Judicial Notice of Ocwen Financial Charges of Forgery

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NEW YORK STATE

DEPARTMENT OF FINANCIAL SERVICES
In the Matter of
OCWEN FINANCIAL CORPORATION,
OCWEN LOAN SERVICING, LLC
CONSENT ORDER PURSUANT TO NEW YORK BANKING LAW 44

The New York State Department of Financial Services (the Department) and Ocwen
Financial Corporation, the parent company of Ocwen Loan Servicing, LLC (together, Ocwen),
(collectively, the Parties) stipulate that:
WHEREAS, Ocwen is the fourth largest mortgage loan servicer and the largest servicer
of subprime loans in the United States, servicing an unpaid principal balance (UPB) of
approximately $430 billion. In New York alone, Ocwen services nearly 130,000 residential
home loans with a total UPB of more than $30 billion.
WHEREAS, Ocwen is a New York State-licensed mortgage banker and mortgage loan
servicer, pursuant to the New York Banking Law, and the Department is responsible for its
supervision and regulation;
WHEREAS, in the last five years, Ocwen has acquired mortgage servicing rights
(MSRs) for hundreds of billions of dollars in UPB from several major servicers, including
Litton Loan Servicing LP (Litton), Saxon Mortgage Services, Inc. (Saxon), and Homeward
Residential Holdings, Inc. (Homeward);
WHEREAS, in 2010 and 2011, the multistate examinations of Ocwen, Litton, and
Homeward identified numerous and significant violations of New York State laws and
regulations;
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WHEREAS, on September 1, 2011, in connection with Ocwens acquisition of Litton

and amid concerns regarding Ocwens rapid growth and capacity to properly acquire and service
a significant portfolio of distressed home loans, Ocwen and the Department entered into an
Agreement on Mortgage Servicing Practices (the 2011 Agreement), which required Ocwen to
adhere to certain servicing practices in the best interest of borrowers and investors;
WHEREAS, a June 2012 targeted examination of Ocwen revealed that Ocwen violated
the 2011 Agreement;
WHEREAS, as a result of Ocwens violation of the 2011 Agreement, Ocwen entered
into a Consent Order with the Department on December 5, 2012, which required Ocwen to retain
an independent compliance monitor (the Compliance Monitor) for two years to conduct a
comprehensive review of Ocwens servicing operations;
WHEREAS, the Department and the Compliance Monitor identified numerous and
significant additional violations of the 2011 Agreement, as well as New York State laws and
regulations;
NOW, THEREFORE, to resolve this matter, the Parties agree to the following:
Facts
1.
Ocwen has grown more than ten-fold in the last several years. Beginning in 2009,
Ocwen significantly expanded its servicing operations through the acquisition of several major
servicers of home loans, as well as the acquisition of MSRs for hundreds of billions of dollars in
UPB. From the end of 2009 to the end of 2013, Ocwens servicing portfolio grew from 351,595
residential loans with an aggregate UPB of $50 billion to 2,861,918 residential loans with an
aggregate UPB of $464.7 billion.
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2.
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In 2010 and 2011, the Department participated in a multistate examination of
Ocwen, as well as examinations of Litton and Homeward, the entities ultimately acquired by
Ocwen. The examination of Ocwen identified, among other things, deficiencies in Ocwens
servicing platform and loss mitigation infrastructure, including (a) robo-signing, (b) inaccurate
affidavits and failure to properly validate document execution processes, (c) missing
documentation, (d) wrongful foreclosure, (e) failure to properly maintain books and records, and
(f) initiation of foreclosure actions without proper legal standing.
3.
The examinations of Litton and Homeward identified substantial deficiencies,
weaknesses, and violations of laws and regulations relating to, among other things, foreclosure
governance, implementation of modification programs, record keeping, required notifications,
and the charging of unallowable fees.
4.
The examination of Litton also revealed that, prior to Ocwens acquisition of
Litton, members of Littons information technology staff falsified documents provided to the
Department during the review of Littons information technology infrastructure.
5.
In connection with Ocwens acquisition of Litton in 2011 and in light of the
examination findings for both Ocwen and Litton, the Department sought to ensure that Ocwen
had sufficient capacity to properly acquire and manage a significant portfolio of distressed loans,
including the ability to effectively manage the increased volume and comply with requirements
under the federal Home Affordable Modification Program, internal loss mitigation policies and
procedures, and laws and regulations governing mortgage loan servicing and foreclosure
activities.
6.
To that end, Ocwen and the Department entered into an Agreement on Mortgage
Servicing Practices on September 1, 2011, which required Ocwen to: (a) establish and maintain
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sufficient capacity to properly acquire and manage its significant portfolio of distressed loans to
ensure a smooth borrower transition; (b) engage in sound document execution and retention
practices to ensure that mortgage files are accurate, complete, and reliable; and (c) implement a
system of robust internal controls and oversight with respect to mortgage servicing practices
performed by its staff and third party vendors to prevent improper foreclosures and maximize
struggling borrowers opportunities to keep their homes.
7.
In June 2012, the Department conducted a targeted examination of Ocwen to
assess its compliance with the 2011 Agreement and Part 419 of the Superintendents
Regulations, which governs business conduct rules for servicers. The examination identified
gaps in the servicing records of certain loans that indicated repeated non-compliance by Ocwen,
including: (a) failing to send borrowers a 90-day notice prior to commencing a foreclosure
action as required under New York Real Property Actions and Proceedings Law (RPAPL)
1304, (b) commencing foreclosure actions on subprime loans without affirmatively alleging in
the complaint that Ocwen had standing to bring the foreclosure action as required by RPAPL
1302, and (c) commencing foreclosure actions without sufficient documentation of its standing
to do so.
8.
The targeted examination also identified instances that indicated widespread non-
compliance with the 2011 Agreement including: (a) failing to provide borrowers with the direct
contact information for their designated single point of contact, a customer care representative
whose role is to understand each assigned borrowers circumstances and history to ensure that
the borrower receives efficient and consistent customer care; (b) dual-tracking; (c) failing to
conduct an independent review of loan modification denials; (d) failing to demonstrate adoption
of policies and procedures to effectively track sanctioned third-party vendors, including local
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foreclosure counsel; (e) failing to demonstrate implementation of policies and procedures to

verify borrower information on newly boarded accounts to accurately reflect the status and
current balance of the borrowers account; and (f) failing to ensure that trial or permanent
modifications granted to borrowers by a prior servicer are honored upon transfer to Ocwen.
9.
Consequently, on December 5, 2012, Ocwen entered into a Consent Order with
the Department, which required Ocwen to retain an independent compliance monitor for two
years. The Consent Order mandated that the Compliance Monitor, which would report directly
to the Department, would conduct a comprehensive review . . . of Ocwens servicing
operations, including its compliance program and operational policies and procedures. The
review would, at a minimum, consider (a) the adequacy of Ocwens staffing levels, (b) the
robustness of Ocwens established policies and procedures, (c) the fairness of servicing fees and
foreclosure charges, (d) the accuracy of borrower account information, (e) Ocwens compliance
with federal and state law, (f) borrower complaints and recordings of customer service, and (g)
Ocwens compliance with the Agreement.
10.
The Compliance Monitor began work in July 2013.
11.
In the course of the Compliance Monitors review, it identified numerous and
significant violations of the 2011 Agreement, as well as New York State laws and regulations.
12.
For example, a limited review by the Compliance Monitor of 478 New York loans
that Ocwen had foreclosed upon revealed 1,358 violations of Ocwens legal obligations, or about
three violations per foreclosed loan. These violations included:
failing to confirm that it had the right to foreclose before initiating foreclosure
proceedings;
failing to ensure that its statements to the court in foreclosure proceedings were
correct;
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pursuing foreclosure even while modification applications were pending (dual

tracking);
failing to maintain records confirming that it is not pursuing foreclosure of
servicemembers on active duty; and
failing to assign a designated customer care representative.
13.
The Department and the Compliance Monitor also identified, among other things,
(a) inadequate and ineffective information technology systems and personnel, and (b) widespread
conflicts of interest with related parties.
Inadequate and Ineffective Information Technology Systems and Personnel
14.
In the course of its review, the Compliance Monitor determined that Ocwens
information technology systems are a patchwork of legacy systems and systems inherited from
acquired companies, many of which are incompatible. A frequent occurrence is that a fix to one
system creates unintended consequences in other systems. As a result, Ocwen regularly gives
borrowers incorrect or outdated information, sends borrowers backdated letters, unreliably tracks
data for investors, and maintains inaccurate records. There are insufficient controls in place
either manual or automatedto catch all of these errors and resolve them.
15.
For example, Ocwens systems have been backdating letters for years. In many
cases, borrowers received a letter denying a mortgage loan modification, and the letter was dated
more than 30 days prior to the date that Ocwen mailed the letter. These borrowers were given 30
days from the date of the denial letter to appeal that denial, but those 30 days had already elapsed
by the time they received the backdated letter. In other cases, Ocwens systems show that
borrowers facing foreclosure received letters with a date by which to cure their default and avoid
foreclosureand the cure date was months prior to receipt of the letter. Ocwens processes
failed to identify and remedy these errors.
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16.
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Moreover, Ocwen failed to fully investigate and appropriately address the
backdating issue when an employee questioned the accuracy of Ocwens letter dating processes
and alerted the companys Vice President of Compliance. Ocwen ignored the issue for five
months until the same employee raised it again. While Ocwen then began efforts to address the
backdating issue, its investigation was incomplete and Ocwen has not fully resolved the issue to
date, more than a year after its initial discovery.
17.
Ocwens core servicing functions rely on its inadequate systems. Specifically,
Ocwen uses comment codes entered either manually or automatically to service its portfolio;
each code initiates a process, such as sending a delinquency letter to a borrower, or referring a
loan to foreclosure counsel. With Ocwens rapid growth and acquisitions of other servicers, the
number of Ocwens comment codes has ballooned to more than 8,400 such codes. Often, due to
insufficient integration following acquisitions of other servicers, there are duplicate codes that
perform the same function. The result is an unnecessarily complex system of comment codes,
including, for example, 50 different codes for the single function of assigning a struggling
borrower a designated customer care representative.
18.
Despite these issues, Ocwen continues to rely on those systems to service its
portfolio of distressed loans. Ocwens reliance on technology has led it to employ fewer trained
personnel than its competitors. For example, Ocwens Chief Financial Officer recently
acknowledged, in reference to its offshore customer care personnel, that Ocwen is simply
training people to read the scripts and the dialogue engines with feeling. Ocwens policy is to
require customer support staff to follow the scripts closely, and Ocwen penalizes and has
terminated customer support staff who fail to follow the scripts that appear on their computer
screens. In some cases, this policy has frustrated struggling borrowers who have complex issues
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that exceed the bounds of a script and have issues speaking with representatives at Ocwen
capable of addressing their concerns. Moreover, Ocwens customer care representatives in many
cases provide conflicting responses to a borrowers question. Representatives have also failed in
many cases to record in Ocwens servicing system the nature of the concerns that a borrower has
expressed, leading to inaccurate records of the issues raised by the borrower.
19.
Ocwens inadequate infrastructure and ineffective personnel have resulted in
Ocwens failure to fulfill its legal obligations. Prior to the Departments and the Compliance
Monitors review, Ocwen did not take adequate steps to implement reforms that it was legally
obligated to implement pursuant to the 2011 Agreement.
Widespread Conflicts of Interest with Related Parties
20.
The Departments review of Ocwens mortgage servicing practices also
uncovered a number of conflicts of interest between Ocwen and four other public companies (the
related parties),1 all of which are chaired by Mr. Erbey, who is also the largest individual
shareholder of each and the Executive Chairman of Ocwen. In addition to serving as chairman
of the board for Ocwen and each related company, Mr. Erbeys holdings in these companies total
more than $1 billion. Other Ocwen executives and directors also own significant investments in
both Ocwen and the related parties. Yet, Ocwen does not have a written policy that explicitly
requires potentially conflicted employees, officers, or directors to recuse themselves from
involvement in transactions with the related companies.
The related parties are, as of the date of this Consent Order, Altisource Portfolio Solutions, S.A.
(Altisource Portfolio), Altisource Residential Corporation, Altisource Asset Management Corporation,
and Home Loan Servicing Solutions Ltd., and any of their affiliates, predecessors and successors in
interest, both past and present, and any of their officers, directors, partners, employees, consultants,
representatives, and agents or other persons and entities acting under their control or on their behalf.
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21.
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Despite Mr. Erbeys holdings in these companies, Mr. Erbey has not in fact
recused himself from approvals of several transactions with the related parties. Mr. Erbey, who
owns approximately 15% of Ocwens stock, and nearly double that percentage of the stock of
Altisource Portfolio, has participated in the approval of a number of transactions between the
two companies or from which Altisource received some benefit, including the renewal of
Ocwens forced placed insurance program in early 2014.
22.
Ocwens close business relationship with related companies is particularly evident
in its relationship with Altisource Portfolio, which has dozens of subsidiaries that perform feebased services for Ocwen. In one example, Altisource Portfolio subsidiary Hubzu, an online
auction site, hosts nearly all Ocwen auctions. In certain circumstances, Hubzu has charged more
for its services to Ocwen than to other customerscharges which are then passed on to
borrowers and investors. Moreover, Ocwen engages Altisource Portfolio subsidiary REALHome
Services and Solutions, Inc. as its default real estate agency for short sales and investor-owned
properties, even though this agency principally employs out-of-state agents who do not perform
the onsite work that local agents perform, at the same cost to borrowers and investors.
23.
Conflicts of interest are evident at other levels of the Ocwen organization. For
example, during its review, the Monitor discovered that Ocwens Chief Risk Officer
concurrently served as the Chief Risk Officer of Altisource Portfolio. The Chief Risk Officer
reported directly to Mr. Erbey in both capacities. This individual seemed not to appreciate the
potential conflicts of interest posed by this dual role, which was of particular concern given his
role as Chief Risk Officer.
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Settlement Provisions
Monetary Payment
24.
Ocwen will pay the amount of $150 million as follows:

a. $100 million paid to the Department by December 31, 2014, as a civil monetary
penalty pursuant to New York Banking Law 44, to be used by the State of New
York for housing, foreclosure relief, and community redevelopment programs
supporting New Yorks housing recovery; and
b. $50 million deposited into an interest-bearing escrow account by December 31,
2014, to be paid as restitution to current and former Ocwen-serviced borrowers in
New York, as follows:
i. $10,000 to each borrower whose home was foreclosed upon by Ocwen
between January 1, 2009, and the date of this Consent Order; and
ii. The balance of the $50 million to be distributed equally among borrowers
who had foreclosure actions filed against them by Ocwen between January
1, 2009, and the date of this Consent Order, but in which Ocwen did not
complete such foreclosure.
25.
Ocwen agrees that it will not claim, assert, or apply for a tax deduction or tax
credit with regard to any U.S. federal, state, or local tax, directly or indirectly, for any portion of
the amount paid pursuant to this Consent Order.
Borrower Assistance
26.
For borrowers receiving payments pursuant to Paragraph 24(b)(ii), Ocwen will
evaluate such borrowers for all applicable modifications and other foreclosure alternatives in
light of their improved financial condition resulting from such payment.
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Beginning sixty (60) days after the date of execution of the Consent Order, and
for a period of two years thereafter, Ocwen will provide upon request by a New York borrower
that borrowers complete loan file, which includes all information from all systems, including
comment codes, at no cost to the borrower, regardless of whether such borrowers loan is still
serviced by Ocwen.
28.
Beginning sixty (60) days after the date of execution of the Consent Order,
Ocwen will provide every New York borrower who is denied a modification, short sale, or deedin-lieu of foreclosure, a detailed explanation of the reasons for denial.
29.
Beginning sixty (60) days after the date of execution of this Consent Order, for all
New York borrowers who have been reported negatively by Ocwen to credit agencies since
January 1, 2010, Ocwen will provide upon request at no cost a copy of such borrowers credit
report (including credit scores) no more than once a year, regardless of whether such borrowers
loan is still serviced by Ocwen. Ocwen will make sufficient staff available for borrowers to
inquire about their credit reporting and will dedicate the resources necessary to investigate such
inquiries and promptly correct any errors.
30.
The Operations Monitor will oversee Ocwens compliance with these borrower
assistance provisions and will work with Ocwen to develop appropriate procedures for such
compliance.
Operations Monitor
31.
The Department will select in its sole discretion an independent on-site operations
monitor (the Operations Monitor) that will report directly to the Department.
32.
The Operations Monitor will review and assess the adequacy and effectiveness of
Ocwens operations. Such an assessment will include but is not limited to the following areas:
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a. Information technology systems and personnel, including with respect to record

keeping and borrower communications;
b. Number of personnel and the training and expertise of its personnel in all
servicing operations;
c. Onboarding process for newly acquired mortgage servicing rights, including
Ocwens ability to onboard newly acquired MSRs without interruption to
servicing newly acquired loans or its existing loan portfolio;
d. Controls in identifying and correcting errors made by Ocwens personnel or
systems;
e. Risk management functions;
f. Contracts or proposed contracts with third parties, including but not limited to
related parties;
g. Fees charged by Ocwen to borrowers or mortgage investors; and
h. The Ocwen borrower experience.
33.
The Operations Monitor will identify the criteria for determining what constitutes
a related party for purposes of compliance with this Consent Order.

34.
The purview of the Operations Monitor will extend to all matters directly or
indirectly affecting New York borrowers, including matters that affect borrowers in all states or
in multiple states that include New York.
35.
The Operations Monitor will identify needed corrective measures to address
identified weaknesses and deficiencies in Ocwens operations, make recommendations to Ocwen

and to the Superintendent, and oversee implementation of reforms. The Operations Monitor will
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also develop benchmarks against which to assess Ocwens progress in complying with
recommended corrective measures.
36.
The Operations Monitor will review and assess Ocwens current committees of
the Board of Directors. Ocwen Financial Corporations Board of Directors (the Board) will
consult with the Operations Monitor concerning, among other things, the structure, composition,
and reporting lines of such committees, and whether certain committees should be either
disbanded or created.
37.
The Board will consult with the Operations Monitor to determine which decisions
should be committed to the specific oversight of the Boards independent directors, or a

committee comprised of such independent directors, including, but not limited to:
a. Approval of transactions with related parties;
b. Approval of transactions to acquire mortgage servicing rights, sub-servicing
rights, or otherwise to increase the number of loans serviced by Ocwen;
c. Approval of new relationships with third-party vendors;
d. Determinations as to whether Ocwens servicing, compliance, and information
technology functions are adequately staffed;
e. Determinations as to whether Ocwens servicing, compliance, and information
technology personnel are adequately trained;
f. Determinations as to whether Ocwens information technology infrastructure and
ongoing investment in information technology systems are adequate;
g. Determinations as to whether Ocwen is adequately addressing the issues
identified by the Operations Monitor and the Compliance Monitor; and
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h. Determinations as to whether Ocwen is treating borrowers fairly and is

communicating with borrowers appropriately.
38.
The Board will consult with the Operations Monitor to determine whether any
member of senior management should be terminated or whether additional officers should be

retained to achieve the goals of complying with this Consent Order, and all applicable laws,
regulations, and agreements, as well as creating a corporate culture of ethics, integrity,
compliance, and responsiveness to borrowers.
39.
Ocwen may acquire MSRs upon (a) meeting benchmarks developed by the
Operations Monitor concerning the adequacy of Ocwens onboarding process for newly acquired
MSRs and its ability to adequately service both those newly acquired MSRs and its existing loan
portfolio, and (b) the Departments approval, not to be unreasonably withheld. The Operations
Monitor will act with reasonable expedition to develop such benchmarks in consultation with
Ocwen. These benchmarks will address, at a minimum, the following:
a. The development and implementation of a satisfactory compliance plan;
b. The development and implementation of a plan to resolve record-keeping and
borrower communication issues;
c. The reasonableness of fees and expenses charged to borrowers and mortgage
investors, including those charged directly or indirectly by related parties;
d. The development and performance of a risk assessment to identify potential risks
and deficiencies in the onboarding process; and
e. The development of a written onboarding plan that addresses potential risks and
deficiencies, including testing and quality control review periodically during the
onboarding process.
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40.
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The Operations Monitor will semi-annually review and approve Ocwens
benchmark pricing and performance studies with respect to all fees or expenses charged to New
York borrowers by any related party.
41.
The Operations Monitor will oversee and ensure Ocwens implementation and
adherence to the terms of this Consent Order.

42.
Within one hundred twenty (120) days of the date of the formal engagement of
the Operations Monitor, the Operations Monitor will submit to the Parties a preliminary written
report of findings, including, to the extent the Operations Monitor has had the opportunity to
develop them, any proposed corrective measures and associated benchmarks (the Operations
Report). The Operations Monitor will submit written monthly action progress reports
(Progress Reports) to the Parties. On a quarterly basis, starting ninety (90) days from the date
of the first Operations Report, the Operations Monitor will issue an Operations Report covering
the three-month period immediately preceding.
43.
Ocwen agrees to cooperate fully with the Operations Monitor by, including but
not limited to, providing the Operations Monitor access to all relevant personnel and records
necessary on a real-time basis, including those at any overseas locations, and including
information on business decisions pertinent to the work of the Operations Monitor currently
pending or recently made by Ocwen management or its Board of Directors, to allow the
Operations Monitor to fulfill its duties.
44.
Any dispute as to the scope of the Operations Monitors authority will be resolved
by the Department in the exercise of its sole discretion after appropriate consultation with Ocwen
and/or the Operations Monitor.
45.
Ocwen will pay all reasonable and necessary costs of the Operations Monitor.
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The terms of the Operations Monitor will extend for a period of twenty-four (24)
months from the date of formal engagement which shall be no later than May 1, 2015. The
Department may, in its sole discretion, extend the engagement another twelve (12) months if the
Department determines that Ocwen has not sufficiently achieved benchmarks identified by the
Operations Monitor.
Compliance Monitor
47.
The Compliance Monitor will remain engaged for at least three (3) months from
the execution of this Consent Order. The Department may, in its sole discretion, extend the
engagement of the Compliance Monitor for a period not to exceed an additional three (3)
months.
48.
Following completion of the Compliance Monitors engagement, the Operations
Monitor may call upon the Compliance Monitor to perform work that draws on the Compliance
Monitors institutional knowledge of Ocwen.
49.
Prior to the Operations Monitors engagement and for a short transitional period
thereafter not to exceed forty-five (45) days, the Department may in its sole discretion direct the
Compliance Monitor to fill any of the roles of the Operations Monitor described in this Consent
Order.
Board of Directors
50.
Ocwen Financial Corporation will expand its Board of Directors by two
independent board members (the Additional Directors) in consultation with the Compliance
Monitor or the Operations Monitor.
51.
The Additional Directors will not own equity in any related party.
52.
Ocwens Board will contain no more than two executive directors at any time.
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Conflicts of Interest
53.
With respect to mortgage loans serviced by Ocwen, Ocwen will conduct semi-
annual benchmarking studies of pricing and performance standards with respect to all fees or
expenses charged to New York borrowers or to investors on New York property by any related
party, to determine whether the terms offered by the related party are commensurate with market
rates or, if market rates are not available, are reasonably related to actual expenses incurred by
the related party. Maximum rates for services that are established by government-sponsored
enterprises or other investors may not be presumed to be the market rate and may not substitute
for actual assessment of market rates.
54.
Ocwen will not share any common officers or employees with any related party.
55.
Ocwen will not share risk, internal audit, or vendor oversight functions with any
related party.
56.
Any Ocwen employee, officer, or director owning more than $200,000 equity
ownership in any related party will be recused from negotiating, or voting to approve a
transaction with the related party in which the employee, officer, or director has such equity
ownership, or any transaction that indirectly benefits such related party if such transaction
involves revenues or expense to Ocwen or a related party of $120,000 or more.
Management Changes
57.
Effective January 16, 2015, William Erbey will resign from his position as
Executive Chairman of Ocwen, his position as Chairman of the Board of Directors of Altisource
Portfolio, his position of Chairman of the Board of Directors of Altisource Residential
Corporation, his position of Chairman of the Board of Directors of Altisource Asset Management
Corporation, and his position of Chairman of the Board of Directors of Home Loan Servicing
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Solutions Ltd. Mr. Erbey will have no directorial, management, oversight, consulting, or any
other role at Ocwen or any related party, or at any of Ocwens or the related parties affiliates or
subsidiaries as of the date of his resignation. Effective at his resignation, Ocwens Board
members and management will not disclose to Mr. Erbey any non-public information about
Ocwen that is not available to other shareholders. In the event that Ocwen discovers a violation
of the terms of this Paragraph, Ocwen will notify the Department of the violation within three (3)
business days of discovery.
No Indemnification
58.
Neither Ocwen, nor any of its parents or affiliates will, collectively or
individually, seek or accept, directly or indirectly, reimbursement or indemnification, including,

but not limited to, payment made pursuant to any insurance policy, or from any of its parents or
affiliates, with regard to any or all of the amounts payable pursuant to this Consent Order.
Breach of Consent Order
59.
In the event that the Department believes Ocwen to be in material breach of this
Consent Order (Breach), the Department will provide written notice to Ocwen, and Ocwen
must, within ten (10) business days of receiving such notice, or on a later date if so determined in
the Departments sole discretion, appear before the Department to demonstrate that no Breach
has occurred or, to the extent pertinent, that the Breach has been cured.
60.
The parties understand and agree that Ocwens failure to make the required
showing within the designated time period will be presumptive evidence of Ocwens Breach.
Upon a finding of Breach, the Department has all the remedies available to it under the New
York Banking and Financial Services Laws and may use any evidence available to the
Department in any ensuing hearings, notices, or orders.
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Wavier of Rights
61.
The parties understand and agree that no provision of this Consent Order is
subject to review in any court or tribunal outside the Department.

Parties Bound by the Consent Order
62.
This Consent Order is binding on the Department and Ocwen, as well as Ocwens
successors and assigns that are under the Departments supervisory authority. This Consent
Order does not bind any federal or other state agency or any law enforcement authority.
63.
Except as set forth in Paragraphs 64 and 65, no further action will be taken by the
Department against Ocwen for the matters set forth in this Consent Order, provided that Ocwen
complies with the terms of the Consent Order.
64.
Nothing in this Consent Order shall excuse Ocwen from paying required
restitution to any borrowers harmed by its improper or illegal conduct, including the backdating
of letters to borrowers. To the extent a borrower entitled to restitution has received a cash
payment pursuant to this Consent Order, Ocwen may offset such payment against the restitution
owed to such borrower.
65.
Notwithstanding any other provision in this Consent Order, the Department may
undertake additional action against Ocwen for transactions or conduct that: (a) are not set forth
in this Consent Order; (b) Ocwen did not disclose to the Compliance Monitor or the Department
in connection with the Departments investigation into these matters; and (c) that the Department
and Compliance Monitor were not otherwise aware of in connection with the Departments
investigation and the work of the Compliance Monitor.
Notices
66.
All notices or communications regarding this Consent Order will be sent to:
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Page 20 of 22
For the Department:

Daniel Burstein
Executive Deputy Superintendent
Real Estate Finance Division
New York State Department of Financial Services
One State Street
New York, NY 10004
For Ocwen:
Timothy M. Hayes
Executive Vice President and General Counsel
Ocwen Financial Corporation
1661 Worthington Road #100
West Palm Beach, FL 33409
Miscellaneous
67.
Each provision of this Consent Order will remain effective and enforceable until
stayed, modified, suspended, or terminated by the Department.

68.
No promise, assurance, representation, or understanding other than those
contained in this Consent Order has been made to induce any party to agree to the provisions of
the Consent Order.
IN WITNESS WHEREOF, the parties have caused this Consent Order to be signed this 22nd
day of December, 2014.
OCWEN FINANCIAL CORPORATION
NEW YORK STATE DEPARTMENT OF

FINANCIAL SERVICES
By: _______________________
RONALD FARIS
President and Chief Executive Officer
By: _______________________
BENJAMIN M. LAWSKY
Superintendent of Financial Services

By: _______________________
TIMOTHY M. HAYES
Executive Vice President
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Page 21 of 22
For the Depmtment:

Daniel Burstein
Real Estate Finance Division
One State Street
New York, NY 10004
For Ocwen:
Timothy M. Hayes
Executive Vice President and General Counsel
Oewen Financial Corporation
1661 WOIthington Road #100
West Palm Beach. FL 33409
Miscellaneous
67.
Each provision o[this Consent Order will remain effective and enforceable until
stayed, modified, suspended, or terminated by the Department.

68.
No promise, assurance, representation, or understanding other than those
contained in this Consent Order has been made to induce any pmty to agree to the provisions of
the Consent Order.
IN WITNESS WHEREOF, the parties have caused this Consent Order to be signed this 19th
day of December. 2014.
OCWEN FINANCIAL CORPORATION
NEW YORK STATE DEPARTMENT OF

FINANCIAL SERVICES
By:
By:
~9-
BENc;cJ;-:A~M;oI:-;N-;:M-;-,-;:L--;A-:CW;-;;S'""'K-:::;Y-;--
RONALD FARIS
President and Chief Executive Officer
By:
TIMO:OccT"'H"'Y=M-;-,coH-;-A:CyC;;EOC,S ,-----
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Page 22 of 22
For the Department:

Daniel Burstei n
Real Estate Finance Divi sion
One State Street
New York, NY 10004
For Oewen:
Timothy M. Hayes
Executi ve Vice President and General Counsel
Ocwen Financial Corporat ion
1661 Worthington Road # 100
We" Palm Beach, FL 33409
Misce ll aneous
67.
Each provision of this Consent Order will remain effective and enforceable unt il
stayed. modified, suspended. or terminated by the Department.

68.
No promi se. assurance . representation, or understanding other than those
conta ined in thi s Consent Order has been made to induce any party to agree to the prov isions of
the Consent Orde r.
IN WITNESS WI-IEREOF, the parties have caused this Consent Order to be signed thi s 19th
day of December. 2014.
OCWEN FINANCIAL CORPORATlON
NEW YORK STATE DEI'ARTMENT OF

FI NANCIAL SE RYICES
By:
RON
~~~~~R
' A L D FA ~I~~-----S
By:
li E N:,eJ'-"
AM
= IN
o,-,-:C"O".--;
M L- A
" '::-Y"'SKY
"'""-;-
Pres id en t ,lnd C hi ef Exec utive Officer
S UJlerintendent of financhll Serv ices
OCWEN LOAN SERV IC ING, LLC
BY
:-r:V 0{ ~
TIMOTHY M. HAYES
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Document #1529254
Andrew M. Cuomo
Governor
Filed: 12/29/2014
Page 1 of 6
Benjamin M. Lawsky
Superintendent
August 4, 2014
Timothy Hayes
General Counsel
Ocwen Financial Corporation
1661 Worthington Road, Suite 100
West Palm Beach, FL 33409
Dear Mr. Hayes:
As part of the Departments ongoing examination of Ocwens mortgage servicing practices, we
are reviewing a troubling transaction involving Ocwens related company, Altisource Portfolio
Solutions, S.A. (Altisource), and the provision of force-placed insurance. Indeed, this complex
arrangement appears designed to funnel as much as $65 million in fees annually from alreadydistressed homeowners to Altisource for minimal work. Additionally, the role that Ocwens
Executive Chairman William C. Erbey played in approving this arrangement appears to be
inconsistent with public statements Ocwen has made, as well as representations in company SEC
filings. As discussed below, we require certain information about this force-placed insurance
arrangement and about Mr. Erbeys role in approving the arrangement.
Background
As you know, the Department has previously expressed concerns about Ocwens use of related
companies to provide fee-based services such as property inspections, online auction sites,
foreclosure sales, real estate brokers, debt collection, and many others. Because mortgage
servicing presents the extraordinary circumstance where there is effectively no customer to select
a vendor for ancillary services, Ocwens use of related companies to provide such services raises
concerns about whether such transactions are priced fairly and conducted at arms-length.
The Department now seeks additional information about Ocwens provision of force-placed
insurance through related companies. As you are aware, the Departments recent investigation
into force-placed insurance revealed that mortgage servicers were setting up affiliated insurance
agencies to collect commissions on force-placed insurance, and funneling all of their borrowers
force-placed business through their own agencies, in violation of New York Insurance Law
section 2324s anti-inducement provisions. The Department discovered that servicers own
insurance agencies had an incentive to purchase force-placed insurance with high premiums
because the higher the premiums, the higher the commissions kicked back by insurers to the
servicers or their affiliates. The extra expense of higher premiums, in turn, can push already
struggling families over the foreclosure cliff. In light of this investigation, the Department last
year imposed further prohibitions on these kickbacks to servicers or their affiliates.
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However, as part of our broader review of ancillary services provided by non-bank mortgage
servicers, we are concerned that certain non-bank mortgage servicers are seeking to side-step
those borrower protections through complex arrangements with subsidiaries and affiliated
companies. Indeed, in recent weeks, we halted one such arrangement at another non-bank
mortgage servicing company.
Agreements with SWBC and Altisource
Based on its investigation and through the Monitors work, the Department understands that
Ocwens force-placed arrangement with Altisource features the use of an unaffiliated insurance
agent, Southwest Business Corporation (SWBC), apparently as a pass-through so that Ocwen
and Altisource are not directly contracting with each other, but Altisource can still receive
insurance commissions and certain fees seemingly for doing very little work.
These are the facts established by documents Ocwen provided to the Monitor: In August 2013,
Ocwen appointed an Altisource subsidiary called Beltline Road Insurance Agency, Inc.
(Beltline) as its exclusive insurance representative, purportedly to negotiate and place a new
force-placed insurance program for Ocwen. Ocwens existing force-placed arrangement with the
insurer Assurant was set to expire in March 2014, and Beltlines stated task was to find an
alternative arrangement. In January 2014, Altisource provided a memo to the Credit Committee
of Ocwen Mortgage Servicing, Inc., recommending, among other things, replacing Assurant with
SWBC as Ocwens managing general agent. SWBC would then be charged with managing
Ocwens force-placed insurance program, including negotiating premiums with insurers. As part
of this arrangement, Altisource recommended itself to provide fee-based services to SWBC.
In emails dated January 15 and 16, 2014, the transaction was approved by the three members of
the Credit Committee: William Erbey, Duo Zhang, and Richard Cooperstein. The Credit
Committee did not meet to discuss this proposal, no minutes were taken of the Credit
Committees consideration of this proposed transaction, and the proposed transaction apparently
was not presented for review or approval to any member of the Ocwen Board of Directors except
Mr. Erbey, as Mr. Zhang and Mr. Cooperstein are not members of the Ocwen Board of
Directors.
Just one month after this Credit Committee approval, on February 26, 2014, the company
received the Departments letter raising concerns about potential conflicts of interest between
Ocwen and its related public companies. In that letter, we identified facts that cast serious
doubts on recent public statements made by the company that Ocwen has a strictly arms-length
business relationship with those companies, and we specifically referenced the multiple roles
played by Mr. Erbey as an area of concern.
Disregarding the concerns raised in our letter, Ocwen proceeded to execute contracts formalizing
this new force-placed arrangement, apparently without further consideration by any Board
member other than Mr. Erbey. Those contracts, dated as of June 1, 2014, indicate that Altisource
will generate significant revenue from Ocwens new force-placed arrangement while apparently
doing very little work. Indeed, a careful review of these and other documents suggests that
Ocwen hired Altisource to design Ocwens new force-placed program with the expectation and
intent that Altisource would use this opportunity to steer profits to itself.
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First, Altisource will reap enormous insurance commissions for having recommended that
Ocwen hire SWBC. Under the contracts, Ocwen promises to give its force-placed insurance
business to SWBC. SWBC does the work of negotiating premiums, preparing policies, and
handling renewals and cancellations. For these services, SWBC receives commissions from
insurers. SWBC then passes on a portion of those commissions, constituting 15% of net written
premium on the policies, to Altisource subsidiary Beltline, for insurance placement services.
Documents indicate that Ocwen expects to force-place policies on its borrowers in excess of
$400 million net written premium per year; a 15% commission on $400 million would be $60
million per year. It is unclear what insurance placement services, if any, Altisource is providing
to justify these commissions.
Second, Altisource will be paid a substantial annual fee for providing technology support that it
appears to be already obligated to provide. This fee relates to monitoring services, whereby
Ocwen pays a company to monitor whether its borrowers insurance remains in effect. Such
monitoring is necessary to establish which borrowers have lapsed on their payments and need to
have insurance force-placed upon them. Prior to 2014, Ocwen was paying ten cents per loan per
month to Assurant for monitoring. In this new arrangement, however, Ocwen agrees to pay
double the prior amount twenty cents per loan per month now paid to SWBC, for each of the
approximately 2.8 million borrowers serviced by Ocwen. SWBC, in turn, agrees to pass on
fifteen out of that twenty cents to Altisource, or an estimated $5 million per year. Altisource
provides only one service in exchange for this fee: granting SWBC access to Ocwens loan files.
Altisource, of course, only has access to Ocwens loan files through its own separate services
agreements with Ocwen, which appear to contractually obligate Altisource to provide this access
to business users designated by Ocwen to receive such access.
Third, the contracts require SWBC to use Altisource to provide loss draft management services
for Ocwen borrowers; to pay Altisource $75 per loss draft for these services; and to pay
Altisource an additional $10,000 per month for certain other services.
In an effort to better understand this arrangement, the Department requests that Ocwen provide
the following information and documents:
1. Is Altisource already obligated to provide access to Ocwens loan files to SWBC
pursuant to separate agreements with Ocwen? If your answer is no, please specifically
explain how the Technology Products Letter between Ocwen and Altisource, produced to
the Department beginning at OFC00002496, does not impose this obligation.
2. What services, if any, does Altisource or its subsidiary provide to SWBC in exchange for
SWBC paying the Altisource subsidiary a commission of 15% of insurance premiums?
In addition, it appears that payment of this commission excludes premium generated by
policies issued on properties in New York State. Please describe the negotiations that
resulted in this exclusion, and identify any alternate compensation to be paid to
Altisource or any affiliate to make up for the excluded commissions on New York
properties.
3. What services, if any, does Altisource provide to SWBC in exchange for SWBC paying
Altisource fifteen cents per loan per month?
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4. What services, if any, does Altisource provide to SWBC in exchange for an additional
$10,000 per month?
5. Under what circumstances do Ocwen policies and procedures permit approval of
transactions solely through the Credit Committee? Did this force-placed insurance
arrangement meet those requirements? Do Ocwen policies and procedures require any
additional review or approvals for transactions involving related companies? If so, did
Ocwen engage in that review or obtain those approvals for this arrangement?
6. Were any options presented to the Credit Committee other than the proposed SWBC
transaction? If so, did all such options feature the retention of Altisource to provide feebased services? Or were options presented that did not involve payments to Altisource?
7. Throughout this process, did members of the Credit Committee or any Ocwen personnel
give any consideration to the impact that Altisource fees and commissions would have in
increasing insurance premiums to be paid by struggling families?
8. After the Credit Committee approved Altisources January 2014 proposal for Ocwens
new forced-placed insurance program, it appears that certain changes were made to the
proposal, including an expansion of SWBCs and Altisources roles in the program and
their associated compensation. Please describe those changes and the negotiations that
led to those changes, and identify all personnel involved in negotiating and approving
those changes.
9. What process resulted in the August 2013 appointment of Altisources subsidiary as
Ocwens exclusive insurance representative? Was this process competitive? What
Ocwen Board members or personnel were involved in this appointment? Which Board
members, if any, authorized this appointment? Did those Ocwen Board members or
personnel know or anticipate that Altisource would return with a plan that would appear
to be highly profitable for itself?
10. What amount of revenue has Altisource or its affiliates realized, and what amount of
revenue is it projected to realize, from the services it is providing pursuant to this forceplaced insurance arrangement? What are its costs for providing those services? How
many employees at Altisource or its subsidiaries work on providing those services, and
how much of their time is dedicated to this work?
11. Altisources presentation to the Credit Committee stated that Altisource will establish its
own managing general underwriter during 2014 to provide LPI underwriting services
starting in 2015. Please explain Altisources intention to establish a managing general
underwriter, state whether Ocwen supports Altisources plan, and explain how this
development will affect Ocwens force-placed program, Altisources revenue, and the
fees to be charged to Ocwen borrowers or mortgage investors.
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Ocwens Public Statements Concerning Transactions with Related Companies

In addition to the issues raised above, the Department has serious concerns about the apparently
conflicted role played by Ocwen Executive Chairman William Erbey and potentially other
Ocwen officers and directors in directing profits to Altisource, which is related to Ocwen but is
formally a separate, publicly-traded company. As you know, Mr. Erbey is Ocwens largest
shareholder and is also the Chairman of and largest shareholder in Altisource. In fact, Mr.
Erbeys stake in Altisource is nearly double his stake in Ocwen: 29 percent versus 15 percent.
Thus, for every dollar Ocwen makes, Mr. Erbeys share is 15 cents, but for every dollar
Altisource makes, his share is 29 cents.
The Department and its Monitor have uncovered a growing body of evidence that Mr. Erbey has
approved a number of transactions with the related companies, despite Ocwens and Altisources
public claims including in SEC filings1 that he recuses himself from decisions involving
related companies. Mr. Erbeys approval of this force-placed insurance arrangement as
described above appears to be a gross violation of this supposed recusal policy.
12. Please explain how and why Mr. Erbey approved the arrangement between Ocwen,
SWBC, and Altisource.
13. Please provide every instance where Mr. Erbey has approved a transaction involving a
related company notwithstanding Ocwens statements to the contrary.
Finally, Ocwen and Altisource state in their public filings that rates charged under agreements
with related companies are market rate,2 but Ocwen has not been able to provide the Monitor
with any analysis to support this assertion.
14. Please advise whether Ocwen has performed any independent analysis to determine
whether the rates charged in the SWBC arrangement are market rate.
15. Please address whether Ocwen has performed any independent analysis to support the
assertion that the rates charged under other related party agreements are market rate.
Ocwen Financial Corporation 2013 Form 10-K Annual Report, at 18 (We have adopted policies, procedures and
practices to avoid potential conflicts with respect to our dealings with Altisource, HLSS, AAMC and Residential,
including our Executive Chairmen recusing himself from negotiations regarding, and approvals of, transactions
with these entities.); Altisource Portfolio Solutions S.A. 2013 Form 10-K Annual Report, at 17 (We follow
policies, procedures and practices to avoid potential conflicts with respect to our dealings with Ocwen, HLSS,
AAMC and Residential, including our Chairman recusing himself from negotiations regarding, and approvals of,
transactions with these entities.).
Ocwen Financial Corporation 2013 Form 10-K Annual Report, at F-60 (We believe the rates charged under
[agreements with Altisource] are market rates as they are materially consistent with one or more of the following:
the fees charged by Altisource to other customers for comparable services and the rates Ocwen pays to or
observes from other service providers.); Altisource Portfolio Solutions S.A. 2013 Form 10-K Annual Report, at 7
(We record revenue we earn from Ocwen and its subsidiaries under various long-term servicing contracts at rates
we believe to be market rates as they are consistent with one or more of the following: the fees we charge to other
customers for comparable services; the fees Ocwen pays to other service providers; and fees charged by our
competitors.).
5
(Page 113 of Total)
USCA Case #14-5265
Document #1529254
Filed: 12/29/2014
Page 6 of 6
We intend to fully review all of the issues raised above. Please also provide documents that
support your responses. We ask and expect that Ocwen will preserve all documents concerning
the matters discussed in this letter.
Sincerely,
Benjamin M. Lawsky
cc:
William C. Erbey, Executive Chairman, Ocwen Board of Directors

Ronald M. Faris, Ocwen Board of Directors
Ronald J. Korn, Ocwen Board of Directors
William H. Lacy, Ocwen Board of Directors
Wilbur L. Ross, Jr., Ocwen Board of Directors
Robert A. Salcetti, Ocwen Board of Directors
Barry N. Wish, Ocwen Board of Directors
Mitra Hormozi, Zuckerman Spaeder LLP
James Sottile, Zuckerman Spaeder LLP
6
(Page 114 of Total)
12/27/2014 Press Release - December 22, 2014: NYDFS Announces Ocwen Chairman To Resign From Firm And Related Companies; Ocwen To Provide Direct H
USCA Case #14-5265
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Document #1529254
Filed: 12/29/2014
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December 22, 2014

Contact: Matt Anderson, 212-709-1691
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NYDFS ANNOUNCES OCWEN CHAIRMAN TO RESIGN FROM FIRM AND RELATED

COMPANIES; OCWEN TO PROVIDE DIRECT HOMEOWNER RELIEF AND UNDERTAKE
SIGNIFICANT OPERATIONAL REFORMS
$150 Million in Hard-dollar Assistance to New Yorkers
NYDFS Will Have Independent Monitor at Ocwen for up to Additional Three Years
Benjamin M. Lawsky, Superintendent of Financial Services, announced today that to address serious conflict of
interest issues uncovered during a New York State Department of Financial Services (NYDFS) investigation William
C. Erbey will step down from his position as Executive Chairman of Ocwen Financial Corporation (OCN) and from his
positions as Chairman of the Board of Directors of each of four related companies: Altisource Portfolio Solutions S.A.
(ASPS), Altisource Residential Corporation (RESI), Altisource Asset Management Corporation (AAMC), and Home Loan
Servicing Solutions, Ltd. (HLSS). As of these resignations, Mr. Erbey will have no directorial, management, oversight,
consulting, or any other role at Ocwen or any related party, or at any of Ocwen's or the related parties' affiliates or
subsidiaries.
Additionally, Ocwen the fourth-largest mortgage servicer in the country and largest subprime mortgage servicer in
the United States will undertake significant operational reforms to address serious servicing misconduct and
conflict of interest issues at the company; have an NYDFS-selected, independent monitor on site for up to an
additional three years; and provide "hard-dollar" assistance to New Yorkers totaling $150 million.
Superintendent Lawsky said: "Today's agreement will deliver significant assistance to Ocwen homeowners in New
York and provide a new path for the company to clean up its operations. We will continue to closely monitor Ocwen
to ensure that it lives up to its obligations under this agreement, and treats struggling homeowners with the respect
and dignity they deserve."
That $150 million in hard-dollar assistance Ocwen will pay includes:
$50 million in direct, hard-dollar restitution payments to former and current Ocwen homeowners in New York.
Ocwen homeowners in New York who lost their homes to foreclosure will receive a payment of $10,000 each.
After the payments are made to foreclosed homeowners, the balance of the funds will be distributed equally to
current and former Ocwen homeowners (up to $1,000 each) who have had foreclosure proceedings initiated
against them but have not yet lost their homes to foreclosure, and those current Ocwen homeowners will also
have the opportunity to be reviewed for a mortgage modification or other alternative to foreclosure.
$100 million for housing, foreclosure relief, and community redevelopment programs supporting New Yorks
housing recovery.
Ocwen may not use so-called "soft-dollar" mortgage modifications of loans it does not own to satisfy any of this
$150 million penalty. As a servicer, Ocwen is already under a legal obligation to make such modifications if they are
in the best interest of homeowners and investors. As such, soft dollar settlements do not represent either a punitive
penalty to Ocwen for its misconduct or provide significant additional relief to consumers. Moreover, Ocwen shall not
seek or accept, directly or indirectly, reimbursement or indemnification with regard to any or all of the amounts
payable under today's agreement; nor will it claim a U.S. tax deduction or tax credit for those payments.
Ocwen will continue to not be permitted to acquire additional mortgage servicing rights (MSRs). Ocwen may not
begin to acquire additional MSRs until and unless it receives prior approval from NYDFS, and meets benchmarks
developed by the independent monitor concerning the adequacy of Ocwens onboarding process for newly acquired
MSRs and its ability to adequately service both those newly acquired MSRs and its existing loan portfolio.
http://www.dfs.ny.gov/about/press2014/pr1412221.htm
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USCA CaseNYDFS'
#14-5265
#1529254
InvestigationDocument
of Ocwen's Misconduct
Filed: 12/29/2014
Page 2 of 4
Ocwen is currently the fourth largest mortgage loan servicer and the largest servicer of subprime loans in the United
States, servicing an unpaid principal balance (UPB) of approximately $430 billion.
Ocwen has grown more than ten-fold in the last several years. Beginning in 2009, Ocwen significantly expanded its
servicing operations through the acquisition of several major servicers of home loans, as well as the acquisition of
mortgage servicing rights (MSRs) for hundreds of billions of dollars in UPB.
In 2010 and 2011, NYDFS participated in a multistate examination of Ocwen, as well as entities ultimately acquired
by Ocwen. The examination of Ocwen identified, among other things, deficiencies in Ocwens servicing platform and
loss mitigation infrastructure, including (a) robo-signing, (b) inaccurate affidavits and failure to properly validate
document execution processes, (c) missing documentation, (d) wrongful foreclosure, (e) failure to properly maintain
books and records, and (f) initiation of foreclosure actions without proper legal standing.
Accordingly, Ocwen and NYDFS entered into an Agreement on Mortgage Servicing Practices on September 1, 2011. In
June 2012, the Department conducted a surprise examination of Ocwen to assess its compliance with the 2011
Agreement, and uncovered significant violations. Consequently, on December 5, 2012, Ocwen entered into a Consent
Order with NYDFS, which required Ocwen to retain an independent compliance monitor for two years.
During the course of the Monitors review, it identified numerous and significant additional violations of the 2011
Agreement, as well as New York State laws and regulations. For example, a limited review by the Monitor of 478 New
York loans that Ocwen had foreclosed upon revealed 1,358 violations of Ocwens legal obligations, or about three
violations per foreclosed loan. These violations included:
failing to confirm that it had the right to foreclose before initiating foreclosure proceedings;
failing to ensure that its statements to the court in foreclosure proceedings were correct;
pursuing foreclosure even while modification applications were pending ("dual tracking");
failing to maintain records confirming that it is not pursuing foreclosure of servicemembers on active duty; and
failing to assign a designated customer care representative.
The Department and the Monitor also identified, among other issues, (a) inadequate and ineffective information
technology systems and personnel, and (b) widespread conflicts of interest with related parties.
In the course of its review, the Monitor determined that Ocwens information technology systems are a patchwork of
legacy systems and systems inherited from acquired companies, many of which are incompatible. A frequent
occurrence is that a fix to one system creates unintended consequences in other systems. As a result, Ocwen
regularly gives borrowers incorrect or outdated information, sends borrowers backdated letters, unreliably tracks data
for investors, and maintains inaccurate records.
Ocwens core servicing functions rely on its inadequate systems. Specifically, Ocwen uses comment codes entered
either manually or automatically to service its portfolio; each code initiates a process, such as sending a delinquency
letter to a borrower, or referring a loan to foreclosure counsel. With Ocwens rapid growth and acquisitions of other
servicers, the number of Ocwens comment codes has ballooned to more than 8,400 such codes. Often, due to
insufficient integration following acquisitions of other servicers, there are duplicate codes that perform the same
function.
Despite these issues, Ocwen continues to rely on those systems to service its portfolio of distressed loans. Ocwens
reliance on technology has led it to employ fewer trained personnel than its competitors. For example, Ocwens Chief
Financial Officer recently acknowledged, in reference to its offshore customer care personnel, that Ocwen is simply
"training people to read the scripts and the dialogue engines with feeling." Ocwens policy is to require customer
support staff to follow the scripts closely, and Ocwen penalizes and has terminated customer support staff who fail
to follow the scripts that appear on their computer screens. In some cases, this policy has frustrated struggling
borrowers who have complex issues that exceed the bounds of a script and have issues speaking with
representatives at Ocwen capable of addressing their concerns. Moreover, Ocwens customer care representatives
in many cases provide conflicting responses to a borrowers question. Representatives have also failed in many
cases to record in Ocwens servicing system the nature of the concerns that a borrower has expressed, leading to
inaccurate records of the issues raised by the borrower.
The Departments review of Ocwens mortgage servicing practices also uncovered a number of conflicts of interest
between Ocwen and four other public companies (the aforementioned "related companies"), all of which are chaired
by Mr. Erbey, who is also the largest individual shareholder of each and the Executive Chairman of Ocwen.
Despite Mr. Erbeys holdings in these companies, Mr. Erbey has not in fact recused himself from approvals of several
transactions with the related parties. Mr. Erbey, who owns approximately 15 percent of Ocwens stock, and nearly
double that percentage of the stock of Altisource Portfolio, has participated in the approval of a number of
transactions between the two companies or from which Altisource received some benefit, including the renewal of
Ocwens forced placed insurance program in early 2014.
Ocwens close business relationship with related companies is particularly evident in its relationship with Altisource
Portfolio, which has dozens of subsidiaries that perform fee-based services for Ocwen. In one example, Altisource
Portfolio subsidiary Hubzu, an online auction site, hosts nearly all Ocwen auctions. In certain circumstances, Hubzu
has charged more for its services to Ocwen than to other customers charges which are then passed on to
(Page 116 of Total)

2/4
USCA Caseborrowers
#14-5265
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#1529254
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and investors.
Moreover, Ocwen
engages Altisource Portfolio
REALHome Services
Solutions, Inc. as its default real estate agency for short sales and investor-owned properties, even though this
agency principally employs out-of-state agents who do not perform the onsite work that local agents perform, at the
same cost to borrowers and investors.
Conflicts of interest are also evident at other levels of the Ocwen organization. For example, during its review, the
Monitor discovered that
Ocwens Chief Risk Officer concurrently served as the Chief Risk Officer of Altisource
Portfolio. The Chief Risk Officer reported directly to Mr. Erbey in both capacities. This individual seemed not to
appreciate the potential conflicts of interest posed by this dual role, which was of particular concern given his role as
Chief Risk Officer.
Homeowner Relief
In addition to the direct payments to Ocwen homeowners in New York, the company will also provide the following
relief:
Ocwen will provide upon request by a New York borrower that borrowers complete loan file, which includes all
information from all systems, including comment codes, at no cost to the borrower, regardless of whether such
borrowers loan is still serviced by Ocwen.
Ocwen will provide every New York borrower who is denied a modification, short sale, or deed-in-lieu of
foreclosure, a detailed explanation of the reasons for denial.
For all New York borrowers who have been reported negatively by Ocwen to credit agencies since January 1,
2010, Ocwen will provide upon request at no cost a copy of such borrowers credit report (including credit
scores), regardless of whether such borrowers loan is still serviced by Ocwen.
Nothing in today's agreement shall excuse Ocwen from paying additional required restitution to any borrowers
harmed by its improper or illegal conduct, including the backdating of letters to borrowers.
Additional Board Members, Monitor, and Significant Operational Reforms
Under today's agreement, to help address conflict of interest issues, Ocwen will expand its Board of Directors by two
independent board members in consultation with the Monitor. These additional directors will not own equity in any
related party company. Moreover, Ocwen's Board will contain no more than two executive directors at any time.
The Monitor will also review the adequacy and effectiveness of Ocwens operations, and assess Ocwens progress in
complying with recommended corrective measures. Such an assessment will include but is not limited to the
following areas:
Information technology systems and personnel, including with respect to record keeping and borrower
communications;
Number of personnel and the training and expertise of its personnel in all servicing operations;
Onboarding process for newly acquired mortgage servicing rights, including Ocwens ability to onboard newly
acquired MSRs without interruption to servicing newly acquired loans or its existing loan portfolio;
Controls in identifying and correcting errors made by Ocwens personnel or systems;
Risk management functions;
Contracts or proposed contracts with third parties, including but not limited to related parties;
Fees charged by Ocwen to borrowers or mortgage investors; and
The Ocwen borrower experience.
The Monitor will review and assess Ocwens current committees of the Board of Directors. The Ocwen Board will
consult with the Monitor concerning, among other things, the structure, composition, and reporting lines of such
committees, and whether certain committees should be either disbanded or created. The Board will consult with the
Monitor to determine which decisions should be committed to the specific oversight of the Boards independent
directors, or a committee comprised of such independent directors, including, but not limited to:
Approval of transactions with related parties;
Approval of transactions to acquire mortgage servicing rights, sub-servicing rights, or otherwise to increase the
number of loans serviced by Ocwen;
Approval of new relationships with third-party vendors;
Determinations as to whether Ocwens servicing, compliance, and information technology functions are
adequately staffed;
Determinations as to whether Ocwens servicing, compliance, and information technology personnel are
adequately trained;
Determinations as to whether Ocwens information technology infrastructure and ongoing investment in
information technology systems are adequate;
Determinations as to whether Ocwen is adequately addressing the issues identified by the Operations Monitor
and the Compliance Monitor; and
(Page 117 of Total)

3/4
and the Compliance Monitor; and
USCA Case #14-5265

Document #1529254
Filed: 12/29/2014
Page 4 of 4
Determinations as to whether Ocwen is treating borrowers fairly and is communicating with borrowers
appropriately.
The Monitor will semi-annually review and approve Ocwens benchmark pricing and performance studies with
respect to all fees or expenses charged to New York borrowers by any related party.
The Board will also consult with the Monitor to determine whether any additional members of senior management
should be terminated or whether additional officers should be retained to achieve the goals of complying with
today's agreement and all other applicable laws, regulations, and agreements as well as creating a corporate
culture of ethics, integrity, compliance, and responsiveness to borrowers.
To view a copy of today's consent order between NYDFS and Ocwen, please visit, link.
###
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4/4
12/27/2014
Ocwen Chairman to Resign Following $150 Settlement with N.Y. Regulator | Reverse Mortgage Daily
USCA Case #14-5265
Document #1529254
Filed: 12/29/2014
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Comment (#com m ents)
The drama continues to unfold for Ocwen Financial Corp. (NYSE: OCN), which
today which today announced the resignation of Founder and Chairman William
C. Erbey, following a $150 million settlement
(http://www.dfs.ny.gov/about/ea/ea141222.pdf) with one of its top scrutinizers, the
New York Department of Financial Services (NYDFS).
e=eyJhdiI6NjI1NCwiYXQiOjIwLCJjbSI6OTU1NSwiY2giOjE3ODQsIm
)
Nationwide Equities
e=eyJhdiI6MTU0NSwiYXQiOjIwLCJjbSI6MTA1MzYsImNoIjoxNzg0L
6YNwBCK2bfupc )
Urban Financial of America

e=eyJhdiI6MjQwMywiYXQiOjIwLCJidCI6MCwiY20iOjEwNTM3LCJja
C4OojOzrW4m-h-aSJ0psxdo )
Live Well Financial

e=eyJhdiI6ODg0MywiYXQiOjIwLCJjbSI6MTI5OTMsImNoIjoxNzg0L
CxCWGJEvAepFiNmLa067nij-P8 )
Reverse Mortgage Solutions

After nearly 30 years of service with the company, Erbey will step down from his
position as Executive Chairman, effective January 16, 2015. Upon his resignation,
current Ocwen Director Barry Wish will assume the role of Non-Executive
Chairman on that date.
I am grateful to the many associates who have worked alongside me and proud
of what we have accomplished, Erbey said in a written statement. I am
confident about Ocwens future under the experienced leadership of the executive
team.
In agreement with the settlement, Erbey will also step down from his positions as
Board Chairman at each of Ocwens four related companies, including Altisource
Portfolio Solutions S. A.; Altisource Residential Corporation; Altisource Asset
Management Corporation; and Home Loan Servicing Solutions, Ltd.
As of these resignations, Mr. Erbey will have no directorial, management,
oversight, consulting, or any other role at Ocwen or any related party, or at any of
Ocwens or the related parties affiliates or subsidiaries, said the NYDFS in a
http://reversemortgagedaily.com/2014/12/22/ocwen-chairman-to-resign-following-150-settlement-with-n-y-regulator/
e=eyJhdiI6Njk5MywiYXQiOjIwLCJjbSI6MTA0OTksImNoIjoxNzg0LC
)
Reverse Mortgage Funding
e=eyJhdiI6Mzg1NDEsImF0IjoyMCwiYnQiOjAsImNtIjoxOTU5MzYsIm
TuqKV0iCHfVmiQyU )
Sponsors
(Page 119 of Total)

1/6
12/27/2014
statement.
USCA Case #14-5265
Document #1529254
Filed: 12/29/2014
Page 2 of 6
Under the terms of the settlement, Ocwen will pay a civil monetary penalty of
$100 million to the NYDFS by December 31, which will be used by the State of
New York for housing, foreclosure relief and community redevelopment programs,
according to a release from the regulator.
The remaining $50 million will be used as restitution to current and former New
York borrowers in the form of $10,000 to each borrower whose home was
foreclosed upon by Ocwen between January 2009 and December 19, 2014. The
balance will then be distributed equally among borrowers who had foreclosure
actions filed, but not completed, by Ocwen between that timeframe.
e=eyJhdiI6Njk5NywiYXQiOjE4LCJidCI6MCwiY20iOjEwNTE4LCJjaC
The settlement, which arrived after the company inadvertently misdated
hundreds of letters (http://reversemortgagedaily.com/2014/10/27/ocwen-woes(http://engine.adzerk.net/r?

continue-as-ceo-pens-apology-to-borrowers/) sent to borrowers regarding loan
e=eyJhdiI6MjQ5MSwiYXQiOjYsImNtIjozODc4LCJjaCI6MTc4NCwiY3IiOjI1NjE2LCJkaSI6ImZjNGQyYTI3YmRhMzQ5NmI5NTU0ZmRjOTNiNGY4MWMxIiwiZG0iOjEsImZjIjozNjU5NCwiZmwiOjkxNjksImlw
modifications and foreclosures, was largely prepared for by Ocwen.
In the third quarter, the company recorded a $100 million charge
(http://reversemortgagedaily.com/2014/10/30/ocwen-prepares-for-100-millionservicing-settlement/) in payments in anticipation to settle for servicing charges in
the midst of investigations from the NYDFS. As for the other $50 million, Ocwen
said it will record that amount in its fourth quarter 2014 financial statements.
Also as part of the settlement, Ocwen will not be permitted to acquire additional
mortgage servicing rights, or begin to acquire additional MSRs until an unless it
receives approval from the NYDFS, and meets benchmarks developed by the
independent monitor concerning the adequacy of Ocwens onboarding process for
newly acquired MSRs.
Todays agreement will deliver significant assistance to Ocwen homeowners in
New York and provide a new path for the company to clean up its operations,
said Lawsky in a written statement. We will continue to closely monitor Ocwen
to ensure that it lives up to its obligations under this agreement, and treats
struggling homeowners with the respect and dignity they deserve.
Ocwen has also agreed to several non-monetary provisions under the settlement,
including monitor-led oversight of its operations, in addition to the New York
borrower assistance measures.
e=eyJhdiI6Njk5MywiYXQiOjE4LCJidCI6MCwiY20iOjEwNDk5LCJjaC
e=eyJhdiI6MTU0NSwiYXQiOjE4LCJidCI6MCwiY20iOjI2ODEsImNoIj
1-AZgrO_LTBv24I)
Beginning 60 days after December 19and for two yearsOcwen will provide,
upon request, New York borrowers with complete loan files at no cost, as well as
provide every N.Y. borrower detailed explanations as to why a loan modification,
short sale (http://reversemortgagedaily.com/2014/12/18/bloomberg-more-troublefor-ocwen/) or deed-in-lieu of foreclosure were denied.
The company will also provide one free credit report per year, at its own expense,
to any N.Y. borrower on request if Ocwen made a negative report to any credit
agency from January 1, 2010, the company will make staff available for borrowers
to inquire about their credit reporting, dedicating resources necessary to
investigate such inquiries and correct any errors.
Another non-monetary provision of the settlement requires the NYDFS to appoint
an independent Operations Monitor to review and assess the adequacy and
effectiveness of Ocwens operations for two years, with the regulator having the
option to extend this engagement for another 12 months.
The year has been a tumultuous oneto say the very leastfor Ocwen, marked
by numerous investigations from regulators, including the NYDFS as well as the
Monitor of the National Mortgage Settlement, which released a report
(http://reversemortgagedaily.com/2014/12/16/ocwen-just-cant-beat-regulator-heat/)
this month examining the companys compliance with NMS standards.

Even with the ongoing federal probes, penned apology letters
(http://reversemortgagedaily.com/2014/10/27/ocwen-woes-continue-as-ceo-pensapology-to-borrowers/) from executive leadership and series of servicing
downgrades (http://reversemortgagedaily.com/2014/10/23/ocwen-faces-moredowngrades-following-regulatory-scrutiny/) , Ocwen has reiterated its cooperation

with regulators time and time again. Todays settlement is no exception, though
2015 looks to be a rigid year.
e=eyJhdiI6MzE0MTgsImF0Ijo2LCJjbSI6NDM1NjEsImNoIjoxNzg0LCJjciI6MzM5NjkyLCJkaSI6ImZhM2FkZDAwYzNhYzRiMzg5NGZiNmJjNGM3NDIyNzM2IiwiZG0iOjEsImZjIjo0MTk1NTksImZsIjo3NzMzM
We believe this agreement is in the best interests of our shareholders,

employees, borrowers and mortgage investors, said Ocwen CEO Ronald Faris.
We will continue to cooperate with the DFS in the implementation of the terms of
this settlement which we believe will allow Ocwen to continue to focus on what
we do besthelping homeowners.
(Page 120 of Total)

2/6
12/27/2014
The fourth-largest
mortgage loan servicer
in the U.S., Ocwen services
an unpaid12/29/2014
USCA Case #14-5265
Document
#1529254
Filed:
Page 3 of 6
principal balance of approximately $430 billion. In New York alone, the company
services nearly 130,000 residential home loans with a total UPB of more than $30
billion.
e=eyJhdiI6MTg1NSwiYXQiOjE4LCJidCI6MCwiY20iOjU4ODUsImNo
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USCA Case #14-5265

#1529254
Comments Document
Community
Sort by Oldest
Filed:
Login12/29/2014
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Join the discussion
(http://www.reversemortgagejobsonline.com/rss/feed
Reverse Mortgage Jobs

The_Critic
(http://www.reversemortgagejobsonline.com/index.p
4 days ago
Have the policies and transactions sanctioned by Erbey already

so irreparably harmed the reputation of Ocwen that Liberty will
never again rise above where it is today? Liberty most likely has
not been helped.
Having Ocwen related to this industry is NOT an overall benefit
to the industry at this time.
Underwriter
(http://www.reversemortgagejobsonline.com/index.php?
page=view_job&post_id=643)
Reverse Mortgage Consultant

Reply Share
Experienced/Driven RMLO
WHAT'S THIS?
ALSO ON REVERSE MORTGAGE DAILY
Heres How One Finance

Professor Came Around to
Reverse
8
commentsMortgages
16 days ago
joshstephens Couldn't
Compliance
Regulations
agree more. I have presented

the program and our take on
using it as a financial
Time:planning
Save Your
tool toHome
at least 10
Equity
Until You
Really
Need
advisors
who have
seen
a
It
1 comment
24 days ago by John
live presentation
Dave83049 I believe you
should take out the reverse
mortgage when you don't
need it and place all the
equity into the line of credit
(LOC). The balance in the
line of credit will grow at a
FHA Loses Competitive Edge

For Home Buyers
1 comment 25 days ago
The_Cynic What private
insurer wants to come into

the reverse mortgage
industry when FHA is
Openreporting
Mortgage
Picks
a one
yearUp
actuarial
Reverse
Originations
Arm
determined
loss of $7.7
From
360 17
Mortgage
1
comment
billion
fordays
lastago
fiscal year? Yet
that
John loss
Smaldone
My
congratulations to Scott
Gordon and Joe Morris. They
are good people and I am
looking forward to them
becoming a force in the
industry.John A. Smaldone
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LOGIN
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admits misconduct
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Plans to exit agency servicing; increase mortgage originations
Company to pay $150 million to homeowners
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Ocwen Chairman Erbey resigns as

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Ocwen Financial (OCN

Symbol=321:2554581)) Executive Chairman William Erbey
will resign from the Ocwen family of companies and
Ocwen will pay $150 million to homeowners under an
agreement with the New York Department of Financial
Services.
Ocwen admitted in the agreement with the New York
regulatory agency that it didn't properly deal with
distressed homeowners and failed to maintain adequate
systems for servicing hundreds of billions of dollars in
mortgages.
Change %
Email
Print
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ocwen-chairman-erbeyresigns-as-companyadmits-misconduct)
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misconduct&title=Ocwen%20Chairman%20Erbey%20resigns%20as%20company%20admits%20miscon
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INDUSTRY EVENTS
Related Articles
1/12/15 12:00AM
(http://www.housingwire.com/events/292mismo-winter-2015-educational-(Page
125 of Total)
NYDFS Superintendent Benjamin Lawsky said the action

What the Ocwen
means
addresses
serious
conflict
of interest issues uncovered
USCA
Case
#14-5265
Document agreement
#1529254
for
Ocwen and
during the departments investigation.
beyond
Erbey will also resign as Chairman of the Board of Directors
of each of four related companies: Altisource Portfolio
Solutions S.A. (ASPS
Symbol=537%3A10407216)), Altisource Residential
Corporation (RESI
Symbol=321%3A20239642)), Altisource Asset
Management Corporation (AAMC
Symbol=321%3A20250106)), and Home Loan Servicing
Solutions, Ltd. (HLSS
Symbol=HLSS)).
As of these resignations, Erbey will have no directorial,
management, oversight, consulting, or any other role at
Ocwen or any related party, or at any of Ocwens or the
related parties affiliates or subsidiaries.
Additionally, Ocwen the fourth-largest mortgage
servicer in the country and largest subprime mortgage
servicer in the United States will undertake significant
operational reforms to address serious servicing
misconduct and conflict of interest issues at the company;
have an NYDFS-selected, independent monitor on site for
up to an additional three years; and provide hard-dollar
assistance to New Yorkers totaling $150 million.
Today's agreement will deliver significant assistance to
Ocwen homeowners in New York and provide a new path
for the company to clean up its operations, Lawsky said.
We will continue to closely monitor Ocwen to ensure that
it lives up to its obligations under this agreement, and
treats struggling homeowners with the respect and dignity
they deserve.
The NYDFS has been investigating Ocwen for its dealings,
its acquisitions, backdating letters to borrowers and the
close association of its companies throughout 2014.
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Filed: 12/29/2014
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Page 3 of 6
black-knightcompany)
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Ocwens stock tumbled in early trading but analysts with Sterne Agee said that in the long
run this could be good for the Ocwen companies.
The settlement with the DFS (assuming the NYT has it right) will leave the company
saddled with a number of changes that in the end, will create a more compliant (dare we
say complacent) company, but cripple profitability for some time, Sterne Agee analysts
told HousingWire. In addition, we do not know if the agreement will violate any of the
terms of the global settlement or leave the company open to additional scrutiny.
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activity of Solutionstar. This is something we need to explore.
That $150 million in hard-dollar assistance Ocwen will pay includes:
$50 million in direct, hard-dollar restitution payments to former and current Ocwen
homeowners in New York. Ocwen homeowners in New York who lost their homes to
foreclosure will receive a payment of $10,000 each. After the payments are made to
foreclosed homeowners, the balance of the funds will be distributed equally to
current and former Ocwen homeowners (up to $1,000 each) who have had
foreclosure proceedings initiated against them but have not yet lost their homes to
foreclosure, and those current Ocwen homeowners will also have the opportunity to
be reviewed for a mortgage modification or other alternative to foreclosure.
$100 million for housing, foreclosure relief, and community redevelopment
programs supporting New Yorks housing recovery.
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The NYDFS said that Ocwen may not use so-called soft-dollar mortgage modifications of
loans it does not own to satisfy any of this $150 million penalty. As a servicer, Ocwen is
already under a legal obligation to make such modifications if they are in the best interest
of homeowners and investors. As such, soft-dollar settlements do not represent either a
punitive penalty to Ocwen for its misconduct or provide significant additional relief to
consumers, the NYDFS said.
Moreover, Ocwen shall not seek or accept, directly or indirectly, reimbursement or
indemnification with regard to any or all of the amounts payable under today's
agreement; nor will it claim a U.S. tax deduction or tax credit for those payments.
Under the terms of the agreement, Ocwen will continue to not be permitted to acquire
additional mortgage servicing rights.
Ocwen may not begin to acquire additional MSRs until and unless it receives prior
approval from NYDFS, and meets benchmarks developed by the independent monitor
concerning the adequacy of Ocwens onboarding process for newly acquired MSRs and its
ability to adequately service both those newly acquired MSRs and its existing loan
portfolio.
Ocwen is currently the fourth-largest mortgage loan servicer and the largest servicer of
subprime loans in the United States, servicing an unpaid principal balance of
approximately $430 billion.
In 2010 and 2011, NYDFS participated in a multistate examination of Ocwen, as well as
entities ultimately acquired by Ocwen. The examination of Ocwen identified, among other
things, deficiencies in Ocwens servicing platform and loss mitigation infrastructure,
including (a) robo-signing, (b) inaccurate affidavits and failure to properly validate
(Page 127 of Total)
document execution processes, (c) missing documentation, (d) wrongful foreclosure, (e)
failure
to properly
maintain
books and records,
and (f) initiation#1529254
of foreclosure actions
USCA
Case
#14-5265
Document
without proper legal standing.
Filed: 12/29/2014
Page 4 of 6
A limited review by the Monitor of 478 New York loans that Ocwen had foreclosed upon
revealed 1,358 violations of Ocwens legal obligations, or about three violations per
foreclosed loan. These violations included:
failing to confirm that it had the right to foreclose before initiating foreclosure
proceedings
failing to ensure that its statements to the court in foreclosure proceedings were
correct
pursuing foreclosure even while modification applications were pending (dual
tracking)
failing to maintain records confirming that it is not pursuing foreclosure of
servicemembers on active duty; and failing to assign a designated customer care
representative.
Trey Garrison is the Senior
Financial Reporter for
HousingWire.com. Trey has
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has been an editor for D Magazine
considered among the best city magazines
in the United States and a contributor
for Reason magazine.
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(Page 128 of Total)
4 Comments
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USCA Case #14-5265
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mike_f
5 days ago
wow...can we expect some prosecutions then? i bet not. the company is well
known for being a giant pain in the a$$ to deal with and now they admit it. will
someone PLEASE get a class together to claim class action status and file suit to
make them pay for their sins...i will contribute $100
1
Reply Share
sandyjean412 > mike_f
4 days ago
I'll make a contribution, too.

sandyjean412
Reply Share
a day ago
At least THEY admitted they didn't deal adequately with distressed homeowners.
When we will hear the same acknowledgments from others?
Reply Share
Mark Buono
3 days ago
Thats a new one....not keeping track of whether or not your forclosing on

someone who is deployed. Maybe they send a loan officer to Afghanistan to see if
the soldier can cure the default.
Reply Share
WHAT'S THIS?
ALSO ON HOUSINGWIRE
Accenture: 3 big changes for

mortgage lending in 2014
FHFA: Here's 7 facts to push

borrowers to refi
1 comment 8 days ago
2 comments 9 days ago
Charles Warnock Sounds right on,
vicky frieberg very frustrating if tax
Brena. Mortgage is not the only space

where companies will have to have a
records are used for self employed,

even if never a late payment in 15
18 Senators, mortgage bankers tell

HUD: Time to lower FHA premiums
FHFA issues warning on super

priority liens
sandyjean412 Premiums are too high
Sircules How does this protect the
when you realize that most homes are

insured against the possibility of a
taxpayer? This horrible for a taxpayer

and the share holders of FNMA. It's
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This Month in HousingWire Magazine

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Crunch time
Special feature: 15 for 15

Whats next in field services?
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economic front. This singular event would lead to calls that
the developed worlds ability to do business, with all of its
multitudinous complexities, was on the road to a recovery,
maybe this time, finally, forever..
by
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With this year's 15 for 15, we're profiling 15

companies who are well positioned to take
on the challenges of 2015. The companies
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to technology providers but they all
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year ahead. Read More
(http://www.housingwire.com/articles/32348for-15)
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at the forefront of the mortgage industry in the past
year or so. As we prepare to enter 2015, focusing on
compliance and new and constantly changing
regulations will remain the industrys focus. Read More
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