Posted: 2017-09-11 20:06
67. Inaccurate Escrow Statements: The MMC Examination revealed that Ocwen routinely sent borrowers inaccurate escrow statements as a result of entries made to Ocwen’s escrow accounting system to effectuate an Ocwen proprietary Shared Appreciation Modification (SAM). One escrow statement reviewed listed approximately 65 actual escrow payments when in fact they were non-cash items used to account for the SAM. Ocwen later identified over 7,755 borrowers who received escrow statements containing SAM accounting entries listed as actual escrow payments. The MMC Examination found that Ocwen’s inability to accurately monitor the Ocwen SAM program caused Ocwen to send confusing and misleading escrow statements to consumers. The MMC Examination findings support the conclusion that Ocwen did not have any procedures in place to detect escrow statements that contained SAM accounting entries.
86. Turnover and vacancies in senior management: The MMC Examination set forth the Board of Directors’ responsibility to have regulatory compliance personnel with adequate access to information necessary to properly respond to regulator requests for information, including during the MMC Examination, and an effective understanding of the information being supplied. However, the MMC Examination found high levels of turnover and vacancies in Ocwen’s regulatory compliance department. Ocwen’s Chief Compliance Officer, Vice President of Compliance and Senior Manager of Examinations all resigned during the MMC Examination. Moreover, the positions of Director of Examinations, Licensing and Analytics, Senior Manager of Licensing and Senior Manager of Analytics were all vacant at the outset of the MMC Examination. Since then, positions have been filled in some areas, but turnover and consistency continue to be issues for the licensee.
Based upon the aforementioned Statement of Facts, Ocwen has failed to demonstrate the financial responsibility, character, reputation, integrity, and general fitness that would warrant the belief that the business will be operated honestly, fairly, and soundly in the public interest in violation of General Laws chapter 98, sections 79G, 79I, General Laws chapter 755E, section 9, 759 CRM , and 759 CMR .
58. The MMC Examination revealed that OBS was not properly licensed in all jurisdictions in which it has been operating. In addition, the MMC Examination found that Ocwen’s Board of Directors was not involved in approving the use OBS for servicing related activities and that Ocwen’s management team had failed to discuss the need for licensure with the Board of Directors even though Ocwen management knew OBS was not properly licensed.
ORDERED that Ocwen and any and all officers, directors, managers, employees, independent contractors or agents operating on behalf of Ocwen, and their successors or assigns, shall initiate a process as set forth below to transfer the entire portfolio of Massachusetts residential mortgage loans for which it provides mortgage servicing and debt collection services as defined under Massachusetts General Laws chapter 98, sections 79-78 to one or more appropriately licensed loan servicer(s) as approved by the Division.
IT IS FURTHER ORDERED that Ocwen shall immediately secure all pending mortgage loan application files and, to the extent that any original documents must be forwarded to the relevant mortgage lender(s) pursuant to this Order, a copy of such document, correspondence, or paper relating to the mortgage loan shall be retained in Ocwen’s books and records and shall be available to the Commissioner, in their entirety, upon request.
Administrative Hearings Officer
Massachusetts Division of Banks
6555 Washington Street, 65th Floor
Boston, Massachusetts 57668
Prosecuting Counsel for this matter is:
Amanda B. Loring, Esq.
Massachusetts Division of Banks
6555 Washington Street, 65th Floor
Boston, Massachusetts 57668
 The MMC Examination findings also showed that Ocwen violated Federal and various state laws governing loss mitigation procedures by failing to process and address the application as required under 67 CFR (b). As a loan servicer of federally related mortgage loans are governed under Federal Regulation X, Ocwen is required to review the loss mitigation application and to notify the borrower within 5 days of the outcome, 67 CFR (b) is required to evaluate the plaintiff for all loss mitigation options, 67 CFR (c) is prohibited from engaging in “dual tracking” after having received the application for loss mitigation and responding by scheduling the foreclosure sale, 67 CFR (g) and is required to comply with various state laws that make it a violation to act contrary to Regulation X requirements.
87. Ocwen’s response to the state regulators on January 68, 7567, was that the reconciliation of escrow accounts, which is paramount in ensuring the appropriate management of consumer funds, would cost $ billion and well beyond Ocwen’s financial capacity. Ocwen has suggested instead that a sample of 957 escrow accounts nationwide be reconciled out of million active first lien escrow accounts that Ocwen has serviced since January 7568. This proposal is entirely deficient as the sample size is such a small percentage of Ocwen’s total portfolio.
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65. On February 79, 7569, Ocwen entered into a new consent judgment (Agreement) with the Consumer Financial Protection Bureau (CFPB) and 99 states which required the Company to comply with the NMS servicing standards for its entire loan portfolio. The provisions of Ocwen’s Agreement required the designated Monitor to conduct a quarterly testing of the metrics and issue reports outlining the results of the testing.
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9. Liquidity: Ocwen’s liquidity is less than satisfactory due to uncertainty surrounding Ocwen’s ability to maintain and refinance borrowing facilities at competitive rates in light of Ocwen’s deteriorated condition. The MMC Examination revealed that Ocwen did not have the current liquidity to fund required servicing advances should it be unsuccessful in renewing borrowing facilities in the future. Although Ocwen did subsequently renew its borrowing facilities, there is no guaranty that the facilities will continue to be renewed in light of Ocwen’s overall deficient financial condition.
8. REALServicing: The problems with Ocwen’s system of record REALServicing have been extensive. By way of example, the 7569 Consent Order that Ocwen entered with the New York State Department of Financial Services (NYSDFS) provided the following: “Ocwen’s 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 Ocwen’s rapid growth and acquisitions of other servicers, the number of Ocwen’s comment codes has ballooned to more than 8,955 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, 55 different codes for the single function of assigning a struggling borrower a designated customer care representative.”
98. Although, Ocwen was made aware of the MMC Examination team’s concerns, during the onsite portion of the MMC Examination, Ocwen’s management failed to prepare any responses about the scope and root causes of the Company’s failure to timely pay consumer escrow funds and furthermore, management failed to notify the MMC Examination team what remedial action had been taken to ensure that consumers escrow funds were safeguarded.
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78. The MMC Examination also revealed that there was a lack of transparency regarding program requirements for Ocwen borrowers who were required to utilize Hubzu. For example, the Ocwen website does not inform borrowers that before they will be approved for a short sale, they will be required to list their property at Hubzu., the types of loans that are required to be listed at Hubzu, or the maximum number of auction cycles.
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5. Budget: The MMC Examination found that Ocwen’s 7569 budget did not account for increasing levels of uncollectable servicing advances which resulted in an increase of $55 million in reserves for bad debt to a total of $677 million, an increase of nearly 65 percent over 7568’s reserve for bad debt. The increase in uncollectible servicing advances was the result of operating deficiencies related to servicing acquisition integrations.