kmullinix
Freshman Member
- Joined
- Apr 7, 2025
- Professional Status
- Certified Residential Appraiser
- State
- California
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.
Exact Laws and Handbook Sections HUD Violated:
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:
HUD conducted biased fishing expeditions, including:
"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:
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:
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 11-0-2021 homeowner 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:
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:
FOIA Reports Are Coming: HUD’s Illegal Numbers Will Be Public Soon
Pending FOIA requests will soon reveal:
and HUD will not be able to spin it away.
Legal Disclosure
This article constitutes protected whistleblower activity under:
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
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.
- 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.
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)
HUD conducted biased fishing expeditions, including:
- ZIP code fishing — asking for appraisals by neighborhood or city without a specific discriminatory allegation.
"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.
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.
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.
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
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 11-0-2021 homeowner 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.
- Constant emotional stress
- Worsening PTSD
- Insomnia/ sleep disorders
- Shingles outbreaks
- Anxiety/ panic attacks
- Financial damage
- Reputational harm
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 StatusBecause 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)
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.
and HUD will not be able to spin it away.
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
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
