oversight

FHFA Completed its Planned Procedures for a 2015 Representation and Warranty Framework Targeted Examination at Fannie Mae, but Did Not Document a Change to Planned Testing

Published by the Federal Housing Finance Agency, Office of Inspector General on 2018-03-13.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                               REDACTED

                      Federal Housing Finance Agency
                          Office of Inspector General




 FHFA Completed its Planned Procedures
 for a 2015 Representation and Warranty
   Framework Targeted Examination at
               Fannie Mae,
but Did Not Document a Change to Planned
                 Testing




   This report contains redactions of information that is privileged or confidential.

       Audit Report • AUD-2018-005 • March 13, 2018
                 Executive Summary
                 The Federal National Mortgage Association (Fannie Mae) and the Federal
                 Home Loan Mortgage Corporation (Freddie Mac) (together, the Enterprises)
                 provide liquidity to the U.S. housing finance system by supporting the
                 secondary mortgage market. The Enterprises purchase residential mortgages
                 from lenders and either hold these mortgages in their portfolios or bundle the
AUD-2018-005     purchased mortgages into securities for which they guarantee principal and
                 interest. In guaranteeing the securities, the Enterprises assume the credit risk
March 13, 2018   from possible default of the underlying mortgages. To mitigate this risk, the
                 Enterprises require lenders from whom they purchase residential mortgages to
                 make contractual representations and warranties wherein the lenders represent
                 that the mortgages meet specific underwriting requirements.

                 Historically, the Enterprises have relied on the lenders’ representations and
                 warranties that underwriting requirements were met and conducted limited due
                 diligence at the time the mortgages were purchased. When mortgages defaulted
                 or the borrower missed payments, the Enterprises would then review the loan
                 files for evidence of breach of the representations and warranties and exercise
                 their contractual rights to require lenders to repurchase, or buy back, non-
                 compliant loans. The Enterprises’ contractual rights to put back non-compliant
                 loans at any point during the term of the loans enabled the Enterprises to
                 reduce losses caused by underwriting defects.

                 In September 2012, the Federal Housing Finance Agency (FHFA) announced
                 that the Enterprises would launch a new representation and warranty
                 framework (new framework). The objective of the new framework was to
                 enhance transparency and certainty for lenders by clarifying when a mortgage
                 loan may be subject to repurchase. The new framework, designed by the
                 Enterprises to meet FHFA’s stated objective, shifted some risk of non-
                 compliance with representations and warranties from the lenders to the
                 Enterprises (and therefore to taxpayers). The new framework required
                 operational changes at the Enterprises to mitigate the additional risk. FHFA
                 recognized the need to test the adequacy of those operational changes, through
                 its supervisory activities, to ensure that the additional risk had been mitigated.

                 FHFA is charged by the Housing and Economic Recovery Act of 2008
                 (HERA) with, among other things, ensuring that the Enterprises and the
                 Federal Home Loan Banks operate in a safe and sound manner. Within FHFA,
                 the Division of Enterprise Regulation (DER) is responsible for the supervision
                 of the Enterprises. We recently issued the results of a completed audit, FHFA’s
                 2015 Report of Examination to Fannie Mae Failed to Follow FHFA’s
                 Standards Because it Reported on an Incomplete Targeted Examination of the
                 Enterprise’s New Representation and Warranty Framework, AUD-2017-008,
                 available online at https://www.fhfaoig.gov/reports/auditsandevaluations. In
                 that audit, we found that DER failed to follow FHFA standards when it
                 reported on the results of a 2015 new framework-related targeted examination
                 before that targeted examination had been subjected to a mandatory internal
                 quality control review.

                 This audit follows on that work. In this audit, we sought to determine whether
AUD-2018-005     DER performed its planned procedures and sufficiently supported its
                 conclusions for this same targeted examination. We found that DER performed
March 13, 2018   its planned procedures and the conclusions presented in the Conclusion Letter
                 to Fannie Mae were consistent with those detailed in the workpapers. We also
                 found that the workpapers sufficiently supported DER’s conclusions regarding
                 the                                                   . However, we also found
                 one instance in which DER did not document the reasons for a reduction in the
                 number of        it planned to test in compliance with established guidance. We
                 make no recommendations in this report.

                 We are also issuing today the results of our audit of DER’s execution of a
                 targeted examination of Freddie Mac’s risk management activities related to
                 the new framework. See FHFA Completed its Planned Procedures for a 2016
                 Representation and Warranty Framework Targeted Examination at Freddie
                 Mac, but the Supporting Workpapers Did Not Sufficiently Document the
                 Examination Work, AUD-2018-006, available online at
                 www.fhfaoig.gov/reports/auditsandevaluations.

                 This report was prepared by James Lisle, Audit Director; Marco Uribe,
                 Auditor-in-Charge; and Brian Maloney, Auditor; with the assistance of Bob
                 Taylor, Assistant Inspector General for Audits. We appreciate the cooperation
                 of FHFA staff, as well as the assistance of all those who contributed to the
                 preparation of the report.

                 This report has been distributed to Congress, the Office of Management and
                 Budget, and others and will be posted to our website, www.fhfaoig.gov.

                 Marla A. Freedman, Deputy Inspector General for Audits /s/
TABLE OF CONTENTS ................................................................
EXECUTIVE SUMMARY .............................................................................................................2

ABBREVIATIONS .........................................................................................................................5

BACKGROUND .............................................................................................................................6
      DER Supervisory Process .........................................................................................................6
      The New Framework Sought to Provide Greater Certainty to the Lender, Shifting
      Some Risk to the Enterprises ....................................................................................................7
      Prior OIG Work on the New Framework .................................................................................8

FACTS AND ANALYSIS...............................................................................................................9
      Required Documents Were Prepared and Approved for the 2015 Loan Quality
      Center Targeted Examination ...................................................................................................9
      Workpapers Supported DER’s Conclusions Regarding the
                  for This Targeted Examination ........................................................................10
      Rationale for Reduced Transaction Testing Was Not Documented in Accordance
      with DER’s Guidance on Sampling Practices ........................................................................11

FINDING .......................................................................................................................................11

CONCLUSION ..............................................................................................................................12

FHFA COMMENTS AND OIG RESPONSE ...............................................................................12

OBJECTIVE, SCOPE, AND METHODOLOGY .........................................................................13

APPENDIX: FHFA MANAGEMENT RESPONSE ....................................................................15

ADDITIONAL INFORMATION AND COPIES .........................................................................16




                                            OIG • AUD-2018-005 • March 13, 2018                                                               4
ABBREVIATIONS .......................................................................

CU                 Collateral Underwriter

DER                Division of Enterprise Regulation

EIC                Examiner-in-Charge

EPB                Examination Practices Bulletin

Enterprises        Fannie Mae and Freddie Mac

Fannie Mae         Federal National Mortgage Association

FHFA               Federal Housing Finance Agency

Freddie Mac        Federal Home Loan Mortgage Corporation

HERA               Housing and Economic Recovery Act of 2008

LQC                Loan Quality Center

New framework      Representation and Warranty Framework

OIG                Federal Housing Finance Agency Office of Inspector General

OPB                Operating Procedures Bulletin

QC                 Quality Control

TAU                Trusted Appraisal and Underwriting




                         OIG • AUD-2018-005 • March 13, 2018                        5
BACKGROUND ..........................................................................

DER Supervisory Process

Created by Congress in 2008, FHFA is charged by HERA with, among other things, the
supervision of the Enterprises. Its mission as a federal financial regulator includes ensuring
the safety and soundness of the Enterprises so that they serve as a reliable source of liquidity
and funding for housing finance and community investment. FHFA exercises its supervision
of the Enterprises through DER. Like other federal financial regulators, FHFA maintains that
it uses a risk-based approach to carry out its supervisory activities.

DER executes supervisory activities, which consist of ongoing monitoring and targeted
examinations conducted in accordance with a supervisory plan. The FHFA Examination
Manual explains that targeted examinations are a critical component of supervision and will
be undertaken, as needed, based on risk. The purpose of targeted examinations is to allow for
a deep or comprehensive assessment of the area under review.

According to DER’s Operating Procedures Bulletin (OPB) 2013-DER-OPB-04, DER
Supervisory Activities (September 19, 2013), targeted examinations are designed to assess a
particular area, product, risk, or activity of the Enterprise and by definition are narrow in
scope. This OPB directs DER examiners to conduct detailed analysis and testing in order to
develop specific conclusions. With regard to testing, FHFA issued Examination Practice
Bulletin (EPB), EPB 2014-01, Sampling Practices in Examinations (February 2014). The
stated purpose of the EPB is to provide examiners with guidance on sampling practices to aid
them in the performance of mandatory testing in accordance with FHFA examination work
programs.

The FHFA Examination Manual and DER’s OPBs define expectations and approval
requirements for examiner workpapers. According to 2013-DER-OPB-04 and
2014-DER-OPB-01, Guidelines for Preparing Supervisory Products and Examination
Workpapers (January 27, 2014), required documents for targeted examinations are:
   •   Procedures Document – sets forth the steps performed to achieve the objective of the
       supervisory activity, and provides the official agency record of evidence to support the
       execution of the targeted examination. The Procedures Document must be approved
       by the Lead Examiner and Examination Manager.
   •   Request Letter – announces the objective and scope of the targeted examination to the
       Enterprise, requests the Enterprise to schedule a kickoff and subsequent meetings with
       management, and requests timely delivery of documentation to be produced by the
       Enterprise. The Request Letter must be approved by the Lead Examiner, Examination
       Manager, and Examiner-in-Charge (EIC).


                              OIG • AUD-2018-005 • March 13, 2018                                  6
    •    Meeting Notes – document the periodic status meetings with management that are
         conducted throughout the targeted examination to ensure that management is kept
         apprised of any preliminary findings or emerging concerns. Meeting Notes must be
         approved by the Lead Examiner and Examination Manager.
    •    Analysis Memorandum – constitutes the main work product from the supervisory
         activity that supports the Conclusion Letter, and provides the complete record of the
         work performed, findings, and conclusions. The Analysis Memorandum should
         include hyperlinks or references to supporting workpapers and must be approved by
         the Lead Examiner, Examination Manager, and EIC. 1
    •    Conclusion Letter – communicates conclusions from targeted examinations to the
         Enterprise. Conclusion Letters must be approved by the Lead Examiner, Examination
         Manager, EIC, and DER Deputy Director.

The FHFA Examination Manual directs that examiner workpapers, on which the Analysis
Memorandum is based, must be prepared in sufficient detail to provide a clear understanding of
the examination work performed. Further, 2014-DER-OPB-01 directs DER examiners to prepare
workpapers with sufficient detail and explanation so that they can provide a third-party with a
clear understanding of the examination work performed, the examination findings, conclusions,
and ratings reached, and any implications of the findings, conclusions, and ratings.

The New Framework Sought to Provide Greater Certainty to the Lender, Shifting Some
Risk to the Enterprises

Implementation of the new framework shifted some risk of non-compliance with
representations and warranties from the lenders to the Enterprises. As a result, the
Enterprises’ quality control (QC) programs 2 became increasingly important to mitigate
origination quality risk and credit risk since, for loans covered by the new framework, the
Enterprises would no longer be able to seek repurchase from a lender for the life of the loan
as a result of some representation and warranty breaches. For loans acquired under the new
framework, both Enterprises represented that they would conduct most quality control
reviews within 30 to 120 days after delivery of the loan to assess whether specific




1
 2014-DER-OPB-01 directs that Examination Managers must ensure examination findings are fully supported
by workpapers and hyperlinked or referenced in the Analysis Memorandum.
2
  A QC program defines the standards for loan quality, establishes processes designed to achieve those
standards, and mitigates risks associated with the origination processes. A QC program includes a documented
QC plan that outlines requirements for validating that loans are originated in accordance with the Enterprise’s
established policies and procedures.




                                   OIG • AUD-2018-005 • March 13, 2018                                            7
representations and warranties were satisfied. 3 In addition, the Enterprises stated that they
were going to use new technologies and data gathering tools to identify loans that were not
originated in accordance with applicable underwriting and eligibility requirements. Fannie
Mae implemented new tools to enhance the focus of its post-purchase quality control reviews
of performing loans. For example, the Trusted Appraisal and Underwriting (TAU) tool was
developed to assist Fannie Mae in identifying underwriting defects by looking for
discrepancies, incentives, and trends across many different internal and external data sources,
and the Collateral Underwriter (CU) tool was developed to assist Fannie Mae in evaluating
the quality of appraisals submitted with loan applications.

Prior OIG Work on the New Framework

A 2014 OIG audit found that FHFA mandated the new framework despite significant unresolved
operational risks to the Enterprises. The audit also found that neither Enterprise had implemented
the processes, procedures, nor systems needed to operate within the new framework before it
went into effect in 2013. The 2014 audit report made two recommendations to FHFA, of which
one is relevant to the scope of this audit:

        [A]ssess the current state of the Enterprises’ critical risk assessment tools,
        representations and warranties tracking systems, and any other systems, processes, or
        infrastructure to determine whether the Enterprises are in a position to minimize
        financial risk that may result from the new framework. The results of this assessment
        should document any areas of identified risk, planned actions, and corresponding
        timelines to mitigate each area of identified risk. Further, this assessment should
        provide an estimate of when each Enterprise will be reasonably equipped to work
        safely and soundly within the new framework. 4

In its written response, FHFA partially agreed with this recommendation, stating that:

        FHFA examination staff will continue to examine and review the Enterprises’
        loan purchase operations, including those affected by the representations and
        warranties framework. DER examination staff will request the Enterprises to
        provide information about operational changes needed at each Enterprise for


3
  For example, Fannie Mae QC reviews assess representations and warranties related to the underwriting of the
borrower, including the seller’s assessment of borrower’s loan terms, credit history employment, income,
assets, and other information used for qualifying the borrower for the mortgage; the assessment also includes
the underwriting of the mortgaged premises, which is the analysis of the description and valuation of the
mortgaged premises to determine its adequacy as collateral for the mortgage.
4
 See OIG, FHFA’s Representation and Warranty Framework (Sept. 17, 2014) (AUD-2014-016) (online at
www.fhfaoig.gov/Content/Files/AUD-2014-016.pdf).




                                  OIG • AUD-2018-005 • March 13, 2018                                           8
        safe and sound implementation of the new framework, and DER will take this
        information into account in developing its examination plans for 2015.

More recently, a September 2017 OIG audit assessed (1) whether DER’s planned supervisory
activities relating to Fannie Mae’s implementation of the new framework for the 2015 and
2016 examination cycles could be tracked to its risk assessments and supervisory strategies
and (2) whether DER executed these planned supervisory activities during the 2015 and 2016
examination cycles. 5 As detailed in the 2017 audit report, we found that DER identified three
risks relating to Fannie Mae’s implementation of the new framework for the 2015
examination cycle: a risk associated with actions taken to



         We found that DER planned and performed one targeted examination, entitled
Single-Family Loan Quality Center. We also found that DER reported on the results of that
targeted examination in the 2015 report of examination before the supervisory activity had
been subjected to an internal quality control review, as required by FHFA and DER. DER did
not identify risks associated with the new framework as a specific focus for the 2016
examination cycle and did not perform any new framework-related supervisory activities
during the examination cycle.

This audit follows on that work. In this audit, we assessed whether DER completed the
planned procedures and sufficiently supported its conclusions for that 2015 targeted
examination.


FACTS AND ANALYSIS ...............................................................

Required Documents Were Prepared and Approved for the 2015 Loan Quality Center
Targeted Examination

As discussed above, DER performed a targeted examination of the LQC at Fannie Mae during
the 2015 examination cycle. According to the targeted examination documents, the objective of
the targeted examination was “to assess the                                    employed by the
              business unit.” The scope statement in these documents specified that the
examination would focus on
           with Fannie Mae's                operations. In addition, the examination was to


5
  See OIG, FHFA’s 2015 Report of Examination to Fannie Mae Failed to Follow FHFA’s Standards Because
it Reported on an Incomplete Targeted Examination of the Enterprise’s New Representation and Warranty
Framework (Sept. 22, 2017) (AUD-2017-008) (online at https://www.fhfaoig.gov/Content/Files/AUD-2017-
008).



                                OIG • AUD-2018-005 • March 13, 2018                                     9
include a review of the                            that were needed to implement the
with a particular focus on Fannie Mae's
Required targeted examination documents – the Request Letter, Procedures Document, Meeting
Notes, Analysis Memorandum, and Conclusion Letter – were completed, reviewed, and
approved by the appropriate DER officials in accordance with the requirements of
2013-DER-OPB-04. Additionally, our review of the Conclusion Letter showed that DER’s
conclusion that “FHFA did not identify
               was consistent with conclusions detailed in the Analysis Memorandum. DER
performed its required quality control review of the targeted examination’s workpapers prior to
issuance of the Conclusion Letter. No exceptions to DER examination standards and FHFA
guidance for document preparation and management were identified in this audit. As we reported
in our September 2017 audit, the results of this targeted examination were included in the Report
of Examination for the 2015 examination cycle before being subject to a required independent
quality control review. 6

Workpapers Supported DER’s Conclusions Regarding the
for This Targeted Examination

The Procedures Document for this targeted examination was constructed using a combination of
work steps selected from FHFA’s Single-Family Mortgage Underwriting and Acquisition (Field
Test version) examination module and work steps developed by the examiners. The Procedures
Document also included a work step for a transaction test, as required in the examination
module. 7
In the Analysis Memorandum, DER concluded that:
    •   Fannie Mae’s

        Fannie Mae standards and requirements,
    •   Fannie Mae has

    •




6
  For a detailed discussion about this shortcoming, see OIG, FHFA’s 2015 Report of Examination to Fannie
Mae Failed to Follow FHFA’s Standards Because it Reported on an Incomplete Targeted Examination of the
Enterprise’s New Representation and Warranty Framework (Sept. 22, 2017) (AUD-2017-008) (online at
https://www.fhfaoig.gov/Content/Files/AUD-2017-008).
7
  The workprogram that accompanies the Single-Family Mortgage Underwriting and Acquisitions examination
module (Field Test version) states that: “Transaction testing…is mandatory and must evidence sufficient work
steps to support the findings and conclusions from this examination module.”



                                  OIG • AUD-2018-005 • March 13, 2018                                          10
   •


The documentation supporting these conclusions included notes documenting meetings with and
presentations by Fannie Mae management describing quality control processes and systems,
copies of Fannie Mae’s LQC policies and procedures, copies of LQC governance and
management reports, descriptions of DER’s testing of repurchase requests, internal audit reports
related to this topic, and analyses. DER examiners also performed a transaction test to determine
whether                        to Fannie Mae


Rationale for Reduced Transaction Testing Was Not Documented in Accordance with
DER’s Guidance on Sampling Practices

As our audit found, DER examiners performed transaction testing designed to determine whether

                          Based on that testing, DER concluded that the files reviewed
                               to perform a review to determine
                                 with [Fannie Mae]
According to the Analysis Memorandum, examiners obtained
and                was reviewed by the                      for certain criteria. However, in the
Procedures Document, DER documented that it
           When questioned about this discrepancy, a DER official explained that the examiners
determined that the review                 constituted a significant representation of the entire
population. EPB 2014-01 states, “Examiners may expand or reduce sampling activities as
appropriate based on the sampling results and the need to support examination conclusions and
findings; however, the examiner should include in the examination workpapers the reasons for
expanding or reducing sampling activities.” This explanation was not documented in the
supporting workpapers, as directed by EPB 2014-01.


FINDING ...................................................................................

DER’s EPB 2014-01 directs that examiners include in the examination workpapers the reasons
for expanding or reducing sampling activities. For this targeted examination, we found that DER
                                           from Fannie Mae to conduct a transaction test.
Ultimately, the examiners                                   because they felt that the tested
were representative of the entire population. This rationale for reducing the sampling activity
was not documented in the targeted examination workpapers, as directed by EPB 2014-01. As a
result, the workpapers did not provide a third party with a clear understanding of the examination
work performed.




                             OIG • AUD-2018-005 • March 13, 2018                               11
CONCLUSION ............................................................................

We found that DER performed its planned procedures and prepared the required examination
documents for the 2015 targeted examination entitled Single-Family Loan Quality Center. The
conclusions that DER presented in the Conclusion Letter for this targeted examination were
consistent with those detailed in the targeted examination workpapers. Further, the targeted
examination workpapers sufficiently supported DER’s conclusions regarding the
              We found, however, that DER examiners did not document the reason(s) that the
sample size was reduced for a transaction test of          , as directed by FHFA guidance.
In a companion audit issued today on DER’s execution of a new framework-related targeted
examination of Freddie Mac, we found the examination workpapers were not sufficiently
documented because they did not reference certain work that was relied upon to support DER’s
conclusions on that targeted examination. 8 In that audit report, we recommended that FHFA
reinforce, in examiner training, the need to prepare workpapers for targeted examinations with
sufficient detail and clarity to provide a third party with a clear understanding of the examination
work performed; the examination findings, conclusions, and ratings reached; and any
implications of the findings, conclusions, and ratings. We are not making a recommendation for
this audit because we only found a lapse in examiner adherence to FHFA and DER workpaper
directives for a single procedure that did not inhibit a third party’s ability to understand the
conclusions reached for the targeted examination that was the scope of this audit. We counsel
that the sufficiency of examination workpapers—to provide a third-party with a clear
understanding of the examination work performed, the examination findings, conclusions, and
ratings reached, and any implications of the findings, conclusions, and ratings—is a matter
needing continued and continual DER examiner and management attention.


FHFA COMMENTS AND OIG RESPONSE .....................................

We provided FHFA an opportunity to respond to a draft of this audit report. FHFA provided
technical comments on the draft report, which we incorporated as appropriate. In its management
response, which is included in the Appendix to this report, FHFA acknowledged our report.




8
 See OIG, FHFA Completed its Planned Procedures for a 2016 Representation and Warranty Framework
Targeted Examination at Freddie Mac, but the Supporting Workpapers Did Not Sufficiently Document the
Examination Work (March 13, 2018) (AUD-2018-006) (online at
www.fhfaoig.gov/reports/auditsandevaluations).



                                 OIG • AUD-2018-005 • March 13, 2018                                   12
OBJECTIVE, SCOPE, AND METHODOLOGY .................................

We conducted this audit to assess whether DER completed the planned procedures and
sufficiently supported its conclusions for the 2015 targeted examination entitled Single-
Family Loan Quality Center.

To accomplish our objective, we reviewed the FHFA Examination Manual (December 2013)
and the related examination module, Single-Family Mortgage Underwriting and Acquisitions;
as well as guidance issued by FHFA and DER related to conduct of and supervisory products
for targeted examinations. In addition, we reviewed Fannie Mae Selling Guides and Lender
Letters related to the new framework.

Specifically, for Fannie Mae, we:

   •   Reviewed DER’s documentation for the 2015 Single-Family Loan Quality Center
       targeted examination, including the Procedures Document, Request Letter, Meeting
       Notes, Analysis Memorandum, Conclusion Letter, and supporting workpapers to see
       that the required documents were completed and approved in accordance with FHFA
       and DER guidance, and supported the conclusions reached for the targeted
       examination.

   •   Interviewed DER personnel to gain an understanding of the supervisory activities
       planned and performed to supervise Fannie Mae’s implementation of the new
       framework.

   •   Reviewed DER’s supervisory work products to determine the extent of planned and
       future examinations as it pertains to the automated systems under review in the audit.

   •   Reviewed the following Fannie Mae Selling Guide Announcements:

           o SEL-2012-08, New Lender Selling Representations and Warranties
             Framework (September 11, 2012)

           o SEL-2014-05, Lender Selling Representations and Warranties Framework
             Updates (May 12, 2014)

           o SEL-2014-16, Selling Guide Updates (December 16, 2014)

           o SEL-2015-11, Selling Representations and Warranties Framework –
             Origination Defects and Remedies (October 7, 2015)




                              OIG • AUD-2018-005 • March 13, 2018                               13
           o SEL-2016-01, Selling Representations and Warranties Framework –
             Independent Dispute Resolution (February 2, 2016)

We conducted this performance audit from September 2017 through March 2018 in
accordance with generally accepted government auditing standards. Those standards require
that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for the findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings and conclusions based
on our audit objectives.




                             OIG • AUD-2018-005 • March 13, 2018                                14
APPENDIX: FHFA MANAGEMENT RESPONSE .............................




                   OIG • AUD-2018-005 • March 13, 2018        15
ADDITIONAL INFORMATION AND COPIES .................................


For additional copies of this report:

   •   Call: 202-730-0880

   •   Fax: 202-318-0239

   •   Visit: www.fhfaoig.gov



To report potential fraud, waste, abuse, mismanagement, or any other kind of criminal or
noncriminal misconduct relative to FHFA’s programs or operations:

   •   Call: 1-800-793-7724

   •   Fax: 202-318-0358

   •   Visit: www.fhfaoig.gov/ReportFraud

   •   Write:

                FHFA Office of Inspector General
                Attn: Office of Investigations – Hotline
                400 Seventh Street SW
                Washington, DC 20219




                               OIG • AUD-2018-005 • March 13, 2018                         16