The problem will be that HUD has already hired at least one or two appraisers that will defend HUD's position.some of the defenses given here won't hold up in court. if you take 2 appraisals done somewhat near each other and you put the subjects & comps on a map,. then you see all the black owner comps are to the right of the house, and all the white owners comps are to the left of the house you have no defense. this appraiser will be bankrupted, or just plead guilty. E&O does not cover fraud, in which this case it is racial fraud. and the appraiser deserves it. solidiffi was a canadian co that paid very well when they started in this area long ago. it was mostly foreclosed stuff. but eventually they paid less, and it was a pain dealing with them. no sympathy for them. but nothing will happen to anyone there. they will close, then open up again as another AMC. a while back rocket employees were posting how bad it was working there. are they doing r.e. sales now on line, i saw rocket realty on tv.
A word salad. Looks like their goal is BS with no substance.
Per your comment in post #6 - used properties to the East and Not the West, which would be cause for the questions HUD has.If the facts alleged are as presented then this looks like a legit allegation insofar as the value is concerned. It's kind of interesting that an appraiser would have to leave the neighborhood at all in order to find any comparable but that's exactly the reason why the problem identification phase of the assignment should ideally include an analysis of the sales histories for the different areas to see how they have done in comparison with each other in the past. I'd be looking closely at rental rates to see what the tenants think about these locations, and I'd be looking at the SFR sales to see how those buyers are reacting to these locations.