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Ocwen relies on third party vendors to actually print and mail the letters.Going as far back as 2012, large scale delays occurred between the time of the event that triggered the need for a letter versus the time the letters were actually mailed by the vendors.Pursuant to the MMC Examination, the participating States identified compliance violations of both State and Federal laws, a deteriorating financial condition, and systemic operational limitations under present management, all of which resulted in substantial harm to consumers and presented grave risk regarding the overall viability of Ocwen as a going concern.

Although the MSR sales provided significant liquidity that Ocwen primarily used to reduce debt, the MSR sales significantly reduced income and contribute to ongoing losses that have eroded capital. REALServicing: The problems with Ocwen’s system of record REALServicing have been extensive.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.” 9.Letter dating deficiencies: The dates on Ocwen’s letters to borrowers are automatically inserted onto the letterhead based on events in the system of record REALServicing.MSR purchases from 2012 through year-end 2014 more than doubled the size of Ocwen’s servicing portfolio from 4 billion to 5 billion.

The rapid growth beginning in 2012 doubled Ocwen’s net income from 1 million for 2012 to 2 million for 2013.

The MMC Examination review of these operational deficiencies revealed that as Ocwen attempted to assimilate MSR purchases, deficient MCSs caused consumer harm, led to violations of federal and state regulations and resulted in non-compliance with servicing standards required by the 2012 National Mortgage Settlement (NMS). Earnings: Ocwen lost 2 million in 2014, 7 million in 2015 and 0 million in 2016.