The unit was an investment townhome right in the middle, posing a fire hazard for the entire block. Upon complaining about the appraisal to the mb, the mb told her it would be fine to defer the corrections until she had available money, and to tell the appraiser it’s o.k. to make the report as is and revise. They dropped me from the approval panel for refusing to comply.

And that’s obviously why these deals go through with AMC’s or anywhere else, when there are obvious property faults. Pressure from the originator and appraisers learn that if they demonstrate real independence they’ll be removed from panel or blacklisted in one manner or another. When the lenders cover for this behavior and it harms consumers, it’s beyond unethical and is arguably criminal. Apparently the judge believed that as long as the loan was successfully originated and someone slapped an ‘as is’ label on the sale listing, standard GSE program rules were no longer applicable.

Cardinal Financial/Class Valuation

I’m sorry but infact that statement is 100% false. The mortgage company and their selected appraiser whom they picked did infact false and inadequate fha appraisal. Plus lender allowed sellers Real estate agent to select the title company under policy is not allowed do to it being bais. Every complaint we have filed with HUD has never once properly investigated the complaint. And my husband is Hispanic and I am white. With all supporting documents hud not once requested a single document including our paid inspection report i paid for not hud. So now the sellers are now being sued in civil litigation. And HUD WONT SEE A DIME

As a realtor, I understand the process in inspections and reporting. With well and septic, it is the sellers obligation to pump the tank and do a well inspection. So yes, you can access the holding tank and have it pumped. Most jurisdictions have laws requiring them to be pumped minimally every 5 years.

It’s clear the appraiser is either incompetent and should not be appraising or was compelled to commit fraud by the AMC, Class Valuation, in order to continue receiving appraisal assignments.

Regardless, the appraiser should no longer be appraising! As for the others; Well… deep pockets have kept this poor lady and her children homeless, broke, and ruined her credit! To that, those involved should be ashamed!