Ocwen has an experienced and tenured management team, solid automation, sound policies and procedures, and improved internal controls; It is an experienced small-balance commercial mortgage servicer, notwithstanding steadily declining portfolio volume; Ocwen has demonstrated expertise in default management and asset management as a small-balance commercial servicer; Large-balance special servicing responsibilities do not include a full range of loan resolution and recovery activity, and its volumes also continue to decline; The company has strengthened its first and second lines of defense; The number and criticality of internal audit findings has declined in the servicing and default operations, though we still continue to note high- and medium-risk findings in the internal audits in key operations areas; While internal control challenges have been
