OVERVIEW We lowered our overall rankings on Ocwen Loan Servicing LLC to BELOW AVERAGE from AVERAGE as a residential mortgage prime, subprime, special, and subordinate-lien servicer, and removed the four rankings from CreditWatch with negative implications. The Outlooks for all four rankings are Stable. We believe regulatory and investor scrutiny and/or actions have affected Ocwen's operations. These have included consent order actions by the New York Department of Financial Services (NY DFS) and the California Department of Business Oversight (CA DBO), and various investor allegations and lawsuits. Various internal audit (IA) results included high-risk findings in key areas of the servicing and default operations. Neither the number nor criticality of those findings, in our view, are consistent with other servicers
