Policy and Procedure links to Change Management

QUESTION 

We need an overhaul of our policies and procedures. Our company merged with another company, and our policies are different in many ways, from the text itself to the format. It is tough enough to have the merging of two cultures, we are now banging into one another over what policy applies and what procedures to follow. 

As the Compliance Officer and General Counsel, I am involved in harmonizing these documents, and the task is almost overwhelming. Every project impacts our policies. We have had to update our Change Management policy five times in the last six months just to adapt to the merging of documents. 

What I need is some kind of checklist that I can get stakeholders to agree to or at least accept by consensus. I consulted with experts in policy development, but it was frustrating. If they knew the regulatory requirements, they disagreed on the text, and if they knew the formatting requirements, they disagreed on the best format. They seem oblivious to the implications of Change Management. 

A member of our Board of Directors referred me to you. She believes you can help resolve these issues. So, I'm writing you for guidance. I also want to schedule a call with you to discuss your services. 

Can you help us understand how our policies and procedures are linked to our Change Management requirements? 

SOLUTIONS 

·       Customized Compliance Library

·       Policies Tune-up®

·       CMS Tune-up®

RESPONSE 

There are a few aspects to your circumstances. Not only do you mention the issue of merging policies and procedures resulting from a merger and the impact on projects, but you also note how many times you have had to update your Change Management requirements because of this debacle. We have handled and resolved matters such as yours many times. Your situation often happens. 

Many clients come to us for our customized compliance library. Since you are new to our services, it is worth knowing that we pioneered the effective drafting and implementation of a compliance library. So, you have come to the right place! I'm sure we can help! 

Let's start with Change Management. What is it? Essentially, it is the governing methodology that provides an infrastructure to support and sustain change throughout multiple phases in your financial institution while focusing on achieving a set of defined and desired business results. 

There is a good reason why you mention Change Management. That is because your policies and procedures are an intrinsic part of it. 

To clarify, a financial institution is under pressure from regulators, borrowers, shareholders, and investors to improve its business continuously. These pressures lead to companies initiating a wide range of company projects, including small, targeted updates, process enhancements, large, complex system implementations, and major business process re-engineering initiatives. Thus, an institution's ability to standardize its process and project management practices mitigates the risk of project failures and maximizes the value delivered to its organizational processes. 

Therefore, you have hit on the two primary purposes of Change Management: 

·       Process Management, and

·       Project Management. 

I am going to offer a way to think about Process Management and Project Management and how they link to Change Management. Merged policies and procedures will be given their due consideration. 

BUILDING A CHANGE MANAGEMENT FRAMEWORK 

Before understanding the operational framework of Change Management, its two primary purposes, and its derivative structures, such as policies and procedures, you must determine:

1. Define and describe what changes will be implemented.

2. How to coordinate the input from stakeholders.

3. What will constitute a formal change plan.

4. The resources and data that will be used and available.

5. The overall communication strategy at all operational levels.

6. A review of budget risks associated with change. 

CHANGE MANAGEMENT METHODOLOGY 

As the company's Compliance Officer, it would be your responsibility to establish controls to ensure a viable Change Management methodology is applied consistently between individuals and work groups. 

I recommend that your methodology contain the following guidelines. 

·     Determination of business ownership and governance responsibilities.

·     An impact analysis prior to the implementation of process changes.

·     Communication of new or revised processes to impacted business units or areas.

·     A process that ensures policies, procedures, and processes are updated to reflect remediated control deficiencies.

·     A procedure for approving new or revised processes.

·     A procedure for managing and introducing process revisions.

·     The identification of training needs based on creating or updating policies and procedures.

·     The validation of new or revised policies and procedures prior to implementation. 

PROCESS MANAGEMENT 

Once the Change Management framework is completed, you can move on to interfacing them with Process Management and Project Management.

The primary purpose of process management is to group specific operational components for implementing interlocking institutional bases and contributing to an institution's activities. This means, in theory and practice, the setting up of the requirements needed to effectuate change throughout the company. 

Our reviews of Process Management have shown that there are at least eight structures needed for executing efficient institutional activities. This is a list that we use to ensure the stability of Process Management.

 

1.     There should be a centralized repository for all policies and procedures. In our work, we keep our clients' Masters in an encrypted, secure extranet.

 

2.     A dedicated group that oversees changes related to processes, systems, and policies. You must have a point person or persons involved in oversight. The contact information should be in writing and ratified by the board and/or management.

 

3.     Policies, procedures, and support documents are "mission-critical" key processes. They must be continually evaluated and updated with current revisions.

 

4.     All policies, procedures, and support documents should evaluated for completeness and accuracy. Inactive, dormant, and inoperative policies should be formally retired. Abeyant and suspended policies should be mothballed.

 

5.     Quality assurance reviews should be conducted periodically to ensure the actual performance of employee work processes is consistent with process flows and descriptions.

 

6.     The oversight team should draft a change management manual or tool to manage and track process updates. The board or management must ratify the manual.

 

7.     A standardized template should be modeled for policies and procedures throughout the organization.

8.     Be sure that the appropriate staff responsible for change management processes is well-trained or has the necessary skills to perform these functions.

PROJECT MANAGEMENT 

There are many ways and means to build project management structures. We have project managers who are credentialed in this task; however, you can create basic elements that interface with the Change Management framework. 

You don't need to be overwhelmed by this undertaking. Everything can be accomplished gradually so long as you have a logistical approach. A generic outline of project management should contain at least the following components: 

·       A project management manual or tool to track and manage projects.

·       Referenced policies, procedures, and systems affected by a project.

·       Project management tracking reports.

·       Centralization of project activities in an oversight group.

·       Training of relevant staff for project participation and management.

·       Periodic project tracking reports are communicated to stakeholders.

·       Updates to the inventory of projects subject to tracking. 

I also recommend that your project management methodology include: 

·       Communication of project goals and status.

·       Milestone reviews and approvals.

·       Identification and mitigation of project risk.

·       Identifying stakeholders, including their operational relevance.

·       Documenting procedures for change control documentation.

·       An escalation process for projects where there are tracking errors.

·       Log of activities with a column for remediation information and implementation. 

Jonathan Foxx, Ph.D., MBA
Chairman & Managing Director 

Lenders Compliance Group

Fannie’s MORA Review: Internal Audits

QUESTION 

Although approved by Fannie Mae, we have not set up an internal audit schedule. This issue came up in a recent discussion with our Fannie representative. They want us to be ready for the MORA audit, and the audit schedule is going to be required. We haven’t even done an internal audit yet. This got us thinking about what we don’t know for preparing for the MORA visit. 

We know your company is well-known for independent risk assessments and self-evaluations, which are called the Compliance Tune-up®. I spoke to one of your Directors this morning about several of them that could help us get prepared for the Fannie audit. We need to know which policies and procedures will be reviewed, and we need to know so much more. Our first MORA audit is coming soon. So, we’re somewhat intimidated. 

I am the compliance manager. I have never handled a MORA audit before. And I have never been involved in an internal audit. I need some guidance about what Fannie expects for internal audits and a “heads-up” for their requirements.

·       What are Fannie’s expectations for internal audits?

 

·       Can you please provide a “heads-up” for the internal audit requirements?

·       What have you found that shows your clients were not prepared for an internal audit? 

SOLUTION 

Compliance Tune-up® List

MORA Tune-up® Fannie's Mortgage Origination Risk Assessment (MORA)

CMS Tune-up® Compliance Management System

RESPONSE 

Anyone who has an interest in our Compliance Tune-up®, in general, or our MORA Tune-up®, in particular, can contact us here. The Compliance Tune-up® is an extensive series of mini-audits that targets departments, functions, and regulations. It is a self-identification and risk assessment review that complies with the second line of defense.[i] The review provides a report and risk rating. It shows the strengths and weaknesses of the area subject to review. 

Fannie Mae conducts regular reviews to evaluate seller/servicer compliance with its guidelines and assess operational risks. Reviews are conducted by a team that operates independently of the Business Account Management Solutions team. 

You will need to establish an independent internal audit function. During the MORA process, Fannie Mae examines the lender's internal audit plan and the latest independent internal audit. A financial institution may outsource its internal audit process; however, it remains responsible for the findings that show compliance (or lack thereof) with Fannie's requirements.

An internal audit is the central feature of the third line of defense. From Fannie’s perspective, management control is itself a function. Indeed, establishing a professional internal audit activity should be a governance requirement for all organizations. 

Management is supposed to rely on the internal audit to validate a financial institution’s governance, risk management, and control processes to help it achieve strategic, operational, financial, and compliance objectives. This compliance framework is meant to ensure a risk-based approach, and the internal audit function evaluates and improves the effectiveness, exigencies, and readiness of risk management, control, and governance processes. 

We believe the following outline provides the guardrails and requirements of an internal audit. It would be best if you considered them collectively so that you prepare adequately for the development of this function. In other words, don’t cut corners. Be sure you comply with all these criteria. 

Internal Audit Function: Guardrails and Requirements

·       Be sure that the internal audit manager is free from any responsibility over any business unit.

 

·       Be sure the internal audit is independent of all key functions of the loan origination and servicing processes.

 

·       Draft internal audit and management control procedures for evaluating and monitoring the overall quality of loan production.

·       Ensure that your organization chart shows that the internal audit function reports directly to the senior management and, if applicable, the Board of Directors. (By the way, we know from experience that Fannie will permit exceptions in situations in which the size of the organization is insufficient to support adequate resources to allow for the separation of these functions. In those situations, your audit plan must include the rationale for the lack of separation of controls in place to mitigate risks associated with the lack of separation of these functions.)

·       Be especially careful that internal audit lines of reporting reflect the independence of the audit process at all levels so that the activities are conducted in an unbiased manner and without compromises that may result from internal influences or conflicts of interest.

·       Be especially careful that the internal audit function does not share any reporting lines with the functional areas that it reviews.

·       Create a reliable and scaleable reporting procedure to ensure that the written findings provide methodologies that derive recommendations that management can use to accomplish actionable objectives through a systematic, disciplined approach to evaluating and improving the effectiveness of risk management, control, and governance processes. 

Adverse Findings and Required Document Preparation 

There are a few other things I would like you to consider. I’ll get to them in a moment. You had asked about how some clients show that they are not ready for an internal audit. By this point, I think we’ve seen just about everything there is to see about internal audit findings and preparation. However, most challenges can be overcome if you have robust plans. 

We have an extensive database of common findings from independent internal audits and Compliance Tune-up®. I have picked seven of them that I think are virtually non-negotiable. 

Adverse Findings

1)    There is no comprehensive written plan to direct the internal audit process across all loan manufacturing and servicing business functions.

 

2)    There is no internal audit function.

3)    MBS Trust compliance is not included in the internal audit review plan and testing.

4)    The internal audit process has not been initiated.

5)    There is no internal audit function that is independent of the business functions subject to review.

6)    An internal audit schedule has not been established to specify the areas of review, and there’s no timeframe for conducting them.

7)    The internal audit plan does not include all required components. 

Required Document Preparation 

Each financial institution differs and is unique in terms of size, products, services, complexity, risk profile, and business strategy. Keep that in mind as I outline the document preparation needed to be ready for a MORA review. You can tighten up preparation by using the appropriate Compliance Tune-up® tool, such as a MORA Tune-up® or a CMS Tune-up®. 

A Compliance Tune-up® report provides recommendations indicating what should be done now and in the future to ensure readiness, but you can’t undo mistakes of the past. Willingness to correct errors, however, is a sign of good management and governance. So, it would be best if you got ready immediately to prevent a lookback that discloses unmitigated adverse findings. 

·       Organization chart reflecting the internal audit department

·       Internal audit policies and procedures.

·       Current year’s testing schedule and internal audit plan.

·       Current year’s Compliance Tune-up®. (Second Line of Defense).       

·       Current year’s independent internal audit. (Third Line of Defense).

·       Ability to identify any significant findings for the past 12-month period.

·       Management and tracking reports for monitoring performance in operational areas. 

WordS to the Wise should be Sufficient! 

I stated above that there are a few other things I want you to consider. I list them in no order of importance because they are all equally important. Let’s group these remarks in the category of “words to the wise should be sufficient!” 

·       An internal audit plan should be risk-based, updated annually, and include a review of all controls and key functions in each origination and servicing department. 

·       Applying a risk rating for each key process area of the originations and servicing platforms is critical to implementing a continuous internal audit schedule. 

·       A second line of defense review, such as the Compliance Tune-up®, should be initiated for specific departments, functions, and regulations in anticipation of performing the internal audit. (This ensures that the internal audit, the third line of defense, may present accurate and reliable findings.) 

·       A process should be in place to define the scope and frequency of audits to be performed based on the specific risk rating for all key functions. (This ensures that the functions that represent the highest risk are audited on at least an annual basis.) 

·       An internal audit schedule should be in place, reflect current activity, and be reviewed on a regular basis to incorporate any emerging risks in operational areas. 

·       Adverse internal or external audit findings pertaining to key functions or regulatory compliance should be reviewed by the audit committee for remediation. 

·       An established framework for interaction between internal audit functions, business units, and management exists to ensure open communications regarding risk and control management, including the adoption and implementation of self-assessment methodologies.

 

Jonathan Foxx, Ph.D., MBA

Chairman & Managing Director

Lenders Compliance Group

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[i] Three Lines of Defense in Effective Risk Management and Control, Institute of Internal Auditors (IIA), January 2013. The Lines of Defense (LOD) model assigns and coordinates risk and control responsibilities across business functions.

Housing Prices, Mortgage Rates, and Morale

QUESTION 

Since the election, our staff has seen a drop in morale. As the CEO, I felt it important to call a companywide Zoom meeting to discuss it. I asked our Chief Compliance Officer and Director of Human Resources to be on the call. During the call, we asked for participation in a survey, which showed quite a divide among staff, especially on how they see the future of mortgage banking and the country. 

Overall, the call was a good idea. People felt less intimidated to share their views, but a lot of people held back. Afterward, I received many emails from employees who thought they were not safe to express themselves. The throughline of these emails was that they feared reprisals from people who held political views opposite to theirs. 

The two big areas of disagreement began over what will happen to housing prices and the future of mortgage rates. There were arguments about whether the new administration's policies would cause a decline in housing prices and an increase in mortgage rates. The differences expanded and became intimidating.

This is the first time I've encountered such a situation. I am concerned about how this will affect our customer, departmental, and vendor relationships. Now, I know you're not a psychologist. We did an HR Tune-up a couple of years ago, and we had an excellent risk score, but this situation is unusual. I don't think it's an HR issue. We also had you do a CMS Tune-up for our compliance management review. However, this situation seems more like an internal risk. I am concerned about the attitude we bring to mortgage banking relationships. Maybe you could offer some feedback. 

I have read your column for years. Members of my firm read your newsletter. I want to post your reply to our company employee page. I have scheduled a call with you this December to discuss new Compliance Tune-up engagements. In the meantime, I urge you to let us know how you view the situation. 

What can I tell our employees about the future of housing prices and mortgage rates? 

What should I do about the harassment and intimidation issues that are messing with our morale? 

SOLUTION 

Compliance Tune-up 

ANSWER 

Since the election, I have received an enormous number of emails from clients, non-clients, subscribers, news organizations, colleagues, academics, and even a few retired regulators. As you correctly surmised, our firm only provides guidance based on our expertise in residential mortgage banking. We are not forecasters bent on prognosticating future events. We immerse ourselves in legal and regulatory compliance, conduct audits and due diligence reviews, and prepare our clients for regulatory changes. 

Given the outpouring of interest, we are considering offering a webinar on the impact of the election outcome on mortgage banking. If you think this is a webinar you would attend, please let me know here. I welcome your input. 

A recurring concern in the emails was the extent to which the new administration will undo regulations and consumer protections. The punditry has been out in full force. I will offer some educated guesses, but they are just guesses. I'll offer some feedback on the new administration's policies with respect to their potential impact on housing prices and mortgage rates. Given your concerns about the morale issues, I will conclude with a few words about mitigating a hostile work environment.

Housing Prices 

Reducing or terminating certain regulations might have a positive effect on housing markets. The theory is that less regulation usually leads to more active markets. 

I have spoken to a few builders – one of them is a national builder – who believe they will do better in the forthcoming plans to reduce regulations. That said, it seems to me that the supply of homes will still run short of some expectations and depends on the variable of an expanding economy, which generally causes home prices (and rents) to increase. 

However, some builders tell me that they expect tax incentives. When I pushed them on this theory, they said to me that increased housing inventory leads to lower home prices – the old supply and demand concept. I noted that the supply/demand ratio has its challenges, too, because lower home prices can, and often are, offset by increases in home buying costs caused by tariffs, which might increase costs, notwithstanding higher mortgage rates. 

For instance, the Trump tariffs imposed on Canadian lumber shipped into the U.S. were continued under the Biden administration. That drove up the average cost of a newly built home by about $14,000, according to a 2022 estimate by the National Association of Home Builders.[i] 

Maybe there will be further development of "opportunity zones,"[ii] which induce companies (or individuals) to invest in certain low-income areas in exchange for specific tax benefits (i.e., deferring capital-gains taxes). There will likely be the continuation of the Low-Income Tax Credit, which is a federal program ratified in 1986 that provides tax credits to housing developers in exchange for building affordable rental housing. 

Other factors that drive up the cost of housing are lot costs, uncertainty regarding the cost and availability of building materials, appraisal concerns, and survey timing. Federal, state, and local regulations also play a role in slowing the growth of the housing sector. How these factors get priced into the housing market will affect housing growth and supply. Notwithstanding the current market, which has pending home sales at their highest level since March, mortgage rates have been higher since early October.[iii] 

I do think it is appropriate to factor in the potential for a severe shortage of labor. The shortage is now at 52%. Previously, it was at 58% in 2023 and a record high of 77% in 2021.[iv] The problem of labor shortage worsens because 3,000,000 immigrant workers[v] account for 26% of the construction workforce.[vi] That's a record high![vii] The problem is the proposed plans for mass deportations of immigrants could have a substantial adverse impact on the house-building industry. 

There is a growing consensus among economists that deporting undocumented immigrants will further erode construction labor. As one well-known economist, Chief Economist Lisa Sturtevant of Bright MLS recently said:

"…the "mass deportation proposal would have a chilling effect on the construction industry, shrinking the already constrained labor force and stalling badly needed new housing construction." … "At the same time, proposed tariffs will increase building costs."[viii] 

In my conversations with builders and lenders, the response I get is that native-born construction workers will take the place of the immigrants. Well, I'm not so sure. According to one study, native-born workers are reluctant to join the construction industry. Their total count remains below the boom levels of the mid-2000s by over half a million.[ix] In fact, one in three craftsmen comes from outside the U.S. 

Mortgage Rates 

I'm not a prophet, but it doesn't take prophecy to figure out the short-term trajectory of mortgage rates, given the new administration's proposed plans. It seems to me that mortgage rates will remain high for now. I watch the credit markets closely, and I've noted the 10-year Treasury note has risen considerably recently, ostensibly, I suppose, in anticipation of a Trump win; but, remember, the 10-year pulls the 30-year mortgage rate along with it. Treasury yields usually increase when investors expect inflation to increase. In other words, investors are signaling an expectation of rising inflation. 

Here's an age-old formula: higher economic growth can lead to higher inflation, and higher inflation can lead to higher interest rates. 

Bond yields are rising because investors must be expecting the proposed fiscal policies to expand the federal deficit, meaning the downward direction of inflation will likely turn upward. Put another way, mortgage rates will be higher in the short term because investors are signaling that the budget deficit will not improve, notwithstanding the Fed cutting short-term interest rates. Therefore, unless inflationary pressures subside, it seems unlikely that the Fed will not make deeper interest rate cuts, which will keep mortgage rates high. 

During the campaign, Mr. Trump said mortgage rates would come down to 3% or lower.[x] My conjecture can be summed up in the following legal terminology: "Not going to happen!" Or, perhaps it could, if and only if there is a sharp economic downturn. I'm not into major economic crashes or some other kind of nasty economic downturn as a means to bring down mortgage rates. I hope you feel the same way! 

Here's another age-old formula: macroeconomic and microeconomic events determine mortgage rates, but presidents have no power to reduce mortgage rates. None. Not even a little bit! 

Given the foregoing observations, in the long term, it may be that home buying will peter down, not bubble up. 

Several of Trump's plans to impose tariffs could lead to higher mortgage rates through the end of this year. Let us not forget that the federal deficit will impact mortgage rates. I read that the president-elect says he will "charge" tariffs on several countries. Of course, tariffs are a tax paid by American consumers. So, it is the American consumer who is being "charged." Tariffs are import or export taxes added to the cost of goods and passed on to the American consumer. They are highly inflationary. And they often trigger retaliatory tariffs, thereby agitating and increasing the inflationary debacle. 

Here's a final age-old formula: taxing American consumers through tariffs, reducing construction labor supply (already severely depleted), implementing tax promises[xi] (i.e., expanding the 2017 tax cuts), increasing the deficit, may lead to a rise in inflation, higher housing prices, and elevated mortgage rates. 

Morale 

I would like you to consider a few final words regarding your observations that participating employees felt they "were not safe to express themselves" because "they feared reprisals from people who held political views opposite to theirs." I do not want to gloss over this fear, as it has a deleterious impact on the sales and operational processes and could even lead to a hostile work environment. You may face legal liability if you do not correct the issue immediately. If an employee is telling you they feel intimidated or afraid, that may be a sign of a hostile work environment. 

Such an environment is where an employee experiences unwelcome conduct, usually severe and pervasive, expressed through offensive behavior, harassment, and discrimination that is severe enough to impact their ability to do their jobs. The fallout on company morale, consumer relations, operations, legal and regulatory risk, and public sentiment can adversely affect a company's risk structure. 

When we have done HR Tune-up audits, we occasionally find hostile work environments overtly or covertly taking shape through such conduct as public humiliation or belittlement, unwanted sexual advances or attention, physical threats or intimidation, subjective abuse of the victim, bullying, and jokes and comments related to someone's beliefs and protected characteristics. You should not think that having a company call puts an end to such problems. They rarely do. 

So, here's my advice, take it or leave it. I think you should publish a Code of Ethics and Conduct, which must be consistent with state and federal law, that sets forth your policy concerning zero tolerance for a hostile work environment. If you want, we offer a strong Code of Ethics and Conduct. 

The Code should include procedures to mitigate the risk. The procedures should include the following:

 

1.   Maintaining a detailed record of the harassing behavior, including dates, times, witnesses, and specific details of what happened.

 

2.   Informing a supervisor, HR department, or appropriate authority about the behavior.

 

3.   Bringing in an employment attorney if the offending issue is not addressed adequately. 

You have already made a good start by opening the dialogue and recognizing the challenge. Now, you need to ensure that the fears and feelings of intimidation do not create a hostile work environment. Taking prompt action to prevent and promptly correct any harassment[xii] can lead to a safe workspace, boost morale, and potentially avoid liability. 

Jonathan Foxx, Ph.D., MBA
Chairman & Managing Director 

Lenders Compliance Group

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[i] Since Pandemic Onset, Lumber Products Have Added $14K to House Price, $51 to Rent, Emrath, July 14, 2022, Paul, National Association of Home Builders, https://eyeonhousing.org/2022/07/since-pandemic-onset-lumber-products-have-added-14k-to-house-price-51-to-rent/ 

[ii] See Tax Cuts and Jobs Act of 2017 (TCJA)

[iii] Pending home sales hit seven-month high, McAlinden, Fergal, November 27, 2024, Mortgage Professional (MP), Key Media  https://www.mpamag.com/us/mortgage-industry/market-updates/pending-home-sales-hit-seven-month-high/515737

[iv] Labor Shortages Ease, But Remain Worse Than in the Last Boom, Emrath, Paul, February 23, 2024, National Association of Home Builders, https://eyeonhousing.org/2024/02/labor-shortages-ease-but-remain-worse-than-in-the-last-boom/

[v] Immigrant Share in Construction Sets New Record, Siniavskaia, Natalia, November 20, 2024, National Association of Home Builders, https://eyeonhousing.org/2024/11/immigrant-share-in-construction-sets-new-record/. “In 2023, 11.9 million workers, including both self-employed and temporarily unemployed, comprised the construction workforce. Out of these, 8.9 million were native-born, and 3 million were foreign-born, the highest number of immigrant workers in construction ever recorded by the American Community Survey.”

[vi] The Role of the Recent Immigrant Surge in Housing Costs, Frost, Riordan, October 29, 2024, Joint Center for Housing Studies, Harvard University, https://www.jchs.harvard.edu/blog/role-recent-immigrant-surge-housing-costs

[vii] Op. cit v

[viii] 5 ways Trump's next presidency could affect the U.S. economy — and your money, Picchi, Aimee, November 7, 2024, CBS News, https://www.cbsnews.com/news/trump-election-impact-on-economy-taxes-inflation-your-money/

[ix] Op. cit. v

[x] Trump’s First Broken Promise Will Be 3% Mortgage Rates, Levin, Jonathan, November 6, 2024, Bloomberg, https://www.bloomberg.com/opinion/articles/2024-11-06/trump-s-first-broken-promise-will-be-3-mortgage-rates-election-2024

[xi] What Trump's return to the White House could mean for the economy and taxes, Pettypiece, Shannon, November 6, 2024, NBC News, https://www.nbcnews.com/politics/2024-election/trumps-return-white-house-mean-economy-taxes-rcna177690. "Economists at the University of Pennsylvania estimate Trump’s tax and spending plans would increase the deficit by $4.1 trillion when accounting for the effects they would have on the wider economy."

[xii] Harassment, U.S. Equal Employment Opportunity Commission, https://www.eeoc.gov/harassment