A letter sent Monday to U.S. Attorney General Pam Bondi details embattled Federal Reserve Governor Lisa Cook’s high-stakes defense of her role and reputation at the central bank, fending off allegations of mortgage fraud lodged by the U.S. government.

The lawyer representing Cook, Abbe Lowell, wrote to Bondi and Edward Martin, associate deputy attorney general and special attorney for mortgage fraud at the Department of Justice (DOJ), that “an isolated notation” on a single loan document does not constitute mortgage fraud.

Cook was criminally referred to the DOJ in August by Federal Housing Finance Agency (FHFA) Director Bill Pulte, who alleged Cook fraudulently claimed homes in two states as her primary residence, and in doing so possibly received more favorable financing terms.

The following week, Martin sent a letter to Fed Chair Jerome Powell signaling the DOJ would be opening a probe into the allegations made by Pulte.

“At this time, I encourage you to remove Ms. Cook from your Board,” Martin wrote. “Do it today before it is too late! After all, no American thinks it is appropriate that she serve during this time with a cloud hanging over her.”

President Donald Trump subsequently moved to fire Cook on Aug. 25, citing the mortgage fraud allegations as justification, but lower courts blocked the administration’s actions. Cook has continued serving at the Fed while her case proceeds, with the Supreme Court scheduled to begin hearing oral arguments on Jan. 21.

A refinance in Ann Arbor

To convict Cook for mortgage fraud, Lowell wrote in Monday’s letter, “the government would have to prove beyond a reasonable doubt that she both made false representations and specifically intended to defraud or influence the actions of the lenders.”

Three properties owned by Cook are under scrutiny by the DOJ: a home in Ann Arbor, Mich., a condo in Atlanta and a home in Cambridge, Mass.

Government lawyers have questioned why Cook claimed the Ann Arbor and Atlanta properties as primary residences on separate purchase and refinance mortgage applications filed just weeks apart in 2021.

Cook purchased the home in Ann Arbor in 2005 when she moved to the state to teach full time at Michigan State University.

She refinanced the loan in 2021, claiming the property as her primary residence on that application and in background and ethics questionnaires filed in connection with her nomination to the Federal Reserve Board in late 2021 and 2022.

With the intent to continue teaching following her full-time role with the Fed, according to Lowell, Cook began renting out the Ann Arbor residence in 2022, obtaining the local licenses and property insurance required to do so.

“Accordingly, Director Pulte’s claim that Governor Cook committed fraud by listing the Ann Arbor property as her ‘primary residence’ is baseless because that listing was true,” claims Lowell.

A purchase in Atlanta

Lowell defends Cook’s record by further underscoring how Pulte, in publicizing the allegations on social media and failing to provide Cook with an opportunity to respond, “has ignored critical context — and in doing so, has misled the public and DOJ.”

Cook purchased a condo in Atlanta in July 2021 to be near her family after her family sold its jointly-owned home in Milledgeville, Ga., in 2021.

Lowell claims the government selectively ignored context when it singled out what “was at most an inadvertent notation” in a bundle of loan documents and federal disclosures.

Evidence attached to Monday’s letter show Cook submitted contemporaneous documents to the mortgage lender stating the intended use of the condo as a “vacation home.”

Those documents prompted Lowell to write that “it would be impossible to conclude that she intended to defraud the lender by inadvertently listing the property as her ‘Primary Residence’ elsewhere.”

Annual filings Cook has submitted in connection with her government employment reference the property as a “2nd home” or “personal residence.”

‘Weaponization of the FHFA’

In reviewing the full package of mortgage documents and federal disclosures that Cook has had to file over the past two decades, Lowell says “cherry-picking one line from one document” does not amount to the criminal wrongdoing FHFA Director Pulte and President Trump claim has occurred.

Rather, Lowell suggests in his letter, Pulte has weaponized the FHFA against those perceived opponents of the Trump administration’s policy priorities, undercutting the basis for the criminal referral.

Lowell points to reporting alleging that Pulte’s own family members, Treasury Secretary Scott Bessent, three of Trump’s cabinet members and the Republican Texas Attorney General Ken Paxton have claimed multiple “primary residences” on mortgage documents, and yet no criminal referrals or firings for cause have been pursued.

Lowell goes so far as to cite reporting from The Wall Street Journal that internal ethics employees at the FHFA-regulated mortgage investor Fannie Mae were allegedly fired for probing whether Pulte had directed senior FHFA officials to improperly obtain mortgage documents of Democratic officials and Pulte’s alleged partisan targets.

Pulte’s use of the criminal referral process “to selectively — and publicly — investigate and target the President’s designated political enemies gives rise to the unmistakable impression that he has been improperly coordinating with the White House to manufacture flimsy predicates to launch these probes,” Lowell claims.