I am being “abolished . . . for the efficiency of the service.” August 25th will mark my final day at FHFA and the final day of my 17 years in the federal career civil service. I’m looking forward to sharing what’s next for me shortly, but I wanted to take a moment of self-indulgence and reflection first.
I started as a Law Clerk in the HUD legal honors program and am leaving as a Deputy Director at FHFA responsible for a division. I’m grateful for all of the leaders and mentors I had across three agencies, as well as the many great colleagues I worked with, and all the other wonderful people I met through my work.
At FHFA I had the opportunity to lead a truly great team. I couldn’t have asked for a better group of people. Some of the items I’m most proud of are:
- the Equitable Housing Finance Plans’ support for special purpose credit programs, which provided at least $82 million in reduced costs to 57,282 borrowers of all races in 2022-2024;
- the public appraisal database that provided privacy-protected access to GSE appraisal data for the first time to researchers, advocates, appraisers, lenders, and the public; and
- the unique fair lending testing methodology that we developed for the risk-based characteristic weights in the capital rule, leading to meaningful improvements in fairness for that part of the rule.
At CFPB, some of the things I’m most proud of include:
- touching Regulations B, C, D, F, M, P, V, X, and Z through guidance or rulemaking;
- significant improvements to the HMDA data through the amendments to Regulation C; and
- being team lead for the Section 1071 rulemaking in some its earlier days.
At HUD, a few of the things I’ll cherish most are:
- working on the original disparate impact rule and having preamble text I wrote quoted favorably by Justice Kennedy; and
- working on the first HUD Fair Housing Act charge on behalf of a trans woman alleging sex discrimination.
I also did a quick review by the numbers of my life as a bureaucrat:
- Presidents - 4 (6 total administrations)
- Acting or permanent agency heads - 9
- Direct supervisors - 7
- Desks or offices - 14
- Legal memos - too many to count
- PowerPoint decks - way too many to count
- Number of times my name appears as an agency contact on a document in the Federal Register - 24
- Proposed, interim, or final rules - at least 25
- Agency guidance documents, interpretive rules, administrative orders, etc., - at least 60
- Clearance comments that had to be resolved when drafting public documents - enough to blot out the sun
- Agency speaking engagements - at least 50
- Time cards certified - about 442 of my own, maybe 1500 for others?
- Informal oral regulatory guidance questions answered - at least 600
- HUD administrative charges - 5 (4 elected to DOJ and resulted in settlements or consent orders, 1 to HUD ALJ hearing and then Secretarial appeal)
- Settlements, conciliations, voluntary compliance agreements, etc. - at least 15
- Adverse findings presented to boards of directors or senior management - CONTROLLED/CONFIDENTIAL SUPERVISORY INFORMATION
- Referrals to the Department of Justice for potential enforcement - CONTROLLED/CONFIDENTIAL INTERAGENCY COMMUNICATION
Y’all don’t be strangers now!