NCRC and Fintechs Urge Federal Regulators to Use AI to Detect and Eliminate Lending Discrimination

 

The National Community Reinvestment Coalition (NCRC) and a group of financial technology firms submitted a joint letter urging regulators issue clear guidelines to lenders on how the new AI fair lending tools could better evaluate disparities in lending. The letter to the Consumer Financial Protection Bureau (CFPB) and Federal Housing Finance Agency (FHFA) - signed by NCRC, Zest AI, Upstart, Stratyfy, and FairPlay - was issued in response to the White House’s Executive Order on AI in October, 2023.

Some lenders have not adopted these newer tools for underwriting analysis because they believe they can remain compliant with existing fair lending laws despite evidence that suggests older scoring models continue to contribute to systemic discrimination. Newer fair lending tools can allow lenders to conduct searches for new underwriting models that perform as well as older scoring models, while also mitigating the risk of discrimination in their analysis of an LMI credit applicant.

From the companies’ perspective, the power of the new AI tools can help lenders comply with regulations and improve their ability to expand credit access to applicants who have traditionally been underserved or considered too risky by old underwriting models.

The key recommendations of the letter include:

1. Don’t wait for perfect information to act. AI will continue to rapidly evolve. Supervisory highlights should be used by regulators to highlight best practices within the industry.
2. Provide written guidance on activity that triggers fair lending oversight. The CFPB should provide clearer guidelines on the conditions that would require a lender to engage in a Less Discriminatory Alternative (LDA) search, as well as the frequency with which such searches will be conducted.
3. Clarify that fair lending applies not only to how applicants are treated, but also how they are selected. Evaluating the creditworthiness of applicants can happen at the earliest stages of the lending process, including during marketing campaign planning. AI tools that can more comprehensively assess the risk of an applicant should be adopted earlier and favored over older models and tools.
4. The FHFA should continue to build upon its 2022 AI Advisory Opinions. The prior advisory opinions offered AI-specific guidance to the GSEs based on select use cases with potential to improve housing finance for consumers.
5. The CFPB should assert that fair lending compliance should be as high a priority as all other parts of the lending process. For companies using AI in credit decisioning, the CFPB should make clear the usage of outdated tools is not sufficient to remain compliant with fair lending laws.
6. Supervisory examination and training should address routine review of financial institutions’ model testing protocols and results. Fair lending examinations should also include reviews of the models used, testing protocols and positive assessment of LDA searches. Data concerning the efficacy of tools and practices should be shared in a forum with regulators and policymakers.

Photo by BoliviaInteligente on Unsplash

Read the September 30, 2024 NCRC article.

The Fair Lending Report of the Consumer Financial Protection Bureau (CFPB) for 2023 is Released

 

The June 2024 Fair Lending Report describes CFPB's fair lending activities in enforcement, guidance and rulemaking, interagency coordination, and outreach and activities for calendar year 2023. It is submitted to Congress. The fair lending activities of the CFPB are summarized here.

Fair Lending Activities

In 2023 the CFPB focused much of its fair lending supervision efforts on: mortgage origination (including redlining, property valuation bias, and HMDA and Regulation C compliance); credit card marketing and the use of alternative data in digital marketing; and on the use of automated systems and models, sometimes marketed as artificial intelligence (AI) and machine learning models, in credit card
originations.

The CFPB’s 2023 mortgage origination work continued to focus on redlining (intentional discrimination against applicants and prospective applicants living or seeking credit in minority neighborhoods, including by discouragement). The CFPB’s mortgage work also included assessing potential discrimination in mortgage underwriting and pricing processes, including assessing whether there were disparities in application, underwriting, and pricing processes, and whether there were weaknesses in fair lending-related compliance management systems. The CFPB’s mortgage origination work also included reviewing residential property appraisal service providers to identify risks that may arise due to potential discrimination or bias as well as HMDA data integrity and validation reviews.

The CFPB continued to assess whether lenders complied with the adverse action notice requirements of the Equal Credit Opportunity Act (ECOA) and Regulation B and evaluated whether lenders maintain policies and procedures that unlawfully exclude property on the basis of geography in underwriting decisions, unlawfully exclude certain types of income, and treat criminal history in an unlawful manner. 

Fair Lending Enforcement

In fair lending enforcement, the CFPB:

(1) Did two ECOA-related public enforcement actions, relating to discrimination on the basis of race and national origin, one against Citibank N.A. (Citibank) and the other against Colony Ridge Development, LLC, and Colony Ridge BV, LLC, and affiliate mortgage company Colony Ridge Land, LLC (collectively, the Colony Ridge defendants).

(2) Took public enforcement actions against two repeat offenders for reporting false, erroneous, or incorrect HMDA data: Freedom Mortgage Corporation (Freedom Mortgage) and Bank of America, N.A.

(3) On October 10, 2023, the CFPB filed a lawsuit against Freedom Mortgage, a residential

mortgage loan originator and servicer, alleging that it submitted legally-required mortgage loan

data that were riddled with errors.

(4) On November 28, 2023, the CFPB issued an order against Bank of America for routinely

submitting falsified HMDA data.5 The CFPB found that between 2016 and late 2020, hundreds

of Bank of America’s loan officers failed to ask applicants for their race, ethnicity, and sex, as

required by law, and instead falsely recorded that the applicants chose not to provide this

information.

(5) In 2023, the CFPB issued several fair lending-related Matters Requiring Attention and entered
Memoranda of Understanding directing entities to take corrective actions that the CFPB will
monitor through follow-up supervisory actions. In these communications, the CFPB directed
mortgage lenders to correct violations relating to redlining, including by institutions providing
consumer remediation designed to spur lending in redlined areas.

Read the full June 2024 CFPB report.

There will be four focused sessions on changes to the Community Reinvestment Act (CRA) at NCRC's April 3-4 2024 Just Economy Conference.

 

The National Community Reinvestment Coalition (NCRC) will be hosting four focused sessions on changes to the Community Reinvestment Act (CRA) at its 2024 Just Economy Conference. The CRA requires banks to lend in the communities where they do business. The federal regulators overseeing CRA announced late in 2023 a much-needed overhaul of this important economic justice law. These sessions will treat the changes as well as the implications for community development and equity.

Register Now

The sessions are:   The New CRA 101 (ROUND 1) This session covers the updated CRA, which encourages financial institutions to meet the credit needs of low- and moderate-income (LMI) neighborhoods and requires federal banking agencies to assess the record of meeting these standards and evaluate their efforts. We will explore how CRA can be used to increase affordable housing and small business reinvestment in your communities, including crucial updates to the rule announced in late 2023.    The New CRA 101 (ROUND 2) Addressing the Climate Crisis through CRA and federal funding Climate change is increasing the frequency and severity of storms, heat waves, fires and other weather-related disasters, with communities of color and low-income households the most affected. CRA’s definition of community development was recently updated to encourage banks to finance weather resiliency. This session will cover climate/weather resiliency projects and priorities, including how best to work with communities to prevent bluelining, a trend where financial institutions withdraw services or increase costs due to climate change.    What's Next With The CRA Final Rule This session will focus on what's coming next with CRA reform and upcoming opportunities to further shape the development of the new CRA rule. Speakers will be covering topics including: developing a statistical model that identifies markets where all banks are underperforming, best practices for reviewing the impact of community development on neighborhoods, and how the regulators can be proactive in preventing a decline in critical investments.   State CRA And Non-Banks Community advocates, along with state and local elected officials, are increasingly pushing for state CRA laws that bring in more resources and fix gaps in the federal CRA rules, especially since more and more lending is done by institutions not covered by federal CRA. This session will explore how state CRA laws include a review of credit unions and mortgage companies' loans and investments in underserved people and neighborhoods, in addition to banks.    Register now.

 Fair Lending News:

CFPB Releases 2022 Fair Lending Annual Report to Congress

On June 26, 2023, the Consumer Finance Protection Bureau(CFPB) released its Fair Lending Annual Report to Congress, describing its fair lending activities in enforcement and supervision; guidance and rulemaking; interagency coordination; and outreach and education for calendar year 2022.

In 2022, the CFPB’s fair lending work centered on the consumers and communities most affected by unlawful discrimination:

• Working with our federal and state partners to address redlining as well as confronting deep-seated discrimination in the home appraisal industry. 
• The CFPB also released several reports shining a light on factors that may influence fair access to credit, including how medical debt affects tens of millions of consumers’ credit profiles, how people in under-resourced rural areas struggle to access financial services, and the challenges faced by justice-involved individuals and families.
• We also issued several rules and guidance documents reaffirming the importance and applicability of fair lending protections for prospective applicants, applicants for credit, and existing account holders. Through our enforcement and examination activity, interpretive rules and advisory opinions, circulars, and other tools, we continue to make clear that fair lending must be a top priority for all financial institutions.

The Fair Lending Annual Report to Congress fulfills the CFPB’s statutory responsibility to, among other things, report annually to Congress on public enforcement actions taken by other agencies with administrative enforcement responsibilities under the Equal Credit Opportunity Act (ECOA), and assessments of the extent to which compliance with ECOA has been achieved. It also fulfills the statutory requirement that the CFPB, in consultation with HUD, report annually on the utility of the Home Mortgage Disclosure Act’s requirement that covered lenders itemize certain mortgage loan data.

Through 2023 and beyond, the CFPB will continue to stand up for those consumers and small businesses who are the least resourced to fight back against exploitation.

As noted in the Future of Fair Lending section at the end of the Report, we are focused especially on the increased use of advanced and emerging technologies in financial services. Consumers and small businesses are not well-resourced to fight back against—and may not even know they are subject to—algorithmic bias, digital surveillance and data harvesting, dark patterns, and advanced technologies that are black boxes. The CFPB has increased its expertise in data science and analytics to ensure that we can identify fair lending violations at each stage of the credit lifecycle. And we will continue to take a whole-of-government approach to protect consumers from harmful uses of automated systems marketed as artificial intelligence. As the CFPB reiterated in conjunction with the release of our joint statement with the Department of Justice, Federal Trade Commission, and U.S. Equal Employment Opportunity Commission, we will hold creditors and service providers accountable for fully complying with fair lending and other federal consumer financial laws, regardless of the technology they choose to use.

The CFPB also continues to fight against bias in home appraisals and redlining. Families and entire communities are harmed by biased, inaccurate appraisals, as well as geographic discrimination, or redlining. Whether it takes the form of excluding neighborhoods with certain demographics from mainstream credit or targeting them with predatory products, the CFPB is combatting these unlawful practices to achieve meaningfully restorative outcomes for the affected consumers and communities.

The CFPB remains committed to protecting individuals, small businesses, and communities from discrimination, holding institutional and individual bad actors accountable, and ensuring robust and comprehensive remedies for violations of the laws under our jurisdiction. In the years to come, we look forward to advancing our work to ensure a fair, equitable, and nondiscriminatory credit market, with equal economic opportunity for all consumers and their communities.

 

HUD Charges New York Corporation and Associated Entities for Targeting Black Caribbean Homeowners in Fraudulent Mortgage Scam

HUD has charged multiple entities and individuals related to the Homeowner Assistance Services of New York (HASNY) with housing discrimination for perpetrating a scheme to deceive distressed homeowners into forfeiting title to their homes. HUD’s charge alleges that HASNY – plus six individuals, Springfield Realty of New York, Inc., Martin Development and Management, LLC, Launch Development, LLC, 272 Milford Street, LLC, Advill Capital, LLC, and Petermark II, LLC - targeted New York City homeowners in violation of the Fair Housing Act. Read the Charge. 

The Charge, filed on behalf of seven homeowners, alleges that HASNY and its associates targeted the homeowners for fraudulent mortgage and foreclosure prevention assistance by filing illegitimate liens and using telemarketing to convince homeowners to engage with HASNY for refinance assistance. After the homeowners accepted their offer of assistance, they used false promises of legal assistance, reassurances, and outright lies to convince the homeowners to sign documents that unknowingly sold their homes to Martin Development, LLC and Launch Development, LLC, which resulted for most forced them to vacate their homes. HASNY’s actions were disproportionately concentrated in neighborhoods which had a high majority of persons of color, especially Blacks and of Caribbean descent. They also used “affinity marketing” to gain the trust of elderly, vulnerable, and distressed homeowners by having telemarketers use their shared national origin and cultural practices to build trust with the homeowners. 

The U.S. Department of Justice previously criminally charged 3 of the men, as well as several other HASNY employees, with bank and wire fraud crimes from the conduct alleged in the Charge. Two respondents pleaded guilty and one was convicted after a jury trial and later disbarred. 

A U. S. Administrative Law Judge will hear HUD’s Charge unless any party elects to have the case heard in federal district court. If an administrative law judge finds, after a hearing, that discrimination has occurred, the judge may impose civil penalties and/or award damages to the homeowners for their losses as a result of the discrimination, injunctive relief, other equitable relief, as well as payment of attorney fees. In addition, the judge may impose civil penalties to vindicate the public interest. If a federal court hears the case, the judge may also award punitive damages to the homeowners. 

Read the June 13, 2023 HUD press

 June Edition of "Fair Housing E-News"

FAIR HOUSING E-NEWS

June, 2023

Welcome to this edition of Fair Housing E-News! This newsletter is produced by the GBCHRB

as a public service. More info/resources: http://www.gbchrb.org. Just a few of the headlines are:

NLIHC’s Out Of Reach 2023: The High Cost Of Housing Shows Rents are Moving Further out of Reach for Low-Income Renters As Pandemic-Era Benefit Programs Expire.

Read the NLIHC Summary of its 2023 Out of Reach report.

Out of Reach 2023 is available at: https://nlihc.org/oor.

Study Finds Baltimore Children who moved from High-Poverty to Low-Poverty Areas had Improved Asthma. Read the May 16, 2023 Baltimore Sun article.

Maryland Finds Erie Insurance Illegally Rejected Baltimore Auto Customers in Minority Neighborhoods. Read the June 6, 2023 Baltimore Sun article. Read the June 1, 2023 Baltimore Banner article.

Justice Department Secures Over $3 Million Redlining Settlement Involving ESSA Bank & Trust in Philadelphia. www.justice.gov/fairhousing.

Federal Housing Administration Launches 30 New Resources to Remove Language Barriers in Chinese, Korean, Spanish, Tagalog, and Vietnamese for Borrowers.

Read the June 13, 2023 HUD release.

KeyBank & Capital One Lose Their Access To New York City’s Business. "NYC Regulator Halts City Deposits at Key Bank, Capital One," Banking Dive, May 26, 2023. NCRC Just News/ May 25, 2023 Press Release.

To read this issue of Fair Housing E-News: fhnews2023jun.pdf.

Contact the GBCHRB for free Fair Housing training.

GBCHRB

P. O. Box 66180

Baltimore, Maryland 21239-6180

http://www.gbchrb.org

443.347.3701

 Mortgage Lending Discrimination

 KeyBank & Capital One Lose Their Access To New York City’s Business

The NYC Banking Commission has voted to freeze deposits at the two megabanks over their refusal to tackle racial discrimination. KeyBank and Capital One will not receive further deposits from the City of New York after the unprecedented public vote by the Commission, which took the punitive action because the banks have refused to share information on their internal efforts to combat discrimination by failing to submit anti-discrimination plans. The New York City Comptroller Brad Lander, one of three members of the commission, also voted against allowing Wells Fargo, PNC, and International Finance Bank to hold public funds after they also failed to submit anti-discrimination plans.

In a public hearing, the Commission designated 26 banks to receive deposits from city agencies for the next two years. Despite the suspensions of Capital One and KeyBank, the two banks can service existing contracts for one year.

These actions come after the Commission in February strengthened its rules to make designated banks more accountable to the public by asking banks to provide detailed plans and specific steps to combat lending and employment discrimination. Banks are expected to provide approved banking products and services for city entities and must provide total collateralization for any money held.

“Good cities shouldn’t do business with bad banks, so it’s great to see the New York commissioners take action here,” the National Community Reinvestment Coalition (NCRC) commented. “KeyBank and Capital One have atrocious track records of not just under-serving but actively harming the interests of low-wealth communities and people of color. New York City moves a lot of money around in the course of everyday business, so some bank is going to make money by providing that service. But that profit opportunity shouldn’t go to banks like these that abuse the privileges of a federal bank charter while flouting the responsibilities that come with it.”

KeyBank’s refusal to provide the required documents to the Commission comes months after an NCRC report exposed the Cleveland-based lender’s worst-in-class performance on lending to non-White, non-wealthy borrowers. The bank in May agreed to a third-party racial equity audit after fair-lending groups and 80 community organizations asked federal regulators for an investigation into alleged redlining in the its mortgage lending practices. It claims that the current problem is a misunderstanding.

NCRC said that "Capital One, meanwhile, has repeatedly harmed the public, violated consumers’ rights, and rejected legal obligations not to discriminate." A Capital One spokesperson told Ameican Banker it does not encourage discrimination against employees and clients, and that what it submitted to city officials was “consistent” with past materials.

In April 2022, after City officials agreed to not to open any new depository accounts with Wells Fargo Bank after a Bloomberg report found the bank approved less than 50% of refinance applications from Black homeowners in 2020 but 72% from white borrowers. A Wells Fargo spokesperson told American Banker in an email at the time that “We are ready to continue serving [the city’s] needs today and well into the future.” 

*****

Sources: 

"NYC Regulator Halts City Deposits at Key Bank, Capital One," Banking Dive, May 26, 2023.

NCRC  Just News/ May 25, 2023 Press Release.

 Free Fair Housing & Tenant Rights Workshop on April 26th

Whether you are a renter or homeowner, do you know your fair housing and tenant rights? Join Citizens Planning & Housing Association (CPHA) and community partners for an educational workshop. Learn about your rights and resources. The CPHA, the Public Justice Center, Baltimore Renters United, and the Baltimore City Branch of the NAACP will lead presentations. Light refreshments will be provided. Registration is required. CLICK HERE to register. Questions? Contact Char McCready at charm@cphamd.org. ***** Source: CPHA.

 Fair Lending

NCRC Announces $50 Billion Community Benefits Agreement With TD Bank

By NCRC / February 15, 2023 / Press Releases

TD Bank will commit $50 billion in investments, lending, philanthropy and other services for diverse and underserved communities, the National Community Reinvestment Coalition (NCRC) announced Wednesday, pursuant to a community benefits plan the organization facilitated between the bank and NCRC members. 

“TD Bank brought dedication and open minds to the meetings with NCRC members that brought us to this strong and promising agreement,” said Jesse Van Tol, President and CEO of the National Community Reinvestment Coalition President. “The deal we just signed will ensure that communities of need see tangible increases in resources and economic opportunity in their neighborhoods — as every bank merger is legally required and morally bound to do. This agreement reflects the hard work of our members and the bank’s staff in numerous ways, including TD’s commitment to opening 25 new physical bank branches in marginalized communities — the largest such pledge to date by any of the 20-plus banks that have signed onto a community benefits agreement with NCRC members. I applaud everyone involved for bringing the candid, constructive energy these deals require to our meetings and producing such a robust final package.”

To identify areas of greatest need in communities across 22 states and Washington, D.C., the bank solicited feedback from NCRC leadership and non-profit groups from both TD and First Horizon markets from the time it announced its definitive agreement to acquire First Horizon Corporation in February 2022. TD will meet annually with NCRC to discuss and measure progress on the elements of the plan. 

“Banks have an important role in providing economic opportunity and supporting changes that help low- and moderate-income (LMI), diverse and underserved communities achieve their financial goals,” said Leo Salom, President and CEO of TD Bank. “This is rooted in the belief that our business only does well when the people we serve are flourishing. Our Community Benefits Plan builds on TD Bank’s and First Horizon’s longstanding focus on our communities. We are excited to continue this focus in First Horizon markets as we move forward with combining our two organizations. Thank you to NCRC and its member organizations for their collaboration and critical insight as we developed an effective plan that addresses the priorities and needs of the communities we serve.”

Since 2016, NCRC has facilitated 27 community benefits agreements with bank groups that committed more than $639 billion for mortgage, small business and community development lending, investments and philanthropy in LMI and under-resourced communities.

*****

Source: National Community Reinvestment Coalition newsletter, February 17, 2023.

Fair Housing History

The Racial History of Housing Discrimination and its Continued Effects in 2022

The following are excerpts from "The Racial History of Housing Discrimination and its Continued Effects in 2022" by Cree Long, who was the Fair Share Housing Center (New Jersey) Communications and Development Intern and former intern at the Center, and posted on the website of the Judge Alexander Williams Jr. Center for Education, Justice & Ethics at the University of Maryland, College Park. The Center can be contacted at the University of Maryland, Seneca Building, 4716 Pontiac Street, Suite 0104, College Park, MD 20740.

This article was written in April, 2022, marking the end of National Fair Housing Month. 

The Mount Laurel Doctrine, the series of Supreme Court decisions that prohibits economic discrimination by municipalities in exercising their land use powers, prioritizes space for affordable housing. The Doctrine fights against towns in New Jersey that used zoning as a tool to further exclude and oppress communities of color. Despite the extraordinary progress we’ve made in addressing exclusionary zoning in the nearly fifty years since we were founded, there is still much more work to do. Discriminatory policies of the past continue to perpetuate recurring, detrimental harms on communities of color, even today. Not only were these policies rooted in racism, but every level of government, especially in New Jersey, supported these mandates– making it impossible for Black and Brown families to generate wealth and live peacefully...

Perhaps the most notable of these is redlining. The practice of redlining was created through the Home Owners’ Loan Coalition’s residential security mapping system, which was used to monitor mortgage default between residents. Outlined in red on the map were Black communities representing “detrimental influences.” Though the idea of redlining began during slavery, its longevity has resulted in discrimination in housing and land ownership based on race throughout the country. Especially with New Jersey’s history of redlining and segregation, it was nearly impossible for Black and Brown residents to ask for financial assistance, buy property, and of course, refinance.

Amid the continued turmoil around housing discrimination for Black residents, the Fair Housing Act (FHA) of 1968 was passed by Congress and was intended to provide equal housing opportunities for residents of every race, background, religion, and ethnicity. Civil Rights leader Martin Luther King, Jr. advocated for fair housing among Black people by eliminating discrimination and promoting Black homeownership. Martin Luther King was assassinated just a week after the Fair Housing Act was passed. And despite the law, discrimination in housing policies made it difficult for Black people to obtain wealth especially through homeownership, no matter their income. Still today, Black people are often rejected for loans, discouraged from buying homes, and are subjected to live in neighborhoods with poor schooling systems, food deserts, lack of public transportation, and environmental issues...

Due to our flawed policies and the vast racial wealth gap, Black and Brown people have struggled to achieve and generate wealth...

References:

New Jersey Institute for Social Justice. (2020). Erasing New Jersey’s Red Lines: Reducing the Racial Wealth Gap Through Homeownership and Investment in Communities of Color. https://d3n8a8pro7vhmx.cloudfront.net/njisj/pages/689/attachments/original/1588…NewJersey’sRedLines_Final.pdf?1588358478

United States Department of Housing and Urban Development. (n.d.). History of Fair Housing. https://www.hud.gov/programoffices/fairhousingequalopp/aboutfheo/history

New Jersey Institute for Social Justice. (2020). Black and Brown in New Jersey: The Garden State’s Shameful Racial Wealth Gap. https://www.njisj.org/blackandbrowninnj

 FHFA Announces Update for Housing Loan Servicers to Maintain Fair Lending Data

The Federal Housing Finance Agency (FHFA) has announced that Fannie Mae and Freddie Mac (the Enterprises) will require loan servicers to obtain and maintain fair lending data on their loans, and for this data to transfer with servicing throughout the mortgage term.

FHFA Director Sandra L. Thompson commented: “The need for collection and maintenance of quality fair lending data is a lesson learned from the foreclosure crisis and COVID-19 response,” said  “Having fair lending data travel with servicing will help servicers do the important work of providing assistance to borrowers in need, helping to further a sustainable and equitable housing finance system.”​

The fair lending data to be maintained includes borrowers’ age, race, ethnicity, gender, and preferred language. Servicers will be required to implement this change starting on March 1, 2023. This update follows a May 2022 announcement, which requires lenders to collect borrowers’ language preference data.

Specifically, that announcement require lenders to use the Supplemental Consumer Information Form (SCIF) as part of the application process for loans that will be sold to the Enterprises. The SCIF collects info regarding the borrower's language preference, if any, and on any homebuyer education or housing counseling the borrower received, so lenders can better understand borrower needs during the home buying process. Lenders are required to adopt these changes and reporting requirements for loans with application dates on or after March 1, 2023. Response by borrowers to the preferred language question in the SCIF will continue to be voluntary.

The Federal Housing Finance Agency regulates Fannie Mae, Freddie Mac and the 11 Federal Home Loan Banks. These government-sponsored enterprises provide more than $7.5 trillion in funding for the U.S. mortgage markets and financial institutions. Additional information is available at www.FHFA.gov, on Twitter, @FHFA, YouTube, Facebook, and LinkedIn.

For more information, contact: ​Adam Russell - Adam.Russell@FHFA.gov

Read the August 10, 2022 FHFA release.