A stabilized internal control environment that continues to develop; No reportable commercial servicing audit issues, as well as a continued reduction in critical and high internal audit findings within residential operations; Experienced management and staff; A recent history of elevated turnover, albeit turnover rates since our last review have leveled off during the first-half of 2017; A demonstrated expertise in small-balance commercial loan servicing, default management, and asset management, notwithstanding steadily declining portfolio volume; The settlement of certain high profile state, federal and investor actions outstanding, but there is ongoing regulatory scrutiny from state and federal banking and financial regulators; The New York Department of Financial Services' (NY DFS) continued regulatory activities, as part of its March 2017 consent order,
