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FHFA Has Fraud on Its Mind

By Christy W. Hancock, Robin-Renee Keys & Sarah Atkinson on April 21, 2025
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FHFA Has Fraud on Its Mind

In recent days, Federal Housing Finance Agency (FHFA) Director Bill Pulte has made it clear that he believes fraud is a rampant problem at FHFA. In a stream of related activities, Pulte has called on the public to report fraud via email and a new Hotline, terminated over 100 FHFA employees for alleged fraud, and taken aim at a political rival for alleged mortgage fraud.

Fraud Hotline Encourages Reporting of Fraud Concerns

On April 15, 2025, Pulte posted an invitation on X for any person to “Please submit any alleged criminal mortgage tips or mortgage fraud tips to FraudTips@fhfa.GOV.” This message coincides with FHFA’s new Hotline for Reporting Alleged Fraud, Waste, Abuse, or Mismanagement at Hotline | FHFA-OIG. The hotline website encourages federal employees and the public to “report information about those, whether inside or outside of the federal government, who waste, steal, or abuse government funds in connection with the Agency, Fannie Mae and Freddie Mac (the Enterprises), any of the Federal Home Loan Banks (FHLBanks), or the FHLBanks’ Office of Finance, or about mismanagement within FHFA.” The Hotline website is now seeking information on any of the following:

  • Possible waste, fraud, abuse, mismanagement, or other misconduct involving FHFA employees, programs, operations, contracts or subcontracts;
  • Possible violations of Federal laws, regulations, rules, or policies pertaining to FHFA or to any of the regulated entities; or
  • Possible unethical activities involving employees of FHFA or of the regulated entities.

This effort marks a significant step in Pulte’s broader campaign to foster transparency, accountability, and a culture of integrity across the federal housing finance system.

FHFA Cleans House

Following an internal investigation launched under Pulte’s anti-fraud campaign, Fannie Mae recently terminated over 100 employees for unethical behavior, including involvement in fraud. This internal investigation reflects Pulte’s zero-tolerance stance on fraud and commitment to restoring integrity at government-sponsored enterprises like Fannie Mae and Freddie Mac.

In a release by the Federal Housing Finance Agency on April 8, 2025, Pulte stressed that “there is no room for fraud, mortgage fraud, or any other deceitful act that can jeopardize the safety and soundness of the housing industry.” Further, Fannie Mae CEO Priscilla Almodovar thanked Pulte for “empowering of Fannie Mae to root out unethical conduct,” emphasizing that “we hold our employees to the highest standards, and we will continue to do so.”  

Although the agencies have not released further details about the terminations, Pulte reaffirmed his commitment to combating misconduct in a post on his personal X account, stating, “We are turning around Fannie Mae and Freddie Mac, slowly but surely.”

Referral of New York Attorney General Letitia James for Mortgage Fraud

As a part of Pulte’s crackdown on alleged mortgage fraud, he has referred New York Attorney General Letitia James for federal prosecution for her alleged mortgage fraud. Pulte alleges James “has, in multiple instances, falsified bank documents and property records to acquire government-backed assistance and loans and more favorable loan terms.” Director Pulte alleges that most recently, James committed fraud by claiming a Virginia home would be her primary residence in 2023, while James is the sitting Attorney General of New York. James’s office has maintained that the Virginia residence is the primary residence of her niece, with whom she purchased the property.

Pulte further alleges fraud connected to a home purchase in Brooklyn in 2001, where James used a loan that was only available to purchase four-unit properties to purchase an alleged five-unit property. However, popular real estate sites such as StreetEasy, Trulia, and Redfin have categorized the property as a four-unit building. 

Lastly, Pulte has alleged fraud in connection with a 1983 home purchase by James’s father, where the mortgage states James is her father’s wife instead of his daughter. It is unclear whether or not this was a clerical error in drafting the Mortgage or whether it was an intentional act by James and her father. While the criminal referral references the 2001 and 1983 purchases, any alleged fraud in connection with these purchases appears to be well beyond the statute of limitations.

James has initially responded that the allegations are “baseless.” She has said the “allegations are nothing more than a revenge tour” related to his civil fraud case against President Trump, which resulted in a $454 judgment from a New York Court in 2024, which he is currently appealing.

Expect Fraud Related Repurchases

Pulte’s interest in fraud is also likely to trigger new repurchase demands to the industry. One of the critical representations and warranties that lenders make when selling loans to the GSEs is that the loan meets all the requirements of the Lender Contract, including that it has not been obtained via misrepresentation or fraud. “Because the selling warranties are not limited to matters within a seller/servicer’s knowledge… the action or inaction (including misrepresentation or fraud) of the borrower, or a third party, as well as the action or inaction (including misrepresentation or fraud) of the seller/servicer will constitute the seller/servicer’s breach of a selling warranty.” Fannie Mae Guide A1-1-02, Representation and Warranty Requirements (08/16/2017), see also Freddie Mac Guide 1301.8 – Warranties and representations by the Seller (8/2/2023).

The GSEs have always maintained the ability to demand repurchase of any mortgage loans that do not meet the many qualifications of their Seller Guidelines. See Freddie Mac Guide 3602.2 – Repurchases (8/17/2016) and Fannie Mae Guide A1-3-02, Fannie Mae-Initiated Repurchases, Indemnifications, Make Whole Payment Requests and Deferred Payment Obligations (10/11/2023). During the Biden Administration, the industry experienced a sharp uptick in repurchase demands from the GSEs. As a November 2023 white paper from the Urban Institute noted, the “GSEs have become more aggressive, forcing more repurchases earlier in the life of the loan than was the case in earlier vintages. In the first few years of the mortgages’ life, there have been more repurchases for the 2018–22 origination years than there were in the 2005–08 origination years.” GSE Repurchase Activity and its Chilling Effect on the Market. Overall, the GSEs have been proactive about their repurchase rights both in recent years and prior to the Trump Administration.

With that background in mind, Pulte’s April 16, 2025, post on X that “FHFA, Fannie Mae, and Freddie Mac will be evaluating ways to ‘recall loans’ that have been obtained fraudulently” is not groundbreaking news, but it does emphasize the recent focus on fraud. Pulte’s use of “recall” instead of “repurchase” may relate to his homebuilding background, but the intent is the same. Apparently, neither Pulte nor the FHFA have responded to the National Mortgage News’ request for clarification on the post. However, some believe the X post may directly relate to the FHFA referral to the U.S. Attorney General regarding Attorney General James.

This renewed emphasis on enforcing repurchase rights—particularly in cases involving fraud—signals that lenders should prepare for heightened scrutiny and further increase in repurchase demands as the FHFA doubles down on accountability under Pulte’s leadership.

Going Forward

Taken together, these actions paint a clear picture: under Bill Pulte’s leadership, the FHFA is aggressively pivoting toward a hardline stance on fraud, ethics, and accountability. From employee terminations and public tip lines to high-profile referrals and the reinforcement of repurchase remedies, Pulte is sending a strong message that misconduct at any level—whether inside the agency, among its regulated entities, or even among political figures—will be met with swift and serious consequences. As the housing finance system braces for increased oversight, stakeholders should expect this aggressive posture to define the agency’s direction for the foreseeable future.

Photo of Christy W. Hancock Christy W. Hancock

Christy Hancock’s practice is dedicated to financial services regulatory compliance and litigation. Her work with mortgage servicing and financial institution clients has given her a broad base of knowledge regarding laws affecting the mortgage servicing business, including bankruptcy and foreclosure best practices, payment…

Christy Hancock’s practice is dedicated to financial services regulatory compliance and litigation. Her work with mortgage servicing and financial institution clients has given her a broad base of knowledge regarding laws affecting the mortgage servicing business, including bankruptcy and foreclosure best practices, payment application, correspondence requirements, allowable fees, loan modifications, escrow requirements, and property preservation. In recent years, the majority of her practice has focused on advising large financial institutions on bankruptcy-related regulatory matters and large-scale remediation projects.

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Photo of Robin-Renee Keys Robin-Renee Keys

Robin-Renee Keys is an associate in Bradley’s Banking and Financial Services Practice Group. Robin-Renee’s practice is focused on helping financial services clients navigate the regulatory and compliance issues most critical to their business. Robin-Renee’s compliance experience encompasses issues arising under the Fair Credit…

Robin-Renee Keys is an associate in Bradley’s Banking and Financial Services Practice Group. Robin-Renee’s practice is focused on helping financial services clients navigate the regulatory and compliance issues most critical to their business. Robin-Renee’s compliance experience encompasses issues arising under the Fair Credit Reporting Act (FCRA), the Fair Debt Collection Practices Act (FDCPA), Truth in Lending Act (TILA), and the Real Estate Settlement Procedures Act (RESPA), including the many regulations interpreting those statutes. She analyzes and advises on regulations issued by the Department of Housing and Urban Development (HUD), Office of the Comptroller of the Currency (OCC), the Consumer Financial Protection Bureau (CFPB), the Federal Trade Commission (FTC), and other regulatory bodies.

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Photo of Sarah Atkinson Sarah Atkinson

Sarah Atkinson is an associate in Bradley’s Banking and Financial Services Practice Group.

Read more about Sarah AtkinsonEmail
  • Posted in:
    Financial
  • Blog:
    Financial Services Perspectives
  • Organization:
    Bradley Arant Boult Cummings LLP
  • Article: View Original Source

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