On 04 October 2023, the International Association of Field Service Technicians (IAFST) sent a basic Freedom of Information Act (FOIA), 5 U.S.C. § 552, request to Housing and Urban Development (HUD) which has since been assigned the designator of #24-FI-HQ-00227. It was prefaced with weeks of emails between the IAFST and HUD simply requesting the ability to use the HUD Form 309 and Form 9519a for educational training by the IAFST University. These are common inspection forms, publicly available and used throughout the Mortgage Field Services Industry. In fact, dozens of other outlets use these forms in an ongoing and for profit nature daily. As opposed to the other firms, including the National Association of Mortgage Field Services (NAMFS), the IAFST wanted to take a road to legitimize documentation and training for Labor. In that, the IAFST Board of Directors requested a simple Yes or No as to using the documents. It was considered to be a win win in that if HUD Prime Vendors train Labor they, in essence, create misclassified employees. And if Labor cannot get training from a third party, the assets which HUD attempts to move up and down the Management and Marketing (M&M) contract may both jeopardize the rights of legitimate homeowners as well as cloud the very titles of the assets for sale.
Common sense is not something that the US government operates under whether it be a Democrat or Republican led White House. And while our current Administration finds that allowing 8 million+ illegal aliens to flood across our borders to take work from hard working Americans; while Fannie Mae, Freddie Mac and HUD believe that giving hundreds of millions of dollars in pay raises to Prime Vendors which never reach Labor itself is a wise use of US taxpayer dollars, the reality is education is required in order to keep assets moving from cradle-to-grave.
What is not disputed is that on 20 September 2023 I reached out to HUD via email and sent the below,
I created and operate the IAFST University. It is the educational arm of our trade association, the International Association of Field Service Technicians (IAFST). The IAFST is currently pending an IRS 501(c)(6) and is a registered nonprofit corporation based out of the State of Wyoming. To that point, I have attached the HUD 9519-a to this email and am in hopes that HUD will allow its use for training purposes under Section 107 of the Copyright Act or other applicable law(s), rule(s), or regulation(s).
A simple question requiring a simple answer. In fact, Section 107 probably renders anything that HUD may say, as both moot and immaterial. In the spirit of cooperation, though; in hopes of engaging the US government to achieve the common goal of an educated workforce, I thought that I would attempt to save US taxpayers some money. My experience has been colored now by what I might only describe as a Deep State of actors hellbent on power and control only to serve themselves. The irony here is that in nearly a dozen previous FOIA filings with HUD, there has been a conciliatory tone with most of them discharged informally. And remember, this was not a request to produce anything nor grant access to some type of classified document or statistic. What became the pretext to an outright assault upon the FOIA process was the questioning of HUD’s Award of $60 million dollars to 24 Asset Management, owned by Eduardo San Roman.
HUD’s newly minted M&M Field Service Manager (FSM) Awardee, 24 Asset Management owes nearly One Million Dollars to the victims of Assero, their subsidiary, including debts owed to Labor on Fannie Mae and LoanCare work. 24 Asset Management is a company who never had a contract spanning more than one job site and a maximum of $80K in single awards since 2011. HUD would have known this if they only read the emails sent to them about the victims or, at minimum, had performed 30 seconds of due diligence. In fact, the only way that 24 Asset Management even made it was with two loans from the Small Business Administration: One for $567,801.04 and the other for $545,503.48. That is a total of $1,113,304.52 to simply keep 24 Asset Management afloat. The mind boggling thing here is how HUD determined that 24 Asset Management, who was not financially solvent and owed nearly One Million Dollars to Labor, deserved $60 Million Dollars in HUD Awards.
How the Biden Administration has been operating, when it comes to FOIA requests, makes the former Trump Administration look like a joke. Here is how Wall Street on Parade put their experience,
On July 20, 2021 the U.S. Senate voted 56-44 to confirm Kenneth Polite (pronounced Po-leet) to head the most powerful criminal law enforcement office in the United States, the Criminal Division of the U.S. Department of Justice. The vetting of this candidate immediately raised red flags at Wall Street On Parade.
Despite Polite owing more than $1.5 million in debts according to his financial disclosure form and public mortgage records; paying over 18 percent interest on an outstanding balance on a credit card; 19.99 percent interest on a personal loan; and then accepting a job where his income was going to be slashed by approximately 77 percent – not one Senator on the Senate Judiciary Committee asked a single question about Polite’s unusual financial obligations during his confirmation hearing on May 26, 2021.
So, the IAFST Board of Directors put forth a formal FOIA two weeks after HUD refused to acknowledge the question filed earlier in September 2023. A month later the IAFST received an incomprehensible document, from HUD’s Denisha G Gilet, which looked like something from the Warren Commission explaining the Magic Bullet that assassinated President John F Kennedy. Now, remember, before you look at Gilet’s reply, this was a simple Yes or No question with the request to use documents attached to the FOIA itself FOR EDUCATING LABOR!
It was the epitome of madness! There is no doubt that HUD has always been a black hole of funds — both funds lost through malfeasance and also funds stored for intelligence operations allowed under law. What completely boggles the mind, though, is how HUD could refuse to answer a simple Yes or No question. Well, unless you take into consideration that neither Foreclosurepedia nor the IAFST donated to the Biden Reelection Campaign Fund.
On 11 December 2023, the IAFST received the following email from HUD’s FOIA Branch Chief which read,
I apologize for the delay in you getting your questions answered. Your request has been forwarded to the program office to provide a response to your FOIA request. Once they have concluded the search in response to what you are requesting, they will return their response back to the FOIA Office, so we can prepare a response to you. Thank you for your interest in the Department’s program.
Prepare a response? It is a Yes or No question! And I want to be extremely clear here, it is going to be hard to allow the use of these documents by Verisk, who currently owns all property preservation software used in the Industry and a firm that was formally identified as potentially involved in antitrust by HUD itself, and yet refuses the use of the same to a nonprofit organization. Here is how HUD put it, referencing Verisk,
I don’t know that it would move into the Anti-Trust space yet, but it does certainly appear to be headed in that direction. The price hikes as they gobble up the competition would certainly help lay the groundwork for an Anti-Trust case. Either way, it does certainly raise certain security concerns. I know that it’s at least on HUD’s radar, as it came up in an internal meeting I was in a couple weeks back where concerns were raised.
The continued stonewalling of HUD, with respect to the IAFST’s FOIA, is part and parcel why their current HUD M&M FSM Awards have not rolled out for years. Awarded over two years ago, HUD still has been incapable of placing financially solvent firms in their awarded slots. Guardian Asset Management, once again, had to take back control with an Award on nearly 90% of all contracts, through March of 2024. And as the internal data is showing, even if HUD can manage to get the Awards out in March, the pricing being offered by 24 Asset Management and others are nearly 40% below what is being paid today. When factored in that the current pricing today is that which is was back in 2009, the reality is the boycotts already ongoing against both pre and post conveyance HUD work, it will not end up well. According to the Bureau of Labor Statistics consumer price index, a dollar in 2023 can buy roughly 70% of what it could buy in 2009.
So, when Labor goes into 2024, what they need to think about is are they willing to do work that pays 40% less with money that is 30% less valuable. That is a combined total of a 70% loss in wages and there is no way Secretary Marcia Fudge can spin that differently in an election cycle.