Ocwen has maintained GMAC Residential Funding's very experienced line management and infrastructure. There are significant enhancements in the primary servicer scorecards. Ocwen continues to adjust servicer oversight to manage servicer issues--such as increased modifications and other loss-mitigation alternatives--using data to monitor default and loss mitigation issues. Ocwen addresses issues outside of pooling and servicing agreements (PSAs) such as servicer responsibilities under regulatory requirements, including national mortgage settlements, consent orders, and Consumer Financial Protection Bureau (CFPB) rules. In past acquisitions, Ocwen closed sites and offshored responsibilities; we believe a change in the current management and infrastructure could hurt its performance as a master servicer. Ocwen's senior management (above the master servicing team) is new to master-servicing responsibilities, and to overseeing its
