Seasoned and knowledgeable management and staff, with low turnover; Solid servicer oversight performance scorecards that compare and rank each metric against each servicer's peers; The master servicing operations continue to enhance its servicer oversight program to incorporate the Office of the Comptroller of the Currency (OCC) and Federal Reserve guidance on managing vendors, as well as reviewing attorney legal files; Addresses issues outside of pooling and servicing agreements (PSAs) such as servicer responsibilities under regulatory requirements, including compliance with Consumer Financial Protection Bureau (CFPB) rules; Regulatory and investor scrutiny and actions that we believe have affected Ocwen Loan Servicing LLC's primary servicing operations and internal control environment; and Portfolio runoff, with limited new business opportunities in the marketplace, reflecting the
