WAC - Walter Investment Management

[cameronfen]

About six months ago, I did some work on Walter Investment Corporation, and I projected that earnings would go up a lot.  They have, but the stock hasn't moved at all.  Annualizing last quarter's results, the company is on pace to make more than 280 million dollars a year (this is also lower than annualizing the pace of the first three quarters of the year).  Next year, the company guides to 230 million dollars at the midpoint.  The reason for the decline is that mortgage originations had a large one time increase due to HARP refinancings.  A large majority of the company's earnings will be from mortgage servicing by 2014, which is much more predictable and stable when compared to originations.  The company has a 1.15 billion dollar market cap.  This is about a 4-5 multiple.  Nationstar Mortgage trades at 8 times.  Ocwen trades at 26 times (Ocwen is best in breed but it seems to me still a little high).  PHH trades at 11 times.  I think it is a bit late to the Mortgage Servicing Rights game, but if you are interested you can read more here: 

 

http://reminiscencesofastockblogger.com/?s=Mortgage+servicing+rights

 

I already am fully allocated but mainly I'm wondering why the price of the company hasn't gone up after the increase in earnings.  Of course, please talk about research as well. 

[morningstar]

I think the growth in earnings was pretty well advertised/guided given the acquisition of the Rescap MSR portfolio. Actually, earnings have been disappointing on net, with higher than expected onboarding costs and lower origination margins in the 2H13 following the taper. I think today's prices reflect several factors: (1) the sense that the easy MSR trade is over and that the remaining pipeline of deals to come out of the big banks will price without a meaningful discount to fair value; (2) much lower gain on sale margins which reduce near-term earnings and make the business more capital intensive since servicing-retained mortgages can't be originated and sold in a cash flow positive fashion; and (3) the realization that these servicing-dedicated companies may have a tough time developing a lasting business model.

 

To the third point, these special servicers (NSM, OCN, WAC) are each sitting on 100+ bn in servicing rights which will mostly run off over the next 7 years, with earnings from that book declining each year. You can refresh the book by buying more servicing from banks - e.g. Ocwen from Wells recently - but nowadays you're doing so at a not great IRR. Otherwise, to get new servicing you need to originate loans. HARP allowed these guys to originate through refis of their existing serviced loans - the servicer has a natural advantage in refis, most especially ones like HARP where there is a modification element. But if we are moving to a more purchase focused market, as seems likely with rising starts and rising rates, its hard to see what advantage these 3 have. The banks, as well as non-bank originators that have a very strong and focused origination channel (e.g. PHH, through its private label deals and Realogy partnership), have an obvious source of new origination, but the special servicers do not.

 

All in all, 2014 earnings will be good for these guys but I think the market might be starting to look ahead to 2016, 17, 18 earnings. And getting worried that for these companies, those years could all see double-digit earnings declines as their servicing books suffer severe attrition.

[bz1516]

I've owned the three major players, OCN, WAC and NSM.  If there were a prize for the space which looked the easiest to understand and the most straightforward, but was actually the most complex and mysterious, this would win it hands down.

 

it was possible to make money in the space before just by knowing that large deals would make the companies money  and as these deals came through, the stocks did well.  However now that these deals look like they are closer to the end of the pipeline than the beginning the stocks are flagging.

 

Aside from the expectation of large deals in the wings, i was never able to get a handle on what moves these stocks.  Everything seems to be the opposite of what you would expect, and there is always a new wrinkle.  I would be very careful at taking a position in these stocks at this time.

 

 

[cameronfen]

I agree with a lot of what Morningstar and bz1516 have to say, but my question to Morningstar is if the market is discounting the value of the company because MSR only last 7-8 years max why aren't HLSS, NSM, and OCN trading at the discount that WAC is. 

 

I think there is a way to guesstimate WAC cash flow using the cash flow OCN posts but that is not a priority for me so I might do that later.  Back of the envelope though, if WAC's cash flow is anything like OCN's cash flow per dollar of UPB, then WAC should have about 4 billion dollars in cash flow the next 10 years (pg 17 of the attachment to find OCN's projection for CF).  3 billion if you apply a discount factor at a 10% rate and an average duration of 3.5 years (which is what the duration for a cash flow that decays by 17% every year for 10 years).  This is already higher than WAC's EV and doesn't include future MSRs, the other businesses including Insurance, Asset Receivables and runoff.  Maybe the company is cheap.  I don't know.  I know now that I don't understand the business well enough to invest though. 

Ocwen_Investor_Presentation_Q2_2013_Sept-2013_v2.pdf

[morningstar]

I agree with a lot of what Morningstar and bz1516 have to say, but my question to Morningstar is if the market is discounting the value of the company because MSR only last 7-8 years max why aren't HLSS, NSM, and OCN trading at the discount that WAC is.

 

I don't see the discount as being quite so large. I come up with EV/EBITDA roughly as follows (don't have cash handy but excess cash is probably no more than 0.5x EBITDA for any of these names):

 

    14 est  debt  cap    EV    mult

OCN  1050    2230  6170  8400  8.0

NSM  575      2440  2640  5080  8.8

WAC  525      2400  1170  3570  6.8

 

It's hard to forecast EBITDA for these WAC and NSM in light of the very volatile origination margins we have seen in recent years. WAC has somewhat higher origination focus than NSM and far more than OCN. However, I am more tempted to say NSM stands out as expensive than that WAC stands out as cheap.

[RandyC]

I know nothing about MSR's but have became curious about WAC simply because GoodHaven Fund has owned it pretty much since the Fund was launched a couple years ago. GoodHaven is run by two former Fairholme analysts, and MKL made a significant seed $ investment in GoodHaven at startup. Is there any reason to think these guys see something in WAC that others are missing?

[scorpioncapital]

I think if you look at the accounting financials and certain qualitative questions, all the differences in valuation between WAC and OCN are as bright as day. The only conclusion I can derive is that OCN is inexpensive, and WAC is far more expensive. It is a value investors dream and reminds me of the example Ben Graham gave in Security Analysis where he showed one company where you punched in the numbers and they came out less than another company, then he goes on to prove that the one with the higher numbers is actually cheaper and the one with the lower numbers.

 

 

[jch548]

I used the search function to see if WAC has been discussed at all and I found a thread!

 

Not sure I can ever fully grasp this beast. Putting aside complexity and credit risk issues I was curious about the burn rate of their UPB of servicing rights vs what they are adding via originations.

 

If you go to page 35 of the 10K for Q114 where they reconcile the beginning and ending fair value estimate of Servicing Rights it says they capitalized $52,613,000  of "Servicing rights capitalized upon transfers of loans." They ended the qtr with $1,513,830,000 in Servicing rights at fair value.

 

Now assuming the servicing rights of $1,513,830,000 have a remaining life of 6.6 years the balance will decline by $229,368,000 a year without any additions or other fluctuations.

 

As they capitalized $52.6mm of "Servicing rights capitalized upon transfers of loans" during the qtr that would be a $210.4mm annual run rate. (I'm assuming these were from loans they originated). So if I'm interpreting this correctly they are treading water with respect to their main income producing asset "Servicing Rights."

 

Now having read the thread I see the main argument against WAC is their servicing rights and the income from them will decline annually and they need to do acquisitions to keep this business going.

 

If their originations hold up perhaps the stock deserves a high multiple.

 

Comments?

 

 

 

 

 

 

[jch548]

WAC gave an update recently on their Q2 operations.

 

"Serviced UPB has grown slightly from Q1 levels through MSR acquisitions and additions from originations platform.

•ARM acquired $3.3 BN UPB portfolio with future flow options."

 

Looks like their UPB is holding up. Not sure what they mean by "ARM." Something reverse mortgage?

 

Still working over the financials when I have time. Over 30% FCF yield on the common is possible based on my Q1 numbers.

 

My simple ebitda for originations for Q1 was $32mm. Insurance came in at $15.8mm. If I get around to it I want to see what their non-servicing business might be worth. They are getting hit on their insurance operations by regulators. They expect this business to decline but are looking for loopholes I think.

 

Originations has been a fairly stable business over the past few years. Volumes are down but they remain profitable. I mean their Origination business could be worth a billion not counting the servicing rights they retain.

 

 

 

[jch548]

Servicers are under pressure today. The article mentions some problems that may be associated with auction activities on foreclosed homes.

 

Not sure where WAC stands here. I would guess they may auction foreclosed properties but thru my reading I don't recall them having their own auction business. If a third party actually oversees the bidding and selling that would give them some cover.

 

Article below....

 

NY regulator mulls probe of CMBS loan servicers

 

9:49pm IST

 

* Lawsky eyes probe of commercial real estate loan servicers

 

* Focus on business conflicts and impact on bondholders

 

* Auction sites expected to fall under heavy scrutiny

 

By Joy Wiltermuth

 

NEW YORK, July 1 (IFR) - New York state bank regulators are preparing an investigation into commercial real estate mortgage loan servicers whose related businesses may be in conflict with the bondholders that the loan companies are supposed to protect.

 

Benjamin Lawsky, the superintendent of New York's Department of Financial Services, will be leading the initial investigation, a source with knowledge of the matter told IFR.

 

"He is looking at these firms to identify if subsidiaries they have developed are profiting from loans they are servicing," the source said.

 

The top three servicers of defaulted CMBS loans, by far the most profitable part of the servicing sector, are CWCapital Asset Management, C-III Asset Management and LNR Partners.

 

Together they held almost 80% of the market for servicing defaulted CMBS loans at the end of 2013, according to Fitch Ratings.

 

But they also all have investment arms that target the same types of problem loans and distressed properties that the servicers handle - lines of business that are expected to be at the heart of the probe.

 

Fortress Investment Group, for example, bought CWCapital, which manages the 110-building Peter Cooper Village Stuyvesant Town mega-complex in New York City.

 

CW gets paid to oversee the property's US$3bn defaulted CMBS loan as a servicer, but also controls the process that will determine what the property sells for - and Fortress is planning to bid on the property for the lowest possible price it can get.

 

"If they are servicing an asset for a third party and have to sell a note, or are taking back property, what steps are they taking to prove they got market bids?" one observer said.

 

"That seems to me what are going to check."

 

 

OCWEN AGAIN?

 

Lawsky's office declined to comment on the CMBS probe or provide any details on when it might be formally launched.

 

People briefed on the situation at all three companies told IFR they had not yet received letters from Lawsky's office. The source, though, said they would be on the way within weeks.

 

It's unclear what fines might be doled out - or if any suspected activity is illegal - but punishments in a similar investigation of the residential servicing space have been hefty, and the big CMBS players are on high alert.

 

Ocwen Financial Corp, the nation's largest non-bank residential mortgage servicer, has come under regulatory fire.

 

It was penalized US$2.1bn last year by the Consumer Financial Protection Bureau (CFPB) and 49 states over charges that it improperly foreclosed on borrowers, and had to compensate people who lost their homes to foreclosure between 2009 and 2012. It also promised principal reductions in a three-year period to others.

 

Lawsky's investigation into the RMBS sector, unlike that of the CFPB, is focused just on the size and scope of the related servicing businesses at Ocwen and rival servicer Nationstar - honing in on whether the two firms have grown too big to handle the volume of loans they service, and if they overcharge investors and borrowers to auction off foreclosed properties.

 

Some are worried that CMBS servicers could be blocked from pursuing some of their ancillary businesses, just as Lawsky's RMBS probe put at least a temporary halt to their explosive growth in the residential mortgage servicing arena - growth only made possible as new regulation forced banks out of the sector.

 

 

HEAT ON AUCTIONS

 

Scrutiny of CMBS auction arms - including LNR's stake in Auction.com - is therefore likely to be particularly intense.

 

In his probe of Ocwen, Lawsky has been concerned about whether its online real estate auction house Hubza was charging higher fees when the costs could be passed off to RMBS bondholders.

 

When Ocwen used the site to host a foreclosure or short sale, Hubza charged a 4.5% fee - a rate that dipped as low as 1.5% when it competed for business from third-party sellers.

 

It's still not clear what changes could be in store at Hubza, but bidders on Auction.com told IFR they expect similar questions to be asked about fees charged on the site and the way the bidding process works.

 

The mechanism is very opaque, and critics say that there should be more disclosure on the process for bidding on assets, minimum sale prices and fees charged across the board to buyers and sellers.

 

So far, though, CMBS bondholders have struggled to mount any lawsuits to force servicers to be more transparent about their activities - simply because they are not obliged to do so.

 

And servicers hope that will not change.

 

"What's transpired in CMBS is different with sophisticated parties," one servicer said.

 

"A lot of the issues with RMBS - clearly some of the abuses - warrant a level of scrutiny because it involves consumers." (Reporting by Joy Wiltermuth; Editing by Natalie Harrison and Marc Carnegie)

 

[morningstar]

Non-bank servicers were down today mainly on the FHFA inspector general's report, which was fairly critical of practices at these companies. It's a direct blow to the growth story for WAC et al. who stand to face additional scrutiny over any future bulk MSR transfers.

 

WAC (and NSM and OCN) have pretty negligible exposure to CMBS servicing.

[jch548]

I haven't seen anything directed specifically at WAC. Sure its never positive to have the regulators scrutinizing your business but I guess its to be expected.

.

I'm still long WAC. Originate mortgages and service mortgages. Hard to see the business going away. These stocks could get some wind at their backs if anyone makes a decent MSR acquisition but in reality the way WAC is priced they only need to tread water for the stock to see some appreciation.

[jch548]

From Morgan Stanley Mortgage Monocle.....

 

 

FHFA watchdog highlights concerns with nonbank servicers; we expect little impact to large specialty servicers. The Inspector General of the FHFA released a report on nonbank servicers 1) highlighting concerns regarding the use of short-term funding and operational capacity and 2) citing an unnamed company whose transfer activity was suspended in 2013. In our view, the report recommends formalization ofprocedures already done on an ad-hoc basis, and the short-term funding concerns do not pertain to NSM or WAC. Based on conversations with our covered companies, we don’t believe either WAC or NSM was the unnamed company cited. Separately, Reuters reported that Benjamin Lawksy is preparing a probe into CRE loan servicers regarding potential business conflicts with their investment subsidiaries.

[jch548]

Downgrade seems rather dubious. Isn't the consensus around here that cash flows should be very strong for servicers?

 

 

Nationstar, Walter Investment downgraded to Underperform at Wells Fargo

Wells Fargo downgraded both Nationstar (NSM) and Walter Investment (WAC) to Underperform from Market Perform and reduced its sector weighting for Mortgage Servicers to Underweight from Market Weight after its cash flow analysis pointed to share downside. Wells also highlights the continued regulatory issues for the space. The firm lowered its price target range for Nationstar shares to $25-$27 from $29-$32 and for Walter to $22-$24 from $27-$32. Wells keeps Buy ratings on Home Loan Servicing (HLSS) and PennyMac (PFSI

[morningstar]

The WFC piece is talking about a discounted cash flow analysis... the companies have plenty of cash flow in the near years but it stands to tail off substantially as the portfolios run down.

[jch548]

What has changed all of a sudden to cause a downgrade? Seems rather suspect to me.

 

I understand the DCF and implications of a run-off in servicing rights but the six or seven year life of these rights doesn't speak to the fact that they are always adding MSR balances to their pile via acquisitions and originations. Via originations would be the key here as this is organic. UPB of MSRs should be greater at the end of Q2 vs Q1.

 

Also, equally important is the Originations business which is generating annual ebitda at a $128mm rate. This is worth a billion at an eight times multiple. Net of associated debt this has to be worth something $600mm, $800mm? WAC market cap is barely over $1B.

 

It all looks rather bullish. I guess what bothers me at the moment is the $36mm in interest expense that went unallocated to any of their segments. I mean what is this debt supporting? 

[morningstar]

What has changed all of a sudden to cause a downgrade? Seems rather suspect to me.

 

I understand the DCF and implications of a run-off in servicing rights but the six or seven year life of these rights doesn't speak to the fact that they are always adding MSR balances to their pile via acquisitions and originations. Via originations would be the key here as this is organic. UPB of MSRs should be greater at the end of Q2 vs Q1.

 

Also, equally important is the Originations business which is generating annual ebitda at a $128mm rate. This is worth a billion at an eight times multiple. Net of associated debt this has to be worth something $600mm, $800mm? WAC market cap is barely over $1B.

 

It all looks rather bullish. I guess what bothers me at the moment is the $36mm in interest expense that went unallocated to any of their segments. I mean what is this debt supporting?

 

I agree with a lot of what you say, but something clearly has changed in the last few months which is the much increased regulatory scrutiny of MSR bulk transfers. Base case this will probably just result in higher servicing costs, but in a downside case we might have seen the end of $10+bn UPB servicing transfers. Especially since meanwhile lower delinquencies and healthier capital levels are making it easier for banks to just sit on the servicing they have rather than deal with trouble from their regulators.

 

WAC's internal origination from its MSR portfolio is unlikely to represent better than 25-35% recapture in the long term (probably much lower, especially if rates are headed upward over the next ~5 years), and its other internal origination avenues besides correspondent are relatively very small. Correspondent & wholesale business is pretty easy to gather but creates negative cash margin in the origination segment. It also carries large potential for hidden liabilities if we get ourselves into another crisis.

 

Additionally, I think investors are wary of significant guidance reduction from players in this space after 2Q earnings. In particular I am looking for NSM to cut its FY14 guidance, though I think WAC is pretty likely to do the same.

 

I'm long WAC vs. a short in NSM.

[jch548]

Well I'm glad you don't seem as bullish as me because maybe I'll learn something.

 

Going back to Q1 they added 52.6mm of "Servicing rights capitalized upon transfers of loans." I'm thinking these are MSRs retained via their origination activities. They make the loan, sell the loan and then keep the MSR. Or I suppose a portion could also be from refinancing loans they had already been servicing but that still get run through originations I would think.

 

You don't seem to think they will be able to add MSRs at this rate going forward. Am I missing something? Perhaps they are originating more loans due to the HARP program. Thus when this goes away the UPB of MSRs will begin their decline. Is that your reasoning?

 

For what its worth MS is forecasting originations to be up from Q1 the rest of the year.

 

 

 

[yadayada]

A few things to note why I think Ocwen is better.

 

1.capital allocation. This is huge, some well timed buy backs can greatly increase returns, and as I explain below, this business is about to throw off huge amounts of cash. Have more faith in Erbey then in the other servicers. Look at Autozone. Doubled earnings, and stock was like a 5 bagger or so over that period.

 

2.One off costs due to large expansion of MSR's. 2013 had larger then usual costs. I like how the VIC write up thinks about this. in run off this thing can easily generate a billion $ this year. And one off costs are for infrastructure to handle the larger amounts. Ofcourse getting new UPB in the future will have costs, but not as high as incurred in 2013.

 

3.OCN is better then WAC. They have worse loans, handle them at lower cost having a lower complaint ratio:

http://ify.valuewalk.com/wp-content/uploads/2014/03/tRW7I9h.png

 

4.note in the above the 60 day delinq ratio of Ocwen. Historically cost comes down a lot after they just bought a bunch of MSR's (and they bought a lot recently) and restructured them. Erbey is actually the best at this in the industry. And costs will come down for this if a larger % stabilize. If they restructure a bunch succesfully, cost difference could be between 300$ and 75$ ( the latter if they get it stable). So I think you will see costs come down from this as well.

 

5.looking at run off value if interest rates don't go up downside is limited. But i think interest rates will go up over the next 10 years or so. This will reduce downside in absolute worse case to almost zero I think.

 

6.If they do get new UPB to let's say 700bn$ (currently 450), there are scale advantages as well. And margins will expand even more. some say 4 trillion  (out of 10 trillion total), but this is unlikely. But note that to make a killing Ocwen doesn't need to double or triple UPB necesairily.

 

7.Unless regulator rolls this up, it seems very likely they will get new UPB in the form of originations in the future. This will likely prevent run off or even increase.

 

Don't let yourself get fooled by earnings multiples here imo.

 

To sum it up, if interest rates go up a bit, Regulator backs off in a year or so (and rationally he really has no good reason to go after these guys), and they get even a little bit of new un paid balance, this one is at least a double. What I also like is that this one hedges itself. If costs don't come down due to stabilizing loans, then that is likely macro economic. This probably happens with the banks too then, which will give them more UPB to buy.

 

Finally if there is no more new UPB to buy, why did a lot of banks start selling long before basel 3 regulations would go into play for such discounts? That probably means there is still more to come. Think about it, if you had to sell 100 items in the next 3 years, would you sell 95 in year one? Or spread it out more and get a higher overall price. The large disadvantages for holding these large MSR's don't really go into play once Basel 3 actually happens.

 

Add a few well timed buy backs and that could nicely enhance upside here.

 

Oh and forgot

8.Erbey is best in the business at squeezing money out of the really bad loans. There well always be loans like this, and there are still plenty left as well. So unless regulator shuts down OCN which would seem very irrational and bad for everyone involved, It looks like value is much more then 5.5 bn$ here. And if everything goes right, upside could be in the several 100% for Ocwen over the next few years.

 

9.And forgot this one as well, Reverse mortgages:

In addition to continuing investments in our servicing business, we have also invested in adjacent markets, including forward and reverse mortgage lending. Ocwen provides forward and reverse mortgages directly, through call-center-based operations, and indirectly, through brokers, correspondents and relationships with lending partners. Mortgage lending is a natural extension of our servicing business, as a substantial portion of our lending business comes from refinancing loans from our servicing portfolio. Liberty Home Equity Solutions, Inc. (Liberty) is the leading reverse mortgage originator based on industry data for November 2013. Based on Consumer Financial Protection Bureau (CFPB) data, we estimate the total potential size of the reverse mortgage market at $1.9 trillion, of which only about 3% has been penetrated to date. We believe the reverse mortgage business is a substantially under-developed market relative to its potential, and that it provides a potential source of long-term growth for Ocwen. Ocwen will continue to evaluate new adjacent market opportunities that are consistent with our growth strategies and to which we believe our competitive advantages in process management and financial services are transferable.

[yadayada]

It all looks rather bullish. I guess what bothers me at the moment is the $36mm in interest expense that went unallocated to any of their segments. I mean what is this debt supporting?

 

I think this is an accounting thing, similar to OCN they have another entity that will hold the MSR's. But untill this is approved the amortization is still on WAC's statement. And they also charge a higher interest, this is the revenue split thaat goes to the financing entity. So technically revenue should be lower, amortization should be lower, and interest expenses should be lower. But how that works out in detail, I don't know. This will become more clear over time though when all the transfers of MSR's are completed.

[jch548]

I just read the VIC write up for WAC. The author seems very bullish. He also seems to think that the origination arm of the business will in large part help replenish the UPB. Very high on more MSR business coming their way.

 

The steady state ebitda analysis which included $65mm from Reverse Mortgages and $65mm from "Other" was lacking as he did not expand on this. I believe he is thinking that in a few years the Reverse Mortgage business will be turning a profit where they are at a loss now. It may be a fair assumption but where is this "Other" $65mm ebitda to come from?

 

He didn't seem to concerned about the HARP program ending after 2015. I might agree here. It costs the borrower to do a HARP refinance just like it would cost a borrower to refinance a non-distressed property. Thus I think the interest rate environment is the key driver.

 

Thanks for the feed back Yada. When I have a chance I'll take a closer look at Ocwen. I still like the MSR angle for these companies. Starting to see a couple of weak points with WAC mainly their leverage.  I understand Ocwen is on better footing.

[ItsAValueTrap]

If you own MSRs, you want interest rates to stay flat.

If they drop, people will refinance and your MSR will end early.

If interest rates rise, the value of your MSR will fall for the some reason bonds lose value when interest rates rise.

[yadayada]

really? that is only true if inflation is also going up with rising rates? would you say flat rates>rising rates>lower rates?

 

seems that when artifical supply from fed comes down, rates go up, but not necesairily higher then normal inflation?

[ItsAValueTrap]

Well if you assume that inflation stays flat, then you want interest rates to stay flat.

 

Higher inflation is bad for MSRs in the same way that inflation is bad for bonds.

Gov't bailouts are good for MSRs.

Unemployment is bad.

Loose credit for refinancings are bad.

Regulations are bad because servicing costs go up.  (In the long run, regulations may be good for companies that specialize in servicing.)

 

MSRs are weird and complex.

[yitech]

If you own MSRs, you want interest rates to stay flat.

If they drop, people will refinance and your MSR will end early.

If interest rates rise, the value of your MSR will fall for the some reason bonds lose value when interest rates rise.

 

MSR should be similar to mortgage Interest-Only strips, though not exactly the same. Servicers could re-capture some of the value lost if the homeowner chooses to refinance with the same originator/servicer while values are lost for the IO holder when home owner refinances.

 

When the mortgage rates rise, the value of MSR should actually increase as people prepay/refinance slower. Only when the rates rise a lot will the value of MSR start to drop to reflect the effect of the higher mortgage rates that offset the slower prepayment rates.

 

There is a paper I found online that talks about MSR vs interest rate volatilities: http://www.kalotay.com/sites/default/files/private/Mortgage_Servicing_Rights.pdf