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OCN - Ocwen Financial


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Guest roark33

I would happily read through one of these PSAs.  They are listed on the law firm notice, any idea how to find these.  I am specifically interested in the voting rights.  Anyone?

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News is settlement with California http://www.latimes.com/business/la-fi-ocwen-california-settlement-20150123-story.html

 

I smelled a rat this morning when a hedge fund did a "public service announcement" lol that they were short the stock and OCN had "defaulted."

 

Bought some shares this morning at +- $6. Now up to $8 after hours on settlement news. This one is not for the fain of heart. Almost pulled trigger earlier this month around $10. Glad I didn't.. Love the analysis you guys have been doing.

 

Bet the hedgies got wind of the settlement and thus BS news this morning to exit short...

 

My take is there is too much money for Wall Street to make on both sides of the trade for there to be BK. But man, what a ride...

 

 

 

 

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Guest roark33

I think the loan mod issue is only one point.  The other points are the affiliate fees (i.e. mark-ups through using altisource), advance recovery practices, etc.  They claims these trusts have performed materially worse than those Trusts serviced by other Servicers.  It will be interesting to see how this all plays out next week and going forward.

 

Good little write-up of the firm that sent the notice of non-performance to OCN.  Looks like they aren't really ambulance chasers...

 

http://www.gibbsbruns.com/most-feared-plaintiffs-firm-gibbs--bruns-llp-11-06-2014/

 

 

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Guest roark33

MYDemarray, Any lead on a PSA for one of the RMBS mentioned in the Notice from Gibbs.  I don't think the HLSS default is good, but not fatal, but forcing a servicer change would be fatal, in my mind...

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Guest roark33

Finally found one....

 

http://www.sec.gov/cgi-bin/browse-edgar?CIK=0001391053&Find=Search&owner=exclude&action=getcompany

 

Well, here is all the filing on this trust.  Will update post when I find the specific PSA.

 

here is the specific PSA:

 

http://www.sec.gov/Archives/edgar/data/1391053/000139105307000004/sp1psafinal.htm

 

 

Looks like they need 51% to force a servicer change.  The leverage they have if they get the 51% is that I don't believe OCN can sells the MSRs if they are in default and the noteholders force a change.  From my reading of the PSA, the note holders just get to swap out the servicer.  I am sure NSM or WAC would line up to get those rights for free...

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From what I understand:

 

The goal of the contract is to make it hard for the investors to remove the Master Servicer.  If it was easy, then MSRs as an asset would be kind of sketchy.  There might also be something to do with REMIC tax laws; the investors aren't supposed to have control over the trust.

 

In practice, you'd have to actually read the PSA because the contract may not be very good at meeting its goals (e.g. they don't do a great job at solving the conflicts of interests between the servicer and the mortgage investors).

 

As far as this particular PSA goes, the Master Servicer could get fired if there is an Event of Default as defined in Section 7.01.  Here is the second clause of it:

 

(ii)    the Master  Servicer  shall fail to observe or perform in any material  respect any other of the covenants

        or agreements on the part of the Master  Servicer  contained in the  Certificates  of any Class or in this

        Agreement and such failure shall  continue  unremedied for a period of 30 days (except that such number of

        days shall be 15 in the case of a failure to pay the  premium for any  Required  Insurance  Policy)  after

        the date on which  written  notice of such  failure,  requiring  the same to be remedied,  shall have been

        given to the Master  Servicer by the Trustee or the Depositor,  or to the Master  Servicer,  the Depositor

        and the Trustee by the  Holders of  Certificates  of any Class  evidencing,  as to such Class,  Percentage

        Interests aggregating not less than 25%; or

 

If the Master Servicer screws up somehow, they have 30 days to remedy that failure.  And if there is still a problem, then there might be an Event of Default.

 

In practice a reason why you might file a lawsuit is to get the servicer to do a better job.  For example, Nationstar settled a lawsuit because the RMBS holders were unhappy that Nationstar was selling non-performing loans at fire sale prices on auction.com, which Nationstar owns a piece of (or it owns the whole thing; I don't know).  The reason why Nationstar wanted to do that was to lower its expenses.  If it sold off the NPLs, it would get back all of its advances right away rather than having to wait a year or two for the foreclosure and REO process.  Because Nationstar wanted to sell the NPLs at fire sale prices ASAP, bondholders would be hurt by the action.  Nationstar would also make money from the sale because it owned a piece of auction.com

 

In the end, Nationstar settled the lawsuit and cancelled the sale of the NPLs.  They also got sued by the buyer of the NPLs because Nationstar reneged on the sale.  (I'm not sure what happened with that other lawsuit.)

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The consent order with the California DBO is up on its website.

http://www.dbo.ca.gov/ENF/List/O/ocwenloanservicingllc.asp

 

Here are some highlights:

 

Prohibition on Acquisition of Mortgage Servicing Rights

3. Upon the effective date of this Consent Order, Ocwen will cease acquiring any additional mortgage servicing rights, from any source, for loans secured by properties in California until the Department is satisfied that Ocwen can satisfactorily respond to the requests for information and documentation made in the course of a regulatory exam.

 

Servicing Practices Review

14. The Auditor’s Servicing Practices Review will assess Ocwen’s operations with respect to loans on 1-4 family unit residential property located in the State of California. The Servicing Practices Review will, at a minimum, assess the following:

a. The adequacy of Ocwen’s staffing levels and staff training in business programs responsible for statutory disclosures to a borrower once a loan is delinquent, assignment of a long-term single point of contact to a borrower, review of foreclosure prevention alternative applications and loans in risk of delinquency, risk of default and loans in foreclosure.

b. The sufficiency and integration of Ocwen’s internal systems for storing and maintaining updated information once a borrower’s loan is acquired for servicing by Ocwen.

c. The effectiveness of communication between third party vendors and Ocwen once a borrower has been referred for foreclosure. This analysis should include access by third parties to Ocwen’s systems and current borrower information, including pending applications for foreclosure prevention alternatives.

d. The completeness and sufficiency of policies and procedures governing Ocwen’s loan servicing practices and that they enable compliance with the law.

e. The accuracy of borrower account information for all loans serviced by Ocwen.

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Guest roark33

Thanks for posting the consent order.  Couldn't find it on Friday.  I think the consent order and auditor is a path for California to seek monetary fines from Ocwen, similar in size and relation to NY DFS settlement.  I can't see California allowing NY to get 10k for each foreclosed homeowner and California homeowners getting nothing (or a measly $1000) from the National Mortgage Settlement (not to mention the $100m slush fund that NY received).  I can't imagine Ocwen's practices were any different in California than in NY.  And queue the others states.  The same source who mentioned to me earlier this week about the RMBS investors suing told me that Texas opened an investigation on Thursday this past week. 

 

Ocwen's stock will mostly likely skyrocket on Monday, but longer term, you have to start eyeballing the amount of settlements that are going to come from each state.  People will think that the $2.5m settlement was a payment for the entire issue in California, but it was merely a slap on the wrist for not turning over the paperwork in an orderly manner.  Now, that the paperwork is going to be turned over and an auditor on site, the first thing the auditor is going to do is look into any backdated letters to California homeowners in the past 6 months.  Once they find a few of those, then the really monetary fines will come.  As always, just great for the pure entertainment value. 

 

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Guest roark33

This is a great defense by Ocwen, taking the side of the homeowner against "certain hedge funds"...claiming the hedge funds want to foreclose and not do any modifications.  Great PR spin...

 

Glad to see Ocwen fighting back a little...

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Guest roark33

I really think people are realizing that the "settlement" was in no way comparable to the NY settlement.  CA didn't have an on-site regulator like the DFS did.  OCN agreed to an auditor in the process, which in my mind, is a precursor, to an actual monetary penalty down the road.  CA will absolutely push for similar terms as those received by NY DFS, so 2500 homeowners foreclosed last year, that's at least 25m, plus no new MSRs.  Just means the melting ice cube will continue.  I also think people are starting to realize that the profitability of OCN and ASPS is going to be seriously hampered when you have a regulator looking over your every move.

 

For example, lender forced placed insurance, and its associated kickbacks, were extremely profitable for servicers (and asps), but sketchy to the point that the have agreed to stop doing it.  Do you really think that this was the only practice that was extremely sketchy that they are going to have to stop doing?  Remember Cross Country mailing scam? 

 

 

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I am not sure why you think all mistakes were released through the settlement.  I am referring to ongoing mistakes, for example, the backdating of letters.  A settlement for past errors doesn't give you cover on mistakes you make in the future.

 

The national mortgage settlement effectively covers OCN for servicing mistakes, even beyond the settlement date

 

Guowei-- are you sure you are reading the settlement correctly? I see a section titled "Release"-- which specifies that the period for which Ocwen has been released extends only to Dec 2012. Is it possible that the metrics and oversight laid out in the settlement is merely in addition to the State AG's ability to prosecute for ongoing (illegal) mistakes in Ocwen's servicing?

 

http://www.dfi.wa.gov/sites/default/files/consumer-services/enforcement-actions/C-13-1153-14-CO01.pdf?q=CS%20Orders/C-13-1153-14-CO01.pdf

 

It seems to me like this is a pretty important issue to understand, so trying to make sure I nail it down.

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I am not sure why you think all mistakes were released through the settlement.  I am referring to ongoing mistakes, for example, the backdating of letters.  A settlement for past errors doesn't give you cover on mistakes you make in the future.

 

The national mortgage settlement effectively covers OCN for servicing mistakes, even beyond the settlement date

 

Guowei-- are you sure you are reading the settlement correctly? I see a section titled "Release"-- which specifies that the period for which Ocwen has been released extends only to Dec 2012. Is it possible that the metrics and oversight laid out in the settlement is merely in addition to the State AG's ability to prosecute for ongoing (illegal) mistakes in Ocwen's servicing?

 

http://www.dfi.wa.gov/sites/default/files/consumer-services/enforcement-actions/C-13-1153-14-CO01.pdf?q=CS%20Orders/C-13-1153-14-CO01.pdf

 

It seems to me like this is a pretty important issue to understand, so trying to make sure I nail it down.

 

Read my previous post on this matter.  In my opinion, all regulatory actions from state AGs and state mortgage regulators have to comply with the National Mortgage Settlement.  Yes, technically the release only covers until Feb 2014, but in order for the states to bring legal actions for sloppy process, they need to make sure OCN fails the compliance framework (operating metrics) laid out by the settlement.  Or else, what's the basis for the legal action if OCN meets the compliance requirements?  Obviously, if there is fraud or bad faith, then all bets are off, and OCN will be in trouble...but if it's sloppy process, then OCN has a chance to cure.  Your understanding is different?

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Guest roark33

Guowei58--If that is your understand, please explain why OCN settled with NY DFS?  Is your understand that since it was a different office, they didn't have to abide by the terms of the settlement?  That seems somewhat absurd, or at least very likely to happen in every other state, as it appears to already begun in CA with the DBO. 

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Let's focus on the FCF of OCN for 2015.  By my math, assuming the company doesn't sell any MSRs, the company generates $500M of unencumbered cash flow in 2015 despite the increasing cost of servicing, etc.  This is surprising because the company doesn't need to purchase MSRs and there is repayment of advances (net of match funding repayments).  OCN can do whatever it wants with this cash...Current market cap is around $900M.  My guess is that they will pay down some debt and use the rest to buy stock.

 

I'm not arguing that litigation and regulatory risks are not significant, but we have to look at the positives too:)  If management has testicles at all, TBV per share would increase in 2015 from buybacks.  If they sell some agency MSRs, then they would delever and shrink share count even faster.

 

 

 

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Guowei58--If that is your understand, please explain why OCN settled with NY DFS?  Is your understand that since it was a different office, they didn't have to abide by the terms of the settlement?  That seems somewhat absurd, or at least very likely to happen in every other state, as it appears to already begun in CA with the DBO.

 

NY DFS was not a party to the National Mortgage Settlement.  CA DBO and almost every other state's mortgage regulators were involved with the settlement...

 

There's a lot of history between OCN and NY DFS, dating back to 2011.  NY DFS had a monitor in place at OCN before the National Mortgage Settlement. 

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Let's focus on the FCF of OCN for 2015.  By my math, assuming the company doesn't sell any MSRs, the company generates $500M of unencumbered cash flow in 2015 despite the increasing cost of servicing, etc.  This is surprising because the company doesn't need to purchase MSRs and there is repayment of advances (net of match funding repayments).  OCN can do whatever it wants with this cash...Current market cap is around $900M.  My guess is that they will pay down some debt and use the rest to buy stock.

 

I'm not arguing that litigation and regulatory risks are not significant, but we have to look at the positives too:)  If management has testicles at all, TBV per share would increase in 2015 from buybacks.  If they sell some agency MSRs, then they would delever and shrink share count even faster.

 

Guowei I agree. I am actually on your side here at the current share price. I think the stock is undervalued even though I'm not sure I agree with you that the national mortgage settlement significantly covers Ocwen going forward.

 

I do hope management shows us their marbles.

 

no-marbles-o.gif.b1ada66656435ee6f6abf36426c6ad4a.gif

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Let's focus on the FCF of OCN for 2015.  By my math, assuming the company doesn't sell any MSRs, the company generates $500M of unencumbered cash flow in 2015 despite the increasing cost of servicing, etc.  This is surprising because the company doesn't need to purchase MSRs and there is repayment of advances (net of match funding repayments).  OCN can do whatever it wants with this cash...Current market cap is around $900M.  My guess is that they will pay down some debt and use the rest to buy stock.

 

I'm not arguing that litigation and regulatory risks are not significant, but we have to look at the positives too:)  If management has testicles at all, TBV per share would increase in 2015 from buybacks.  If they sell some agency MSRs, then they would delever and shrink share count even faster.

 

Guowei I agree. I am actually on your side here at the current share price. I think the stock is undervalued even though I'm not sure I agree with you that the national mortgage settlement significantly covers Ocwen going forward.

 

I do hope management shows us their marbles.

 

Just to be clear, I'm not saying that the National Mortgage Settlement is going to save OCN in all scenarios.  There are two scenarios that the Settlement doesn't cover:  1) Fraud or bad will, and 2) Inability to cure failed operating metrics as laid out by the Settlement. 

 

The settlement covers OCN in the scenarios of sloppy processes that can be remediated.  Lots of nuances I suppose.

 

There's a lot of risk and uncertainty in OCN right now, so I don't want to discount any of that.  I just think some people are drawing conclusions without any analysis, and that decreases the value of this forum.

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I like this type of reaction, bodes well that they are not just going to sit by and let the shorts eat them alive.

 

Agree with guowei that FCF analysis ought to be a component.

 

I'm an owner at $6. Only thing that scares me is that the big banks that Ocwen is messing with have the power to take them down. Still, this type of action from Ocwen is good in the sense that it shows the sharks they are not easy prey...

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