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ItsAValueTrap

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I agree with this point about something being up.  It doesn't really make sense for them to say, We are working with counsel to determine if we have disclosed everything on this call. 

 

If you want to disclose the facts, you put them in the script, and then you have disclosed it.  It isn't like you are waiting for someone analyst to ask the right question and no one does, so you have to wait till your 10-K. 

 

If they're buying back shares, then the concern about nonmaterial public information would be that ASPS is withholding good news rather than bad news?

 

If they withhold bad news and buy back shares, presumably they would not have litigation risk.

If they withhold good news and buy back shares, then there is a chance that they will be sued?  How does this stuff work?

 

*I'm definitely not a lawyer.

 

---

Here's my theory.

 

Altisource colluded with Ocwen to disguise kickbacks on force-placed insurance.  This is a grey area.  Normally, middlemen take commissions on home insurance.  You can view the stuff as commissions, brokerage profits, or kickbacks.  In any case, because they can be seen as kickbacks there is regulatory risk and litigation risk (from homeowners and mortgage investors).

It is Ocwen that generates kickbacks because Ocwen owns servicing rights and directs the purchasing of force-placed insurance.

 

You can see why Altisource might not want to come clean here.  It does not want attention from the SEC (because the deal may have treated one set of shareholders unfairly), class action lawyers, mortgage investors, GSEs, and regulators.

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I think withholding positive news to buy back shares is something that the SEC cares about a lot but shareholders very little.

 

Shareholders are more likely to sue based on slow/insufficient disclosure of the problems in NY and CA. I'm surprised that the usual lawyers have not already sent out press releases.

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I agree with this point about something being up.  It doesn't really make sense for them to say, We are working with counsel to determine if we have disclosed everything on this call. 

 

If you want to disclose the facts, you put them in the script, and then you have disclosed it.  It isn't like you are waiting for someone analyst to ask the right question and no one does, so you have to wait till your 10-K. 

 

Altisource colluded with Ocwen to disguise kickbacks on force-placed insurance.  This is a grey area.  Normally, middlemen take commissions on home insurance.  You can view the stuff as commissions, brokerage profits, or kickbacks.  In any case, because they can be seen as kickbacks there is regulatory risk and litigation risk (from homeowners and mortgage investors).

It is Ocwen that generates kickbacks because Ocwen owns servicing rights and directs the purchasing of force-placed insurance.

 

Just to clarify, forced place insurance wasn't an OCN only problem. Other servicers were accused of similar things: http://www.insurancejournal.com/news/national/2014/08/04/336633.htm

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Guest roark33

Regarding the OCN issue in California, the non-issue that some long-term bulls see this as, is surprising...

 

Imagine if Conn's was being investigated for deceptive marketing or up-selling without proper disclosure insurance policies on its products.  California was requested information, and Conn's was slow-walking the process--I think most people would see that as an obvious issue and conclude that they are probably doing something wrong.  Quantifying that wrong-doing would be the next step....

 

OCN's practices are much more opaque than most investors realize.  The fact that OCN is slow-walking the paperwork in California seems utterly absurd.  If you have a bias towards the long side, you may conclude that it is a regulator over-reaching.  I think that argument is weak here, because the regulator isn't even accusing them of wrongdoing that is borderline...They are just requesting documents, a simple clerical task that OCN has refused to comply with under threat of license revocation. 

 

What's even more absurd is that the LA Times broke this story.  That OCN didn't disclose this or reference it anywhere has got to push someone to think, hey this isn't the most ethical company.  It may be cheap (not my opinion), but you have to know who you are getting into bed with...

 

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At risk of exposing my own ignorance, what are you talking about Roark?

 

The issue has been known about since October.

 

The company says that they believe that they've gotten CA  everything requested.

 

Even NY's Lawsky used very reconciliatory language last week and said that they're consstructively working with OCN and look forward to working with them as they continue business, or something along those lines. 

 

If anything (and not that this is any better), CA just saw a $150 million pound of flesh extracted, so they're trying to play their own game of getting a settlement of their own. you don't get the bull side, and similarly I can't understand the obsession with insinuating that OCN is the next Enron.

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valueinvestor82 - i know the DBO issued a public accusation on their website in October.  But did OCN?  I may have missed it but can't find any 8-K or mention of them disclosing the DBO accusation or that their CA license  is being threatened by a regulator.

 

Would make a difference in understanding management's attitude towards disclosing material information to shareholders.

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If anything (and not that this is any better), CA just saw a $150 million pound of flesh extracted, so they're trying to play their own game of getting a settlement of their own. you don't get the bull side, and similarly I can't understand the obsession with insinuating that OCN is the next Enron.

 

It's unlikely the regulator is threatening to pull a license in order to extract money. They have sued Ocwen in administrative court, not for damages. If the California AG office gets involved (or if they are already investigating) that would be bad news for OCN/ASPS because they might see the potential for large damages comparable to New York.

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It's admittedly out of my area of expertise but I'm interested to know what limits are placed on CA to pursue certain types of claims. Keep in mind, NY didn't sign on to the national settlement that CA and other states did with OCN, so many states like CA have given up their right to sue for certain things. But maybe not others, so I don't know.

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Guest roark33

At risk of exposing my own ignorance, what are you talking about Roark?

 

The issue has been known about since October.

 

The company says that they believe that they've gotten CA  everything requested.

 

Even NY's Lawsky used very reconciliatory language last week and said that they're consstructively working with OCN and look forward to working with them as they continue business, or something along those lines. 

 

If anything (and not that this is any better), CA just saw a $150 million pound of flesh extracted, so they're trying to play their own game of getting a settlement of their own. you don't get the bull side, and similarly I can't understand the obsession with insinuating that OCN is the next Enron.

 

I would be interested to see any other public statements or items regarding the CA issue prior to the LA Times article.  I have looked at ASPS/OCN on and off for the past year and did not find any reference to that.  Admittedly, the price decline on Tuesday this past week in OCN/ASPS indicates that this news was not well-known.  I am happy to reveal my lack of due diligence ability, but I don't think anyone mentioned it. 

 

That's why I have made a point regarding the other 48 states, and whether anyone has looked at various regulatory websites to find if OCN is being investigated by Illinois or Ohio, etc.

 

I don't think OCN/ASPS is the next Enron.  That was an accounting thing.  I think all of the cash flow here is real, I just don't think it will last.  I think Erbey's brilliance was recognizing that he could, what I will call, skim from two separate parties in a single transaction.  On the one hand, you have defaulting homeowners, who are generally less likely to fight, or at least, not fight well.  You add in an extra $10 for preservation fee, late fees on insurance (even though the homeowner was paying insurance themselves), etc, etc, and these fees become large over time. 

 

At the same time, OCN/ASPS has been able to skim from the bond holders on the other side because they are so widely dispersed that there is no individual watching the hen house, so to say.  Over time, these fees add up, but in the short-run, OCN/ASPS can blame the situation on the bad housing market and the bondholders just say, ok. 

 

I am always surprised that no one goes back and reads the history of OCN, it has been a public company for quite some time and it basically did this for a while in the early 90s, until the regulators took away its ability to buy distressed loans because of how badly it treated the foreclosed homeowners.  There was a boom and then a big bust for OCN.  Ironically, the new Chairman at OCN to replace Erbey was the president of the original OCN when it was a bank. 

 

 

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Guest roark33

The more I think about the buyback, the more I bet it has to do with their thoughts surrounding their liquidity.  I think they realize their cash flow is going to be constrained in the near future and will need the cash to retire the debt.  But, you can't really say that on a conference call, so you mention that you need to clear the buyback with your GC and play it off as a legal thing. 

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They don't seem shy about warning that the buyback program will progress slowly:

Therefore we will be prudent in our execution of the share repurchase program and plan to retain cash to give us a long runway to achieve our initiatives.

The paragraph refers to the risks linked to Ocwen... but the debt is part of the reason: if they didn't have any/as much debt, they'd have more flexibility in dealing with those risks.

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Guest roark33

The language from the DFS settlement is pretty damning in regards to ASPS's supposed technological advantage, see below. 

 

Inadequate and Ineffective Information Technology Systems and Personnel

14. In the course of its review, the Compliance Monitor determined that Ocwen’s 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 automated—to catch all of these errors and resolve them.

 

15. For example, Ocwen’s 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, Ocwen’s systems show that borrowers facing foreclosure received letters with a date by which to cure their default and avoid foreclosure—and the cure date was months prior to receipt of the letter. Ocwen’s processes failed to identify and remedy these errors.

 

16. Moreover, Ocwen failed to fully investigate and appropriately address the backdating issue when an employee questioned the accuracy of Ocwen’s letter dating processes and alerted the company’s 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. 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 8,400 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. Ocwen’s reliance on technology has led it to employ fewer trained personnel than its competitors. For example, Ocwen’s 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.” Ocwen’s 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, Ocwen’s customer care representatives in many cases provide conflicting responses to a borrower’s question. Representatives have also failed in many cases to record in Ocwen’s servicing system the nature of the concerns that a borrower has expressed, leading to inaccurate records of the issues raised by the borrower.

 

19. Ocwen’s inadequate infrastructure and ineffective personnel have resulted in Ocwen’s failure to fulfill its legal obligations. Prior to the Department’s and the Compliance Monitor’s review, Ocwen did not take adequate steps to implement reforms that it was legally obligated to implement pursuant to the 2011 Agreement.

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Guest roark33

This might be the funniest move I have ever seen on a Form 4 filing. The filing was made in response to Cooperman crossing the 10% threshold on 12/18-ish period.  That follow-up filing (Form 4), indicates that Cooperman bought at prices ranging between 39-47, right before the DFS settlement and prior to the CA disclosure.  The form 4 below shows the pricing and dates Cooperman paid.  My question is if Leon has received any calls from LPs questioning the size of his testicles? 

 

Instead of a bullish indicator, it merely goes to show how badly Cooperman has done on this investment. 

 

Form 3

http://www.sec.gov/Archives/edgar/data/1462418/000089838215000001/0000898382-15-000001-index.htm

 

Form 4

http://www.sec.gov/Archives/edgar/data/898382/000089838215000002/xslF345X03/primary_doc.xml

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So I think this is how Altisource's BPO business works.

 

The person doing the grunt work gets paid $39.  (It's not actually grunt work.)

$1 is taken away from their $40 pay for REALTrans.

http://www.agentsonline.net/forums/ubbthreads.php/topics/414820/Altisource_Ocwen_BPO_Automatio.html

http://activerain.trulia.com/blogsview/53799/anyone-do-bpo-s-for-ocwen-

 

On top of the $39, Altisource will have various operating expenses and needs staff to talk to the people doing the grunt work.  And also to review the work.

 

For the BPO, I'm not sure what Altisource charges.  Ocwen used to have a fee schedule on their site but it's behind a login-wall now.  Fannie Mae rates for a BPO are $80.

https://www.fanniemae.com/content/announcement/ntce121710a.pdf

 

This seems like a high-margin business if you have Ocwen's scale.

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Latest new on Erbey complex.  As I mentioned on OCN board, hedge fund trying to force a change in servicer, which would cripple OCN and ASPS. 

 

http://www.prnewswire.com/news-releases/bluemountain-capital-management-llc-delivers-notice-of-default-on-certain-notes-to-trustee-of-the-hlss-servicer-advance-receivables-trust-300024840.html

 

The press release talks about:

Series 2012-T2 and Series 2013-T3 Notes issued in connection with the HLSS Servicer Advance Receivables Trust (the "HSART Trust")

This seems to refer to debt that HLSS has issued.  It also mentions:

 

BlueMountain also has directed the trustees of certain of the RMBS Certificates to investigate and/or take action with respect to Ocwen Loan Servicing, LLC.
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Guest roark33

It looks like you are right on the RMBS vs. the debt issued by HLSS.  I think the end game is the same though, if the debt is accelerated on OCN, their capital dries up and they become a forced seller of any MSRs that can get a bid. 

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It looks like you are right on the RMBS vs. the debt issued by HLSS.  I think the end game is the same though, if the debt is accelerated on OCN, their capital dries up and they become a forced seller of any MSRs that can get a bid.

 

How can debt issued by HLSS be "accelerated on OCN"?

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Guest roark33

Jay21, agree with your point, I meant HLSS.  HLSS may have recourse rights to OCN if they are in default under their servicing contract with HLSS.  That relationship was always a little fuzzy. I don't think anyone, including me, thought that HLSS might ever be in a position to fire OCN as the servicer...

 

 

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