Sound senior and middle management experience levels, along with low turnover; Internal controls were further strengthened through the establishment of the company's own internal audit (IA) function and a compliance integration unit, in addition to other existing mechanisms such as quality control (QC) reviews, and a Statement on Standards for Attestation Engagements No. 16 (SSAE 16) examination; Comprehensive policies and procedures; Good technology, which was further enhanced over the past 18 months; Strengthening of various validation functions in the new loan boarding area; Servicing metrics that are mainly competitive with similar peers; Improvements introduced in loss mitigation through additional oversight; IAs conducted infrequently; and No onsite reviews of the attorney network, although management plans to implement such a program shortly.
