OVERVIEW We affirmed our AVERAGE commercial mortgage special servicer ranking on Ocwen Loan Servicing LLC (OLS). The ranking reflects our opinion of the company's successful track record of managing REO asset management and disposition activity for a major government-sponsored entity (GSE). We believe OLS' combination of low U.S.-based employee turnover, its structured internal audit and quality control programs, and solid technology base contribute to a stable servicing environment. Employees in offshore locations generally possess lower levels of industry experience and company tenure; however, we acknowledge this situation is somewhat common among U.S.-based commercial mortgage servicers operating in foreign locations. NEW YORK (Standard&Poor's) Nov. 19, 2013--Standard&Poor's Ratings Services today affirmed its AVERAGE ranking on Ocwen Loan Servicing