other sources of revenue include ( i ) net warehouse interest income we earn while the loan is held for sale through one of our warehouse facilities , ( ii ) net warehouse interest income from loans held for investment while they are outstanding , ( iii ) sales commissions for brokering the sale of multifamily properties , and ( iv ) asset management fees from our investment management activities . we retain servicing rights on substantially all the loans we originate and sell , and generate revenues from the fees we receive for servicing the loans , from the interest income on escrow deposits held on behalf of borrowers , and from other ancillary fees . servicing fees set at the time an investor agrees to purchase the loan are generally paid monthly for the duration of the loan and are based on the unpaid principal balance of the loan . our fannie mae and freddie mac servicing arrangements generally provide for prepayment fees to us in the event of a voluntary prepayment . for loans serviced outside of fannie mae and freddie mac , we typically do not share in any such payments . ​ we are currently not exposed to unhedged interest rate risk during the loan commitment , closing , and delivery process . the sale or placement of each loan to an investor is negotiated concurrently with establishing the coupon rate for 25 the loan . we also seek to mitigate the risk of a loan not closing . we have agreements in place with the agencies that specify the cost of a failed loan delivery , in the event we fail to deliver the loan to the investor . to protect us against such fees , we require a deposit from the borrower at rate lock that is typically more than the potential fee . the deposit is returned to the borrower only once the loan is closed . any potential loss from a catastrophic change in the property condition while the loan is held for sale using warehouse facility financing is mitigated through property insurance equal to replacement cost . we are also protected contractually from an investor 's failure to purchase the loan . we have experienced an immaterial number of failed deliveries in our history and have incurred immaterial losses on such failed deliveries . we have risk-sharing obligations on substantially all loans we originate under the fannie mae dus program . when a fannie mae dus loan is subject to full risk-sharing , we absorb losses on the first 5 % of the unpaid principal balance of a loan at the time of loss settlement , and above 5 % we share a percentage of the loss with fannie mae , with our maximum loss capped at 20 % of the original unpaid principal balance of the loan ( subject to doubling or tripling if the loan does not meet specific underwriting criteria or if the loan defaults within 12 months of its sale to fannie mae ) , except for rare instances when we negotiate a cap at 30 % for loans with unique attributes . at december 31 , 2019 , we have had only one such experience . we occasionally request modified risk-sharing based on the size of the loan . during the second quarter of 2018 , fannie mae increased our risk-sharing cap from $ 60.0 million to $ 200.0 million . accordingly , our maximum loss exposure on any one loan is $ 40.0 million ( such exposure would occur if the underlying collateral is determined to be completely without value at the time of loss ) . we may request modified risk-sharing at the time of origination , which reduces our potential risk-sharing losses from the levels described above if we do not believe that we are being fairly compensated for the risks of the transaction . our servicing fees for risk-sharing loans include compensation for the risk-sharing obligations and are larger than the servicing fees we receive from fannie mae for loans with no risk-sharing obligations . our interim program offers floating-rate , interest-only loans for terms of generally up to three years to experienced borrowers seeking to acquire or reposition multifamily properties that do not currently qualify for permanent financing . we underwrite , asset-manage , and service all loans executed through the interim program . the ultimate goal of the interim program is to provide permanent agency financing on these transition properties . the interim program has two distinct executions : held by the interim program jv and held for investment . the interim program jv assumes full risk of loss while the loans it originates are outstanding . we hold a 15 % ownership interest in the interim program jv and are responsible for sourcing , underwriting , servicing , and asset-managing the loans originated by the joint venture . the joint venture funds its operations using a combination of equity contributions from its owners and third-party credit facilities . we originate and hold some interim program loans for investment , which are included on our balance sheet . during the time that these loans are outstanding , we assume the full risk of loss . since we began originating interim loans , we have not charged off any interim program loans . as of december 31 , 2019 , we had 22 loans held for investment under the interim program with an aggregate outstanding unpaid principal balance of $ 546.6 million . one loan , totaling $ 14.7 million , is currently in default , and we are working with the borrower to restructure the loan . during the year ended december 31 , 2019 , $ 436.1 million of the $ 757.2 million of interim loan originations were executed through the joint venture , with the remainder originated through our interim program . story_separator_special_tag 29 the mortgage bankers ' association ( “ mba ” ) recently reported that the amount of commercial and multifamily mortgage debt outstanding continued to grow in the third quarter of 2019 , reaching $ 3.6 trillion , an increase of $ 75.7 billion ( 2.2 % ) from the second quarter of 2019. multifamily mortgage debt outstanding rose by $ 40.6 billion to $ 1.5 trillion as of the end of the third quarter of 2019 , an increase of 2.8 % from the second quarter of 2019. steady household formation and a dearth of supply of entry-level single-family homes have led to strong demand for rental housing and continued increasing rents for multifamily properties in most markets . the positive performance has boosted the value of many multifamily properties towards the high end of historical ranges . according to realpage , a provider of commercial real estate data and analytics , rent growth continued to increase at an average annual pace of 3.0 % during the fourth quarter of 2019 as occupancy rates fell slightly to 95.8 % , from a near all-time high of 96.3 % in the third quarter of 2019. we believe that the market demand for multifamily housing in the upcoming quarters will continue to absorb most of the capacity created by new construction and that vacancy rates will remain near historic lows , continuing to make multifamily properties an attractive investment option . in addition to the healthy property fundamentals , for the last several years , the u.s. commercial real estate and multifamily mortgage market has experienced historically low cost of borrowing , which has further encouraged capital investment into commercial real estate . as borrowers have sought to take advantage of the interest rate environment and strong property fundamentals , the number of investors and amount of capital available to lend have increased . all of these factors have benefited our total transaction volumes over the past several years . competition for lending on commercial and multifamily real estate among commercial real estate services firms , banks , life insurance companies , and the gses remains fierce . the federal reserve lowered the fed funds rate by 50 basis points during the third quarter of 2019 and by 25 basis points during the fourth quarter of 2019 and changed the target rate to 1.50 % - 1.75 % . prior to the rate decreases starting in the third quarter of 2019 , the rate had increased 125 basis points over the previous two years . long-term mortgage interest rates , which form the basis for most of our lending , have remained at relatively low levels throughout this period and have resulted in a flattened yield curve . there remains a significant amount of capital investing in u.s. commercial real estate and multifamily properties resulting from historically low global interest rates and the strong fundamentals of the u.s. commercial real estate and multifamily market . we expect to see continued strength in the multifamily financing market for the foreseeable future due to the underlying fundamentals of the multifamily market as the labor market remains strong , single-family home ownership remains unaffordable for many households , and new household formation fuels rental demand . we are a market-leading originator with fannie mae and freddie mac , and the gses remain the most significant providers of capital to the multifamily market . the federal housing finance agency ( “ fhfa ” ) establishes loan origination caps for both fannie mae and freddie mac each year . in september 2019 , fhfa revised fannie mae 's and freddie mac 's loan origination caps to $ 100.0 billion each for all multifamily business for the five-quarter period beginning with the fourth quarter 2019 through the fourth quarter of 2020. the new caps apply to all multifamily business with no exclusions . the gses reported combined loan origination volume of approximately $ 148.5 billion in 2019 compared to $ 143.3 billion during 2018 , an increase of 3.6 % , with fannie mae and freddie mac volumes growing 7.5 % and 0.4 % , respectively . we expect the gses to maintain their historical market share in a multifamily origination market that is projected by the mba on average to be $ 390 billion in 2020. we believe our market leadership positions us to be a significant lender with the gses for the foreseeable future . our originations with the gses are some of our most profitable executions as they provide significant non-cash gains from msrs that turn into significant cash revenue streams in the future . a decline in our gse originations would negatively impact our financial results as our non-cash revenues would decrease disproportionately with loan origination volume and future servicing fee revenue would be constrained or decline . we continue to significantly grow our debt brokerage platform through hiring and acquisitions to gain greater access to capital , deal flow , and borrower relationships . the apparent appetite for debt funding within the broader commercial real estate market , along with the significant additions of mortgage bankers over the past several years , has resulted in significant growth in our brokered debt financing volume with a 40 % increase in brokered debt financing volume from the fourth quarter of 2018 to the fourth quarter of 2019. our outlook for our debt brokerage platform is positive as we expect 30 continued growth in the commercial and multifamily financing markets in the near future , and we expect to continue adding debt brokers to our platform . during the first quarter of 2019 , the u.s. government was shut down for approximately one month , during which time hud processed no loan commitments . the shutdown negatively impacted the amount of loan originations at hud , which contributed to a decrease of 15 % of 2019 originations compared to 2018. hud remains a strong source of capital for new construction loans and healthcare facilities .

interest expense on corporate debt . interest expense on corporate debt includes interest expense incurred and amortization of debt discount and deferred debt issuance costs related to our term loan facility . other operating expenses . other operating expenses include sub-servicing costs , facilities costs , travel and entertainment costs , marketing costs , professional fees , license fees , dues and subscriptions , corporate insurance premiums , and other administrative expenses . income tax expense . the company is a c-corporation subject to both federal and state corporate tax . as of december 31 , 2019 , our estimated combined statutory federal and state tax rate was approximately 25.0 % compared to approximately 25.1 % as of december 31 , 2018 and 38.2 % as of december 31 , 2017. in december 2017 , the tax cuts and jobs act ( “ tax reform ” ) was enacted . tax reform significantly reduced the federal income tax rate from 35.0 % in 2017 to 21.0 % in 2018. except for the effects of tax reform , our combined statutory tax rate has historically not varied significantly as the only material difference in the calculation of the combined statutory tax rate from year to year is the apportionment of our taxable income amongst the various states where we are subject to taxation since we do not have foreign operations or significant permanent differences . for example , from the period since we went public in 2010 through 2017 , our combined statutory tax rate varied by only 0.7 % , with a low of 38.2 % and a high of 38.9 % . absent additional significant legislative changes to statutory tax rates ( particularly the federal tax rate ) , we expect minimal deviation from the 2019 combined statutory tax rate for future years . however , we do expect some variability in the effective tax rate going forward due to excess tax benefits recognized and limitations on the deductibility of certain book expenses as a result of tax reform , primarily related to executive compensation . excess tax benefits recognized in 2019 , 2018 , and 2017 reduced income tax expense by $ 4.6 million , $ 6.8 million , and $ 9.5 million , respectively .


 Write a concise suspicious activity report of the following text delimited by triple backquotes. Return your response as a formal report which covers the key points highlighting the location,dates,entity names and account holder information in chronological order of the text.
     ```interest expense on corporate debt . interest expense on corporate debt includes interest expense incurred and amortization of debt discount and deferred debt issuance costs related to our term loan facility . other operating expenses . other operating expenses include sub-servicing costs , facilities costs , travel and entertainment costs , marketing costs , professional fees , license fees , dues and subscriptions , corporate insurance premiums , and other administrative expenses . income tax expense . the company is a c-corporation subject to both federal and state corporate tax . as of december 31 , 2019 , our estimated combined statutory federal and state tax rate was approximately 25.0 % compared to approximately 25.1 % as of december 31 , 2018 and 38.2 % as of december 31 , 2017. in december 2017 , the tax cuts and jobs act ( “ tax reform ” ) was enacted . tax reform significantly reduced the federal income tax rate from 35.0 % in 2017 to 21.0 % in 2018. except for the effects of tax reform , our combined statutory tax rate has historically not varied significantly as the only material difference in the calculation of the combined statutory tax rate from year to year is the apportionment of our taxable income amongst the various states where we are subject to taxation since we do not have foreign operations or significant permanent differences . for example , from the period since we went public in 2010 through 2017 , our combined statutory tax rate varied by only 0.7 % , with a low of 38.2 % and a high of 38.9 % . absent additional significant legislative changes to statutory tax rates ( particularly the federal tax rate ) , we expect minimal deviation from the 2019 combined statutory tax rate for future years . however , we do expect some variability in the effective tax rate going forward due to excess tax benefits recognized and limitations on the deductibility of certain book expenses as a result of tax reform , primarily related to executive compensation . excess tax benefits recognized in 2019 , 2018 , and 2017 reduced income tax expense by $ 4.6 million , $ 6.8 million , and $ 9.5 million , respectively .
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 Suspicious Activity Report : other sources of revenue include ( i ) net warehouse interest income we earn while the loan is held for sale through one of our warehouse facilities , ( ii ) net warehouse interest income from loans held for investment while they are outstanding , ( iii ) sales commissions for brokering the sale of multifamily properties , and ( iv ) asset management fees from our investment management activities . we retain servicing rights on substantially all the loans we originate and sell , and generate revenues from the fees we receive for servicing the loans , from the interest income on escrow deposits held on behalf of borrowers , and from other ancillary fees . servicing fees set at the time an investor agrees to purchase the loan are generally paid monthly for the duration of the loan and are based on the unpaid principal balance of the loan . our fannie mae and freddie mac servicing arrangements generally provide for prepayment fees to us in the event of a voluntary prepayment . for loans serviced outside of fannie mae and freddie mac , we typically do not share in any such payments . ​ we are currently not exposed to unhedged interest rate risk during the loan commitment , closing , and delivery process . the sale or placement of each loan to an investor is negotiated concurrently with establishing the coupon rate for 25 the loan . we also seek to mitigate the risk of a loan not closing . we have agreements in place with the agencies that specify the cost of a failed loan delivery , in the event we fail to deliver the loan to the investor . to protect us against such fees , we require a deposit from the borrower at rate lock that is typically more than the potential fee . the deposit is returned to the borrower only once the loan is closed . any potential loss from a catastrophic change in the property condition while the loan is held for sale using warehouse facility financing is mitigated through property insurance equal to replacement cost . we are also protected contractually from an investor 's failure to purchase the loan . we have experienced an immaterial number of failed deliveries in our history and have incurred immaterial losses on such failed deliveries . we have risk-sharing obligations on substantially all loans we originate under the fannie mae dus program . when a fannie mae dus loan is subject to full risk-sharing , we absorb losses on the first 5 % of the unpaid principal balance of a loan at the time of loss settlement , and above 5 % we share a percentage of the loss with fannie mae , with our maximum loss capped at 20 % of the original unpaid principal balance of the loan ( subject to doubling or tripling if the loan does not meet specific underwriting criteria or if the loan defaults within 12 months of its sale to fannie mae ) , except for rare instances when we negotiate a cap at 30 % for loans with unique attributes . at december 31 , 2019 , we have had only one such experience . we occasionally request modified risk-sharing based on the size of the loan . during the second quarter of 2018 , fannie mae increased our risk-sharing cap from $ 60.0 million to $ 200.0 million . accordingly , our maximum loss exposure on any one loan is $ 40.0 million ( such exposure would occur if the underlying collateral is determined to be completely without value at the time of loss ) . we may request modified risk-sharing at the time of origination , which reduces our potential risk-sharing losses from the levels described above if we do not believe that we are being fairly compensated for the risks of the transaction . our servicing fees for risk-sharing loans include compensation for the risk-sharing obligations and are larger than the servicing fees we receive from fannie mae for loans with no risk-sharing obligations . our interim program offers floating-rate , interest-only loans for terms of generally up to three years to experienced borrowers seeking to acquire or reposition multifamily properties that do not currently qualify for permanent financing . we underwrite , asset-manage , and service all loans executed through the interim program . the ultimate goal of the interim program is to provide permanent agency financing on these transition properties . the interim program has two distinct executions : held by the interim program jv and held for investment . the interim program jv assumes full risk of loss while the loans it originates are outstanding . we hold a 15 % ownership interest in the interim program jv and are responsible for sourcing , underwriting , servicing , and asset-managing the loans originated by the joint venture . the joint venture funds its operations using a combination of equity contributions from its owners and third-party credit facilities . we originate and hold some interim program loans for investment , which are included on our balance sheet . during the time that these loans are outstanding , we assume the full risk of loss . since we began originating interim loans , we have not charged off any interim program loans . as of december 31 , 2019 , we had 22 loans held for investment under the interim program with an aggregate outstanding unpaid principal balance of $ 546.6 million . one loan , totaling $ 14.7 million , is currently in default , and we are working with the borrower to restructure the loan . during the year ended december 31 , 2019 , $ 436.1 million of the $ 757.2 million of interim loan originations were executed through the joint venture , with the remainder originated through our interim program . story_separator_special_tag 29 the mortgage bankers ' association ( “ mba ” ) recently reported that the amount of commercial and multifamily mortgage debt outstanding continued to grow in the third quarter of 2019 , reaching $ 3.6 trillion , an increase of $ 75.7 billion ( 2.2 % ) from the second quarter of 2019. multifamily mortgage debt outstanding rose by $ 40.6 billion to $ 1.5 trillion as of the end of the third quarter of 2019 , an increase of 2.8 % from the second quarter of 2019. steady household formation and a dearth of supply of entry-level single-family homes have led to strong demand for rental housing and continued increasing rents for multifamily properties in most markets . the positive performance has boosted the value of many multifamily properties towards the high end of historical ranges . according to realpage , a provider of commercial real estate data and analytics , rent growth continued to increase at an average annual pace of 3.0 % during the fourth quarter of 2019 as occupancy rates fell slightly to 95.8 % , from a near all-time high of 96.3 % in the third quarter of 2019. we believe that the market demand for multifamily housing in the upcoming quarters will continue to absorb most of the capacity created by new construction and that vacancy rates will remain near historic lows , continuing to make multifamily properties an attractive investment option . in addition to the healthy property fundamentals , for the last several years , the u.s. commercial real estate and multifamily mortgage market has experienced historically low cost of borrowing , which has further encouraged capital investment into commercial real estate . as borrowers have sought to take advantage of the interest rate environment and strong property fundamentals , the number of investors and amount of capital available to lend have increased . all of these factors have benefited our total transaction volumes over the past several years . competition for lending on commercial and multifamily real estate among commercial real estate services firms , banks , life insurance companies , and the gses remains fierce . the federal reserve lowered the fed funds rate by 50 basis points during the third quarter of 2019 and by 25 basis points during the fourth quarter of 2019 and changed the target rate to 1.50 % - 1.75 % . prior to the rate decreases starting in the third quarter of 2019 , the rate had increased 125 basis points over the previous two years . long-term mortgage interest rates , which form the basis for most of our lending , have remained at relatively low levels throughout this period and have resulted in a flattened yield curve . there remains a significant amount of capital investing in u.s. commercial real estate and multifamily properties resulting from historically low global interest rates and the strong fundamentals of the u.s. commercial real estate and multifamily market . we expect to see continued strength in the multifamily financing market for the foreseeable future due to the underlying fundamentals of the multifamily market as the labor market remains strong , single-family home ownership remains unaffordable for many households , and new household formation fuels rental demand . we are a market-leading originator with fannie mae and freddie mac , and the gses remain the most significant providers of capital to the multifamily market . the federal housing finance agency ( “ fhfa ” ) establishes loan origination caps for both fannie mae and freddie mac each year . in september 2019 , fhfa revised fannie mae 's and freddie mac 's loan origination caps to $ 100.0 billion each for all multifamily business for the five-quarter period beginning with the fourth quarter 2019 through the fourth quarter of 2020. the new caps apply to all multifamily business with no exclusions . the gses reported combined loan origination volume of approximately $ 148.5 billion in 2019 compared to $ 143.3 billion during 2018 , an increase of 3.6 % , with fannie mae and freddie mac volumes growing 7.5 % and 0.4 % , respectively . we expect the gses to maintain their historical market share in a multifamily origination market that is projected by the mba on average to be $ 390 billion in 2020. we believe our market leadership positions us to be a significant lender with the gses for the foreseeable future . our originations with the gses are some of our most profitable executions as they provide significant non-cash gains from msrs that turn into significant cash revenue streams in the future . a decline in our gse originations would negatively impact our financial results as our non-cash revenues would decrease disproportionately with loan origination volume and future servicing fee revenue would be constrained or decline . we continue to significantly grow our debt brokerage platform through hiring and acquisitions to gain greater access to capital , deal flow , and borrower relationships . the apparent appetite for debt funding within the broader commercial real estate market , along with the significant additions of mortgage bankers over the past several years , has resulted in significant growth in our brokered debt financing volume with a 40 % increase in brokered debt financing volume from the fourth quarter of 2018 to the fourth quarter of 2019. our outlook for our debt brokerage platform is positive as we expect 30 continued growth in the commercial and multifamily financing markets in the near future , and we expect to continue adding debt brokers to our platform . during the first quarter of 2019 , the u.s. government was shut down for approximately one month , during which time hud processed no loan commitments . the shutdown negatively impacted the amount of loan originations at hud , which contributed to a decrease of 15 % of 2019 originations compared to 2018. hud remains a strong source of capital for new construction loans and healthcare facilities .

