Federal Reserve Governor Lisa Cook’s defense repeatedly emphasized that she had no intent to defraud as an argument central to refuting allegations that she misrepresented the occupancy of three properties to obtain more favorable mortgage terms, according to a letter sent by her attorney to the Department of Justice (DOJ).

In early September, the DOJ reportedly launched an investigation seeking information related to the claims stemming from two criminal referrals that Federal Housing Finance Agency (FHFA) Director Bill Pulte sent to Attorney General Pam Bondi. These referrals prompted President Donald Trump to attempt to dismiss Cook “for cause” on Aug. 25.

“Nothing in the referral letters even remotely suggests that the government could carry that burden because there is no evidence that Governor Cook made false representations or had the ‘required specific intent to defraud,” states the letter, which was signed by Cook’s attorney, Abbe David Lowell.

A spokesperson told HousingWire that the DOJ “does not comment on current or prospective litigation including matters that may be an investigation.”

In a letter to Bondi and Special Attorney Edward Martin, Lowell argued that the criminal referrals were prepared with “no or minimal research into the actual facts” and were used as a pretext for Trump and Pulte to investigate those viewed as obstacles to the president’s political and economic agenda.

Lowell also wrote that Pulte’s actions were a response to the “President’s desire to change the makeup of the Federal Reserve Board so he could dictate an interest rate cut.” The FHFA did not immediately reply to HousingWire‘s request for comments.

Responses to the mortgage fraud claims

Pulte alleges that in 2021, Cook stated in mortgage applications that homes in Michigan and Georgia would serve as primary residences in order to qualify for lower interest rates and reduced down payments, when in fact they were intended as investment properties.

According to Lowell, Cook has had different principal residences over the years due to her academic and government positions. Her Ann Arbor property, refinanced in 2021, remains Cook’s primary residence, even though she has not lived there during her Fed tenure. Cook intends to return once her term ends, Lowell said.

Regarding the Atlanta property, Lowell stated that listing it as a primary residence was, at most, an “inadvertent notation,” noting that another document provided to the lender identifies the condo as a “vacation home.”

“In cherry-picking one line from one document, Director Pulte has ignored critical context— and in doing so, has misled the public and DOJ in his postings of incomplete mortgage documents on social media,” the letter reads. 

Pulte also claimed in a second referral that Cook listed a Massachusetts condominium as a second home but later reported rental income from the property, suggesting it was being used as an investment.

The defense letter states that Cook refinanced the property in 2021, converting it to a second-home mortgage — a transaction approved by the bank. “Governor Cook still spends a few weeks each summer at the Cambridge home — making it a ‘second home’ for mortgage purposes.”

Cook has challenged President Trump’s attempt to fire her in court. The U.S. Supreme Court is set to hear arguments in the case on January 21.