IAFST Files for a Dedicated NAICS Code — And the Industry Immediately Understands Why That Terrifies It

The NAICS That NAMFS Members Are Fighting Against

August 15, 2026

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The International Association of Field Service Technicians (IAFST) has formally submitted a proposal to the Economic Classification Policy Committee requesting a dedicated NAICS code for the Mortgage Field Services Industry. The filing, docketed as USBC-2024-0032-0013, asked the federal government to establish NAICS 238360 — Mortgage Field Services — for the 2027 revision cycle. It is a twelve-page document. It should not have taken this long to write.

The Problem the Industry Has Spent a Decade Ignoring

Right now, mortgage field services providers operate under a patchwork of borrowed codes. Building Inspection Services. Janitorial Services. Landscaping Services. Office Administrative Services. Residential Property Managers. None of them describe what an FST actually does, and none of them were built to.

That is not an accident. A vague classification is a feature, not a bug, for an industry that has spent years arguing — in courtrooms, in depositions, in front of the Department of Labor — that it cannot possibly track pay and labor conditions for a workforce that does not officially exist as its own category. You cannot report wage data for a NAICS code that has never been assigned. You cannot benchmark misclassification against an industry the Census Bureau does not recognize. Every FST know this. Every firm profiting from the ambiguity knows it too.

What the Filing Actually Says

IAFST’s proposal lays out the case cleanly. Inspection services, property securing, winterization, debris removal, handyman repairs, lawn care, code compliance, eviction support — all of it currently gets crammed into five or six unrelated codes, none of which capture the compliance documentation, the reporting cadence, or the direct coordination with servicers and municipalities that defines the work.

The filing cites an estimated $1.465 billion in annual industry revenue and roughly 45,000 workers nationwide, figures built off Foreclosurepedia’s own Altisource-derived formula and adjusted for the current 1.73% residential default rate. It walks through eight existing codes the industry has been forced to borrow from, and it explains — in plain terms — why each one fails. 561730 covers the mowing but not the inspections. 541350 covers the inspections but not the repairs. 531311 covers property management but ignores foreclosure-specific compliance entirely.

The filing even surfaces the HUD FSM 3.6 history: a former M&M Director solicited those contracts under the Janitorial/Custodial NAICS specifically because the dollar threshold for 531311 was low enough to graduate successful FSMs out of small-business status within a year. Good performers got pushed out of Prime eligibility on follow-on awards before they ever had a chance to compete. SBA eventually ran an out-of-cycle review and raised the threshold. That correction should never have been necessary. A dedicated code would have prevented the problem at the source.

Why the Industry Will Fight This Quietly

Nobody in this industry is going to stand up at a hearing and say, on the record, that they oppose a NAICS code because it would make wage theft harder to hide. That is not how it works. The opposition will come dressed as concern about compliance burden, about reporting overhead, about how a new code disrupts existing government contracting relationships built on the old classifications.

Strip that away and the real objection is simple. A dedicated NAICS code means the Bureau of Labor Statistics can finally publish wage data specific to this workforce. It means the DOL can benchmark misclassification claims — the kind that produced Hurst v. Buczek — against an actual labor market baseline instead of arguing from scratch every time. It means inspectors paid $7 to $9 a job, and technicians doing $25 to $30 grass cuts and $45 to $50 winterizations, stop being invisible in federal statistics.

Firms that have built entire business models on 1099 misclassification and border-line wage floors have every incentive to keep this industry statistically nonexistent. A code that makes their labor practices measurable is a code that makes their labor practices litigable.

Where This Goes Next

The ECPC reviews NAICS revision proposals on a five-year cycle, with the next window landing in 2027. IAFST’s filing asks the Board to consider the petition for that cycle and has offered to supply additional industry data, case studies, and documentation as requested.

Foreclosurepedia will track this filing through the comment period and report on any pushback that surfaces — quiet or otherwise. If a NAMFS member firm, a servicer platform, or an industry association submits an objection to this docket, that objection becomes news the moment it’s filed.