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; 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; Improved internal control environment of Ocwen's primary servicing operations and the internal audit department, which provides some oversight of the master servicer; Internal audit cycle was updated to review the master servicing operations annually; No Regulation AB or Uniform Single Attestation Program (USAP) items noted in the past eight years and no material internal audit findings; and Portfolio runoff, with limited new business opportunities in the marketplace, reflecting the slow securitization
