Federal Reserve Governor Lisa Cook is under increasing scrutiny following allegations of mortgage and occupancy fraud tied to discrepancies in her property filings. Federal housing regulators have issued at least two criminal referrals, raising questions about her mortgage applications and disclosures.

CNN acknowledged the seriousness of the case on Friday, with legal analyst Elie Honig calling the situation “really problematic” for Cook, according to The Daily Caller.

Bill Pulte, head of the U.S. Federal Housing Agency, confirmed that a second criminal referral has been filed against Cook. He alleges that she misrepresented a Cambridge, Massachusetts, condominium as a “second home” on a 2021 mortgage application, while listing the same property as an “investment/rental” on a government ethics form just eight months later.

“Three strikes and you’re out,” Pulte wrote on X, outlining what he called repeated false statements involving Cook’s properties in Cambridge, Massachusetts; Atlanta, Georgia; and Ann Arbor, Michigan.

According to Pulte, Cook’s 2022–2025 filings consistently classified the Cambridge condo as an investment property—directly contradicting the earlier “second home” claim on her mortgage application. He also alleged that Cook declared both her Atlanta and Michigan properties as her primary residence on separate mortgage documents filed within two weeks of each other. Later, she allegedly listed the Ann Arbor address as her home while renting it out.

Such misrepresentations could have given Cook access to more favorable loan terms. Lenders generally offer lower rates and down payments for primary or secondary residences compared to investment properties, which are considered riskier.

Cook has admitted in court documents that some filings were inaccurate but attributed the inconsistencies to clerical errors. Legal analysts, however, are unconvinced.

“Why would someone do all this? Because you get better interest rates, because you get better tax benefits,” Honig said on CNN. He emphasized the pattern of behavior: “There’s three properties. In one two-week period, she claims two different places as her primary residence. And she calls a rental property a second home. That’s not a mistake—that’s a scheme.”

Honig also dismissed Cook’s defense. “She’s one of the most accomplished economic and financial experts in the country. The clerical error excuse doesn’t hold up.”

Pulte contends that the case involves potential mortgage fraud, occupancy fraud, and tax violations. He noted one instance where Cook reportedly told the U.S. government on February 28, 2023, that her Atlanta property was her personal residence—just six months after listing it for rent.

Cook, who was appointed to the Federal Reserve Board by President Joe Biden, was removed from her post last week by President Donald Trump, citing the ongoing fraud investigation.

In a letter to Cook, Trump wrote:

“Pursuant to my authority under Article II of the Constitution of the United States and the Federal Reserve Act of 1913, as amended, you are hereby removed from your position on the Board of Governors of the Federal Reserve, effective immediately. I have determined that there is sufficient cause to remove you from your position.”

Cook has since filed a lawsuit challenging her dismissal. The case, assigned to a federal judge appointed by President Biden, names Trump, the Federal Reserve Board of Governors, and Fed Chair Jerome Powell as defendants. Her legal team includes high-profile attorneys Abbe Lowell and Norm Eisen.

Pulte has argued that the close timing of Cook’s various mortgage filings indicates her lenders may not have been aware of each other’s underwriting assessments, a situation he says fits the definition of occupancy fraud.