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No. Recommendation Report Status EVL-2012-009-3 FHFA should ensure that supervisory policies are well-founded and coordinated and that the agency speaks with one voice by: • confirming its position or the agreement in writing as soon as practical if FHFA is going to take a position or believes it has come to an agreement with Freddie Mac regarding a particular investment product; and • ensuring that supervisory policies are based on the robust work of agency personnel and not reactions to media or other public scrutiny. FHFA’s Oversight of Freddie Mac’s Investment in Inverse Floaters Recommendation partially agreed to by FHFA; implementation of recommendation pending. EVL-2012-009-4 Prior to issuing any public statement, FHFA should exercise due diligence to ensure that statements accurately reflect all relevant facts. FHFA’s Oversight of Freddie Mac’s Investment in Inverse Floaters Recommendation agreed to by FHFA; implementation of recommendation pending. EVL-2012-008-1 FHFA should consider revising FHFA’s delegation of authorities to require FHFA approval of unusual, high-cost, new initiatives, like the High Touch Servicing Program. Evaluation of FHFA’s Oversight of Fannie Mae’s Transfer of Mortgage Servicing Rights from Bank of America to High Touch Servicers Recommendation agreed to by FHFA; implementation of recommendation pending. EVL-2012-008-2 FHFA should ensure that Fannie Mae does not have to pay a premium to transfer inadequately performing portfolios. Evaluation of FHFA’s Oversight of Fannie Mae’s Transfer of Mortgage Servicing Rights from Bank of America to High Touch Servicers Recommendation agreed to by FHFA; implementation of recommendation pending. Semiannual Report to the Congress • April 1, 2013–September 30, 2013 99
No. Recommendation Report Status EVL-2012-008-3 Consistent with the control issues found in Fannie Mae’s internal audit report on the High Touch Servicing Program, FHFA should ensure that Fannie Mae applies additional scrutiny and rigor to pricing significant MSR transactions. Specifically, FHFA should: • consider requiring Fannie Mae to assess the valuation methods of multiple MSR valuators in order to discern best practices; and • consider requiring two independent valuations in the case of larger MSR transactions (at a threshold to be determined by FHFA). Evaluation of FHFA’s Oversight of Fannie Mae’s Transfer of Mortgage Servicing Rights from Bank of America to High Touch Servicers Recommendation agreed to by FHFA; implementation of recommendation pending. EVL-2012-008-4 FHFA should assess the efficacy of the program and direct any necessary modifications. As the portfolios purchased under the program approach the five-year mark, FHFA should review both the underlying assumptions and the performance criteria for the High Touch Servicing Program. Evaluation of FHFA’s Oversight of Fannie Mae’s Transfer of Mortgage Servicing Rights from Bank of America to High Touch Servicers Recommendation agreed to by FHFA; implementation of recommendation pending. EVL-2012-007-1 FHFA and Freddie Mac should continue to carry out the loan review and related reforms they have initiated since OIG’s original report on the Bank of America settlement with Freddie Mac was issued. Follow-up on Freddie Mac’s Loan Repurchase Process Recommendation agreed to by FHFA; implementation of recommendation pending. EVL-2012-005-1 FHFA should continue its ongoing horizontal review of unsecured credit practices at the FHLBanks by: • following up on any potential evidence of violations of the existing regulatory limits and taking supervisory and enforcement actions as warranted; and FHFA’s Oversight of the Federal Home Loan Banks’ Unsecured Credit Risk Management Practices Closed—Final action taken by FHFA. • determining the extent to which inadequate systems and controls may compromise the FHLBanks’ capacity to comply with regulatory limits and taking any supervisory actions necessary to correct such deficiencies as warranted. 100 Federal Housing Finance Agency Office of Inspector General
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Federal Housing Finance Agency Offi
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Section 3: Lessons for Housing Fina
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OIG’s Accomplishments from 2010 t
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A Message from the Acting Inspector
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insures mortgages against credit lo
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Semiannual Report to the Congress
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in a number of criminal and civil i
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Figure 3. Scoring of Investor Quali
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and provide for financial consequen
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Figure 5. Agreements Between Fannie
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2010 to 2012, but the attrition rat
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Figure 8. Estimated Enterprise Aggr
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operations that pose the greatest r
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poor financial condition, Appalachi
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fraud and wire fraud involving a fi
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This was a joint investigation with
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y falsified, forged, and altered do
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Short Sale Schemes A short sale occ
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This was a joint investigation with
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at Appalachian concealed past due l
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indemnification payments that OIG p
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the SEC, and others. In July 2013,
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Figure 10. Overview of the Enterpri
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Figure 12. Enterprises’ Annual Ne
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Figure 14. Home Price Index 2011 Th
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educe the principal balance of Trea
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Figure 17. FHLBanks’ Net Income f
Page 56 and 57: multifamily housing lending busines
Page 58 and 59: The bill would replace the enterpri
Page 60 and 61: mortgage credit. For its part, the
Page 62 and 63: Figure 20. Reform Models and Reform
Page 64 and 65: Multifamily We have also found indi
Page 66 and 67: Based on recent history, a reformed
Page 68 and 69: Figure 26. The Mortgage Servicing P
Page 70 and 71: Even though the FHFA senior examine
Page 72 and 73: assistance to homeowners and to use
Page 74 and 75: positive NPV, then the servicer is
Page 76 and 77: Siloed Practices: Harmonizing Busin
Page 78 and 79: Semiannual Report to the Congress
Page 80 and 81: overseen by FHFA. As conservator, F
Page 82 and 83: Interest Rate Swap: An interest rat
Page 84 and 85: References Federal Deposit Insuranc
Page 86 and 87: Department of the Treasury Financia
Page 88 and 89: Acronyms and Abbreviations Agency A
Page 92 and 93: Figure 29. Summary of OIG Recommend
Page 94 and 95: No. Recommendation Report Status AU
Page 104 and 105: No. Recommendation Report Status EV
Page 108 and 109: No. Recommendation Report Status EV
Page 114 and 115: Audit and Evaluation Reports with R
Page 116 and 117: Appendix D: OIG Reports See www.fhf
Page 118 and 119: Appendix F: Description of OIG Offi
Page 120 and 121: Strategic Goal 2—Operating with I
Page 122 and 123: Figure 17. Federal Home Loan Banks
Page 126 and 127: 15 Federal Housing Finance Agency,
Page 128 and 129: 33 Fannie Mae, “Multifamily Busin
Page 130 and 131: Federal Home Loan Banks Office of F
Page 132 and 133: to FHFA Scorecard Directive, at 48,
Page 134 and 135: it is preferable to limit our discu
Page 136 and 137: Position in the Housing Finance Sys
Page 138 and 139: 144 Fannie Mae, “Comparison of Mu
Page 140 and 141: 157 Id., “Mortgage Servicing,”
Page 142 and 143: 184 Federal Housing Finance Agency,
Page 144 and 145: Transparency and Certainty for Lend
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