“FHFA recognized the importance of its oversight of the Enterprises’ default-related legal services and gradually accumulated information on the attorney network programs of Fannie Mae and Freddie Mac. However, FHFA did not schedule comprehensive examination coverage of foreclosure issues, including allegations of abuse by RAN law firms until after news stories about alleged abuses surfaced in August 2010. FHFA had not previously considered risks associated with foreclosure processing to be significant. Instead, FHFA focused its examination resources on assessing high risk areas such as the Enterprises management of credit risk.
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