We believe regulatory and investor scrutiny and actions have affected Ocwen Loan Servicing LLC's operations, including consent order actions by the New York Department of Financial Services and the California Department of Business Oversight, as well as various investor allegations and lawsuits. Various internal audit results included high-risk findings in key areas of the residential servicing and default operations. The number and criticality of those findings, in our view, is not consistent with other servicers we rank as AVERAGE. The internal audit department recently experienced turnover and reorganization. While we believe the changes made may be positive, in our view, not enough time has passed to determine their effectiveness. Standard&Poor's Ratings Services' rankings on Ocwen Loan Servicing LLC
