A vendor in Minnesota has come forward with the latest claim, and it is the heaviest yet. The vendor was forwarded Foreclosurepedia’s reporting on the HUD FSM 3.12 awards and says 24 Asset Management owes $130,000 for completed, approved work.
That claim goes onto a running tally of unpaid Labor that now exceeds half a million dollars. Every article in this series adds to the same number, and not one has drawn a reply from HUD or from the Office of Inspector General.
What The Vendor Says Is Owed
The vendor reports close to 1,100 completed and approved Lead Based Paint work orders, dating from June 24 through October 1, with some projects reaching back to July. That is more than three months of production, performed in the field, approved, and submitted.
The vendor also reports 30 completed excessive debris projects that remain unpaid, the oldest dating to 2024. A bill that has sat for two years is not a cash flow problem. It is a decision about who gets paid and who waits.
Almost all of these work orders, the vendor says, were paid by HUD. The vendor says a HUD Contracting Officer verified that payment to 24 Asset Management on the approved work. Foreclosurepedia has not seen that conversation and reports it as the vendor’s account.
I received your name and company as someone to contact regarding unpaid debt from 24 Assets. I was forwarded your article regarding the HUD FSM contract and the total mess 24 has created. Currently, 24 Assets owe me $130,000. I have LBP projects dating back to July, which HUD has paid 24. Close to 1,100 completed and approved individual work orders dating from June 24th to October 1. Excessive debris work orders are a mess; they owe me for 30 completed projects dating back to 2024. Almost all of these work orders have been paid by HUD. I have spoken to a HUD Contracting Officer and verified payment to 24 on approved work orders.
24 Asset Management Got Paid And Kept The Money
Take the vendor’s account at its plain meaning. HUD paid 24 Asset Management for work that Labor performed, and 24 Asset Management did not pass that money down. That is not a payment delay, and it is not a dispute between trading partners.
Foreclosurepedia’s position is that a prime contractor that collects federal money for approved work and refuses to pay the subcontractors who performed it violates the False Claims Act. A prime that asks HUD for payment represents that it is entitled to the money. Collecting on that representation and keeping what belongs to Labor is the conduct the statute was written to punish.
Lead Is Not Trash
The vendor made one point forcefully, and it deserves space. Lead Based Paint work is not hauling debris out of a vacant house. It demands training, containment, and careful cleanup, and it carries real health risk for the crew and for the next family that lives in the home. A vendor who does that work correctly, wins approval, and then waits months for payment has financed a federal contract out of pocket while carrying the liability.
HUD Wrote It Down
HUD has already told the public why the 3.12 contracts failed. In its Justification and Approval for Other Than Full and Open Competition, J&A 26-30, HUD says it will not exercise the next option for the affected areas. It cites lack of performance, and it lists what that lack of performance caused.
HUD’s words: “key vendors suspending operations because of outstanding client invoices, lack of property preservation and maintenance triggering property liens and blocking the marketing or sale of homes, and non-payments escalated to Congressional inquiries, putting the Agency’s reputation and funding at risk.”
Read that slowly. HUD is not describing a paperwork dispute. It is describing vendors who shut their doors because they were not paid, homes frozen by liens, and Congress asking questions. The agency wrote it, and the agency signed it. HUD cannot say it did not know.

The Contractor Behind The Nonpayment Held Six Of Those Contracts
24 Asset Management held six of the 3.12 vehicles: 3A/4A, 5A/8A, 1D, 4D/5D, 5P, and 3S/5S. Spectrum Solutions Acquisitions held 2D and 4S/6S. Those incumbents continue through option year 2, with ordering periods running to February 15, 2027.
HUD’s stated reason for walking away is nonpayment. The vendors’ stated experience is that the prime was paid and Labor was not. Foreclosurepedia has now documented well over half a million dollars in claims, and HUD has taken no public step to recover a dollar of it for the people who did the work.
HUD’s Answer Was A Limited-Sources Award And A Chapter 11 Debtor
HUD’s replacement vehicle is J&A 26-30, a limited-sources procurement worth an estimated $170,829,743.00 across eight areas. HUD invoked “unusual and compelling urgency” to skip full and open competition. The term is 30 months, a 12-month base, one 12-month option, and a six-month extension.
HUD sent a Sources Sought Notice to five companies in July 2026, and all five answered. HUD shortlisted three as “uniquely capable”: Alpine Companies, P.K. Management Group, and A2Z Field Services. Altisource Solutions and VRM Mortgage Services answered in writing too and were not shortlisted.
A2Z Field Services is a Chapter 11 debtor in Subchapter V, Case No. 2:26-bk-52098 in the Southern District of Ohio. Its own sworn monthly operating report for August shows $1,979.31 in the bank, zero full-time employees, and $261,065.19 in post-petition vendor bills past due.
Either HUD never opened a public court record that anyone can pull in ten minutes, or HUD read it and shortlisted a bankrupt company that is not paying vendors for a program it says was ruined by vendors who did not pay. Both answers are an indictment.
Foreclosurepedia put A2Z’s sworn bankruptcy declaration in front of HUD’s Craig Karnes in May 2026, more than a month before the Sources Sought Notice went out. He did not reply.
The Rush To Award
HUD’s own paper trail adds to the problem. Alpine’s three awards, 3A/4A, 5A/8A, and 4S/6S, totaling $51,568,665.00, were signed before the Chief Procurement Officer approved the J&A. Then HUD issued Amendment 0001, partially canceling four areas with no stated reason. Those four areas, 1D, 2D, 4D/5D, and 5P, carry $96,622,154.00, or 56.56 percent of the J&A.
The approval chain is on the page. Paul M. Olin certified for the program office. Contracting Officer Charles W. Hoyle Jr. signed. Francine L. Hemphill, as Chief Procurement Officer, approved. Each had the authority to stop it and ask what HUD had checked. Foreclosurepedia has seen nothing showing that anyone did.
What This Is, and What It Isn’t
Federal rules require a prime contractor to certify that its subcontractors are entitled to payment before it requests payment from the government. That is FAR 52.232-27(h). A prime that certifies, collects, and then does not pay has a serious problem under that clause and under the False Claims Act.
The separate FAR 52.242-5 requirement to notify the contracting officer of late or reduced subcontractor payments does not apply to small business primes, and 24 Asset Management is one. That gap may explain why HUD heard so little from the prime while the debt grew.
A False Claims Act case still requires proof of what 24 Asset Management knew and certified. Foreclosurepedia has not seen the work orders, the HUD payment records, or the Contracting Officer conversation. That is exactly why the vendors’ records belong in front of investigators now, and the statute lets Labor put them there.
What Labor Must Do Now
File the complaint. Every unpaid Field Service Technician and Inspector, and every contractor stacked beneath them, who has a record of work HUD paid for should report it in three places.
Go to america.gov/fraud and file your claim. It is separate and outside of HUD.
Go to the HUD Office of Inspector General hotline and file here: https://www.hudoig.gov/hotline/hotline-form#no-back
Report it to Foreclosurepedia at [email protected].
Keep every work order, approval, photograph, invoice, and message about payment. If a HUD official verified payment to the prime on your work, write down who said it, when, and what was said.
Stay Off The HUD M&M FSM Contract
Unless and until the money owed to Labor is paid, Foreclosurepedia is calling on Labor to avoid the HUD M&M FSM contract. HUD’s own document says nonpayment is wrecking the program. The vendors say HUD paid the prime and Labor still went unpaid. Working that contract on those terms means financing a federal program out of your own pocket, and Foreclosurepedia considers it unsafe.
Do not take the work. Do not extend credit to a prime that has not paid its last invoice. Do not let anyone tell you the money is coming.
HUD said vendors were not paid. The vendors say HUD paid. The total is above half a million dollars, the Inspector General has not answered, and Labor is the only party in this chain that has already done its job.
The Debt Owed Thus Far
| State/Territory | Low | High | Basis |
|---|---|---|---|
| Puerto Rico | $42,900.00 | $42,900.00 | Documented: audits of 2,145 properties |
| Illinois | $29,286.50 | $29,286.50 | Documented: invoice sheet, 250 work orders |
| Texas, New Mexico, Puerto Rico | $45,458.00 | $45,458.00 | Documented: formal claim, 1,023 invoices |
| Central Florida | $37,035.00 | $37,035.00 | Documented: vendor invoice list |
| Pennsylvania | $100,000.00 | $100,000.00 | Vendor-reported, two vendors, approximate |
| Iowa | $25,000.00 | $30,000.00 | Vendor-reported |
| Indiana | $28,000.00 | $28,000.00 | Vendor-reported, three cleanouts |
| Minnesota | $158,000.00 | $158,000.00 | Vendor-reported, two vendors: $130,000.00 (about 1,100 Lead Based Paint work orders and 30 debris projects) and $28,000.00 |
| Colorado | $20,800.00 | $20,800.00 | Vendor-reported |
| Montana | $3,500.00 | $3,500.00 | Vendor-reported |
| Nebraska | $30,000.00 | $30,000.00 | Vendor-reported |
| North Dakota | $24,000.00 | $24,000.00 | Vendor-reported |
| State not identified | $46,000.00 | $46,000.00 | Vendor-reported: $33,000.00 on one asset since April, $13,000.00 since March |
| Total | $589,979.50 | $594,979.50 |







