Strengthened first and second lines of defense; Good management and staff experience levels; Manageable staff and management turnover rates; Improved nonreimbursable tax penalties on par with peers; Investment and continued strengthening of staffing, technology, and processes in the internal control environment; Servicing metrics that are generally competitive with those of the company's peers; Reduction in the number and criticality of internal audit findings 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; Continued monitoring and supervision by the New York Department of Financial Services (NY DFS), California Department of Business Oversight (CA DBO); and Continued National Mortgage Settlement (NMS) monitoring. S&P Global Ratings' overall rankings
