Eduardo “Fast Eddie” San Roman’s 24 Asset Management holds six HUD Field Service Manager 3.12 awards across ten geographic areas, with first-year contract value reported at $51,045,736 and a life-of-contract ceiling industry contractors put north of $102 million. Labor performing preservation work under that contract has gone unpaid for months, with bounced checks, mechanics liens, and float schemes documented across multiple states and multiple technicians — not one asset, but a pattern repeating case after case. One Field Service Technician’s outstanding balance runs $38,674, with over $10,000 aged past 90 days and a check that arrived 46 days after the date printed on it. A separate case put $33,000 in unpaid work orders on the books since April 2026. A prior $21,000 non-payment dispute from January 2024 involved the same ownership.
None of that is in dispute. What matters now is simpler and worse: staff kept dispatching work orders after they knew.
The Contract Is Ending. The Exposure Isn’t.
24 Asset Management is on the precipice of losing its HUD FSM 3.12 contract according to many industry insiders. That should be the beginning of accountability, not the end of the story. A terminated award closes the spigot on new work orders. It does nothing to the record of who dispatched the old ones, who fielded the complaints, who kept the wheels turning while Labor went unpaid month after month. Contracts end. Knowledge does not expire with them.
This is precisely the moment industry memory matters most, because it is precisely the moment industry memory tends to fail. When a HUD FSM award changes hands, the Field Service Technicians and Inspectors on the ground rarely change. Neither, typically, do the project managers, contract managers, and coordinators who ran operations for the outgoing contractor. They update a résumé, submit to the incoming firm’s onboarding, and carry every ounce of what they knew straight through the door with them — unexamined, unquestioned, and now working the same territory for someone new. Revolving door 101.
Foreclosurepedia is putting two audiences on notice now, while the record is fresh and before the transition obscures it.
To Labor: if you are still owed money by 24 Asset Management when this contract changes hands, document everything before the transition completes. Invoices, dates, correspondence, liens filed, liens threatened, every email where a staff member acknowledged the debt without paying it. A change in prime contractor does not extinguish what you are owed, and it does not erase the paper trail proving who at 24AM knew and did nothing. That record is your leverage, whether the venue ends up being a mechanics lien, a False Claims Act qui tam action, or simple public pressure on whoever inherits the territory next.
To the next HUD M&M FSM holder, whoever that turns out to be: vet your hires. A résumé that lists 24 Asset Management is not disqualifying on its face — plenty of good people worked field operations for a bad company and had no visibility into payment decisions above their pay grade. But a hiring manager who does not ask hard, specific questions about what a candidate knew, when they knew it, and what they did about it is choosing convenience over diligence on a federal contract. If you bring on staff who fielded Labor’s complaints at 24AM and kept dispatching work orders anyway, you are not hiring experience. You are importing the same willful blindness that got the prior holder into this position, and inheriting whatever liability comes attached to it. HUD’s own procurement office should be asking the same question before the next award goes out, not after Labor files the next round of complaints.
The Choice Being Made Every Day
Work orders on a HUD M&M FSM contract don’t dispatch themselves. Someone reviews the queue, assigns the vendor, and pushes the order out by email or work order software. That person is not anonymous to the system. Every dispatch is logged, timestamped, and tied to a login.
When that same person has fielded complaints from unpaid Labor across multiple states, has watched the nonpayment surface publicly and repeatedly, and keeps pushing orders to vendors anyway, the defense collapses to one sentence: I just did my job. That sentence has never been a defense to fraud. It has only ever been an explanation for why someone chose not to stop. The Nuremberg defense didn’t work for the Nazis and it certainly doesn’t work here.
Why “I Didn’t Control the Money” Doesn’t Close the Exposure
Federal law does not require someone to control a bank account to be exposed to liability for a fraudulent scheme they knowingly kept running — and it’s worth being precise about what the federal rulebook actually requires here, because 24 Asset Management’s own size status is part of the story.
24 Asset Management holds its HUD FSM 3.12 awards as a small business prime contractor. That status matters more than it should. FAR 52.242-5, the clause that requires prime contractors to notify a contracting officer in writing within 14 days of any reduced or untimely payment to a subcontractor, exists specifically to protect small business subcontractors from large primes. By design, it does not reach a prime that is itself a small business. Neither does the small business subcontracting plan requirement under FAR 19.702 and 52.219-9, which is where that 14-day notification duty actually lives. Both are built for the opposite direction of harm than what’s happening here.
That is not a loophole 24AM engineered. It is a structural gap in the FAR. The same small business status that made 24 Asset Management eligible to compete for these set-aside opportunities in the first place is also what exempts them from the one federal mechanism specifically designed to force a paper trail on exactly this pattern: months of untimely payment to the people doing the actual work. A $102 million federal contract carries none of the payment-transparency obligations it would carry if awarded to a large business, purely because of the size designation that helped 24AM win it. And even that needs closer scrutiny with the direct ties to Assero, under Fast Eddie’s control and bailed on nearly a million dollars owed to Labor, which is a story for another day.
That gap does not eliminate the legal exposure elsewhere. It just means nobody was required to catch it early on paper.
Willful blindness. Federal courts, including the Supreme Court in Global-Tech Appliances v. SEB (2011), have treated deliberate avoidance of knowledge as legally equivalent to actual knowledge. Staff who receive complaints from unpaid Labor across multiple assets and multiple states, watch those complaints escalate publicly, and keep dispatching work orders without asking hard questions internally do not get to claim ignorance later. Willful blindness is not a shield. It is a separate theory of liability, and it does not depend on the size of the company doing the dispatching, or on whether that company still holds the contract by the time the questions get asked.
The False Claims Act. HUD FSM 3.12 work is federally funded, and payment on federal contracts typically runs through certifications that the contractor is complying with program requirements, including timely payment to subcontracted Labor. Knowingly submitting, or knowingly causing to be submitted, a false certification to obtain federal payment can trigger liability under 31 U.S.C. § 3729. The statute reaches anyone who knowingly causes a false claim, not only the person who signs it. It also authorizes qui tam suits, meaning a current or former employee or contractor with direct knowledge can file on the government’s behalf and share in the recovery — and that right to file does not disappear when the underlying contract does.
Wire fraud exposure. 18 U.S.C. § 1343 reaches any scheme to defraud that uses interstate wire communications in furtherance of the scheme. Dispatching work orders by email, EDI, or work order software across state lines, to Labor the firm has reason to know will not be paid, checks that box. A check dated 46 days before delivery is not an accident of the mail. It is a float scheme, and someone had to decide to send it that way. The statute does not require the person sending the dispatch to also be the one withholding payment. It requires participation, using interstate electronic means, with knowledge of the fraud’s basic contours.
Suspension and debarment. Federal procurement regulations under 2 CFR Part 180 allow suspension or debarment of individuals, not only entities, where there is evidence of a lack of business integrity seriously affecting present responsibility. A staff member’s documented knowledge of a nonpayment pattern spanning multiple states and multiple technicians, on a nine-figure HUD-funded contract, is precisely the fact pattern debarment referrals are built on, and losing the contract does not retroactively clean that record. If anything, a contract ending under this kind of cloud is exactly when HUD should be looking hardest at debarment, not quietly moving on.
The Moral Question Nobody in This Industry Wants Asked
Set the statutes aside for a moment. If you know Labor is being defrauded on a federal contract, and you keep the work orders flowing anyway, you are not a bystander. You are choosing continued income over reporting known criminality. That is a decision, not a job description. Federal whistleblower protections exist specifically because Congress understood that insiders are often the only people positioned to stop fraud before it compounds. This contractor already has one whistleblower complaint reported spiked. Choosing silence over disclosure is not neutral. It is complicity dressed up as professionalism, and it is a choice every staff member with visibility into these work orders makes fresh each time they hit send.
Secretary Scott Turner has spent this year testifying about stewardship of taxpayer dollars. Stewardship is not a word that survives contact with a $102 million contract sitting on top of a documented, near-decade-old nonpayment pattern, protected by named procurement staff who have been publicly identified and never removed, and shielded on paper by a size-status exemption nobody at HUD seems inclined to revisit. If the department’s own officials can be quietly recycled from one protection assignment to the next, the question of who else is being recycled through the same contractor’s staff roster is not a tangent. It is the same rot, one level down.
And there is a second question this industry keeps refusing to answer honestly: how many of the people currently occupying project manager and contract manager seats at HUD M&M FSM holders were sitting in the same seats, at a different firm, the last time that firm’s payment practices collapsed? Field services is a small industry. The same names surface again and again — one order mill implodes, and the staff who watched it happen simply resurface at the next HUD-panel contractor down the road, résumé intact, references intact, knowledge intact. 24 Asset Management’s own contract sitting on the precipice right now is the exact moment that cycle either breaks or repeats, and it depends entirely on whether the next holder does the diligence this one’s hiring managers apparently didn’t.
The public funding these contracts has a right to know when the people administering them are repeat witnesses to the same pattern of nonpayment, firm after firm. HUD’s procurement office has a right to know it too, before award decisions get made rather than after Labor has gone unpaid for another six months. Silence protects the individual’s next job. It does not protect the taxpayer, and it does not protect Labor standing in a driveway wondering why the check — dated six weeks earlier — only just arrived.
24 Asset Management’s grip on its HUD FSM 3.12 award areas may be ending. Labor across multiple states is still waiting on payment stretching back months, under the same contracting-office oversight that has drawn public scrutiny for nearly a decade. Foreclosurepedia will continue documenting who inside that structure had knowledge and kept the work moving anyway — not because a name on a payroll matters, but because knowledge, once documented, does not evaporate when someone changes employers, and neither does the responsibility to disclose it before the next contractor hands them a badge.
This analysis discusses potential legal theories as a matter of public interest reporting on federally funded contract work. It is not a legal conclusion, a formal allegation against any named individual, and does not constitute legal advice.
