President Donald Trump used the accusation as a basis to seek her firing.

It was the first time a president has sought to remove a Fed governor in the central bank’s 112-year history. Cook sued to keep her job, and the Supreme Court ruled last month that she could remain in the position while she fights the administration in court. The Supreme Court has said it would hear arguments in the case in January.

The letter to Bondi was the first comprehensive response to a criminal referral in August by Bill Pulte, director of the Federal Housing Finance Agency. Pulte has made several other mortgage fraud accusations against leading Democrats, including New York Attorney General Letitia James, Sen. Adam Schiff of California, and California Rep. Eric Swalwell.

Cook’s attorney, Abbe Lowell, wrote that the case against Cook largely rests on “one stray reference” in a 2021 mortgage document that was “plainly innocuous in light of the several other truthful and more specific disclosures” about the homes she has purchased.

“There is no fraud, no intent to deceive, nothing whatsoever criminal or remotely a basis to allege mortgage fraud,” the letter said.

Cook is the first Black woman to serve on the Fed’s governing board, and was appointed in 2022 by President Joe Biden. Trump’s attempt to fire her has occurred as he has also repeatedly demanded the Fed reduce its key interest rate.

The Justice Department and FHFA did not immediately respond to emails seeking comment.

In August, Pulte accused Cook of committing mortgage fraud by declaring two different homes — one in Ann Arbor, Michigan, the other in Atlanta — as her “primary residence.” Such declarations can result in lower mortgage rates or a smaller down payment requirement than if a property is declared to be a second or vacation home.

“Do not declare two principal residences in President Trump’s America,” Pulte said Aug. 20 on social media platform X. “Mortgage fraud is a serious crime and must be prosecuted as such.”

Pulte made a criminal referral to the Justice Department that month, and followed up with a second referral on a third property in Cambridge, Massachusetts. Pulte alleged that Cook also classified that property as a primary residence, even though she rented it out.

Lowell argued in his Monday letter than Cook has mostly lived in the Ann Arbor property since first purchasing it in 2005. As a result, it was accurate for her to refer to it as her “primary residence” in a June 2021 application to refinance its mortgage, the letter said.

A month later she purchased a condominium in Atlanta, and in a July 2021 document also referred to it as her “primary residence.” Lowell said that it was an “isolated notation” that did not reflect an intent to defraud. An earlier mortgage application to the same lender in May 2021 had referred to the Atlanta condo as a “vacation home,” Lowell said. Cook also referred to it as a second home in other documents she submitted during her confirmation as Fed governor.

“It would be impossible to conclude that she intended to defraud the lender by inadvertently listing the property as her ‘Primary Residence,’” the letter said.

Lowell wrote that there was similarly no fraud involved in the Cambridge home, which she obtained while working as an economist for Harvard University.

Cook worked for the school for roughly five years when she bought the home in 2002 and obtained a mortgage that listed it as her primary residence. It remained her primary residence until she was hired as a tenure-track academic by Michigan State University and moved, Lowell said. She refinanced the Cambridge property in 2021 and redesignated it as a second-home, according to mortgage documents provided by Lowell.

On financial filings submitted to the government in connection with her nomination to the Fed, Cook also disclosed the home as a rental property and second home, the letter said.

“Once again, Director Pulte offers no evidence indicating that Governor Cook had the ‘required specific intent to defraud’ in relation to the Cambridge property,” Lowell wrote. “ On the contrary, when Governor Cook refinanced the Cambridge property, she updated the mortgage to reflect that it was no longer her primary residence.”