FHFA-OIG recommends that FHFA:
1. Review the circumstances surrounding FHFA not identifying the foreclosure abuses at an earlier stage and develop potential enhancements to its capacity to identify new and emerging risks.
2. Develop and implement comprehensive examination guidance and procedures together with supervisory plans for default-related legal services.
3. Develop and implement policies and procedures to address poor performance by default-related legal services vendors that have contractual relationships with both of the Enterprises.