The document discusses the residential mortgage services offered by NewOak Credit Services, including credit underwriting and due diligence, mortgage regulatory compliance, servicing oversight and advisory, and RMBS litigation and enforcement actions. NewOak provides consulting, advisory, and professional services to help clients address challenges in areas like regulatory compliance, risk management, and legal issues throughout the loan lifecycle.
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When we talk about “centralizing” in business and commercial banking, its often received with a negative connotation. Centralization to many implies reorganizations and layoffs. This session is intended to educate attendees on centralization initiatives, communicate the potential upside, potential downside, and dispel myths that are often associated with this dichotomy. The session will also discuss if and when centralization efforts should be contemplated by financial institutions, steps/best practices in doing so, potential change management/cultural implications, and what parts of the organization should be involved. Lastly, the session will secondarily address portfolio segmentation efforts necessary to achieve efficiencies.
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3. NEWOAK CREDIT SERVICES’ RESIDENTIAL MORTGAGE SERVICES
Consultants for: Banks ▪ Finance Companies ▪ Credit Unions ▪ Servicers ▪ Sub-Servicers ▪ Investors ▪
Specialty Finance Companies
NewOak Credit Services is an independent consultancy specializing in credit and regulatory
compliance services for the residential mortgage, consumer finance, and specialty finance
industries.
Our Residential Mortgage Services group supports and advises originators, servicers, investors,
and other industry participants through challenges relating to potential risk or liability, regulatory
burdens, and onerous data and technology demands. Leveraging our team of expert market and
legal practitioners and a proprietary platform, we are able to provide clients with end-to-end support
throughout the loan lifecycle – from underwriting, servicing, and loan-level analysis to broad legal
strategy consulting.
NewOak Credit Services’ Residential Mortgage Services offers a comprehensive suite of
consulting, advisory, and professional services to help clients tackle today’s challenges in the
residential mortgage business.
Credit
Underwriting &
Due Diligence
Customized loan-level and quality control reviews, providing the
transparency necessary to understand and mitigate potential risks.
Regulatory
Compliance
Solutions to navigate today’s dynamic regulatory landscape, from
origination through servicing, to ensure compliance with federal, state,
and local laws and regulations.
Servicing
Oversight &
Advisory
Enhanced assessment, monitoring, reporting, and compliance tools
necessary to stay ahead of the challenges of today’s marketplace.
RMBS Litigation
& Enforcement
Actions
Development of legal strategy and loan-level evaluation of residential
mortgage portfolios under strict court and regulatory mandated
deadlines.
4. Credit Underwriting & Due Diligence
MORE THAN JUST ANOTHER QUALITY CONTROL COMPANY
NewOak’s Credit Underwriting and Due Diligence services allow our clients to understand and manage the quality of
loans originated. We perform customized loan-level and quality control reviews that provide the transparency necessary to
understand and mitigate potential risks stemming from the constantly changing regulatory climate and create efficiencies to
maximize profitability and increase originations.
NEWOAK’S SUITE OF SERVICES
► Credit Underwriting
► FHA Review
► Reverse Mortgage Review
► Risk Assessment Review
► ATR / Non-QM Review
► Repurchase Review
► Quality Control Review
► Pre-Funding QC
► Post-Closing QC
► Pre-Acquisition QC
► Trailing Document Review
► TRID Review
► Operational Review
NewOak possesses the hands on experience necessary to understand the challenges facing lenders today. Due
Diligence is key to circumvent and drastically reduce the potential for repurchases, indemnifications, litigation, and monetary
losses.
QUALITY ASSURANCE SUPPORT
NewOak offers reviews that meet the requirements of
Fannie Mae, Freddie Mac, FHA, and VA performed by our
experienced team of credit professionals. We provide
guidance and solutions including risk identification and
management and training tailored to firms operating in a
complex and dynamic environment.
ON-GOING COMPLIANCE SUPPORT
NewOak provides the ongoing monitoring and quality
control needed to proactively ensure regulatory compliance.
PROFESSIONAL SUPPORT
NewOak brings strategic implementation and transparent
project management, such as customizable and
comprehensive reporting, on-demand mortgage staffing
solutions, and training.
We offer a comprehensive menu of services
to support lenders in today’s evolving
regulatory climate.
What can NewOak do for you?
1
5. Mortgage Regulatory Compliance
NAVIGATING THE REGULATORY
LANDSCAPE
NewOak’s Regulatory Compliance services help clients
navigate the regulatory landscape from origination through
servicing to ensure compliance with applicable regulations. • Compliance Program Development
• Complaint Management
• Monitoring and Reporting
• Training
• Independent Audit
Compliance Management System
Development
• Operational Effectiveness
• Product and Program Gap Analyses
• Development of Controls
• Regulatory Change Management
• Compliance Program Enhancement
Compliance Risk Assessment
NEWOAK’S SUITE OF SERVICES
• Loan Portfolio Statistical Analysis
• Policy and Procedure Reviews
• Products and Marketing Comparative
Analysis
• Vendor Agreements
• Internal Controls
• Self Assessments
Fair Lending Risk Assessment
• Proactive Audit Preparation
• Policy and Procedure Review
• Gap Remediation
• Mock Regulatory Audits
• Sample Loan Review
• Incorporation of Regulator Audit
Issues into Protocol/Procedures
Regulatory Examinations
• Compliance Gap Analysis
• Federal and State Compliance Review
• Vendor Compliance
• Portfolio Due Diligence
Independent Audit
• Compliance Gap Analysis
• Compliance Program Enhancement
• Conduct Loan-Level Reviews
• Vendor Compliance
• Training
TRID Review
Compliance & Operational Review
Situation
The client, a top mortgage lender, sought to understand and
mitigate any potential risks with respect to its lending and
servicing operations.
Services Offered and the Deliverables
NewOak conducted a gap analysis of existing process and
procedures, reviewing a test file, performing a loan-level
servicing due diligence review, focusing on loss mitigation,
and identifying areas of potential compliance risk. The client
was delivered a written validation report that included the
loan-level servicing review results and compliance related
issues as well as recommendations. NewOak then
collaborated with the client to implement said
recommendations and monitor both newly implemented
protocols as well as those previously established. As a
result the lender is now in compliance and can maintain
operational integrity using standardized documentation.
CASE STUDY
2
6. Servicing Oversight & Advisory
BE PREPARED FOR NEW RULES THAT
IMPACT YOUR BUSINESS
Compliance management has become increasingly
complex given the changing regulatory landscape,
operational challenges (e.g., antiquated systems and
manual processes) combined with the normal course of
business (e.g., loss mitigation, foreclosure, and
modification, asset sales and transfers), resulting in
increased compliance risk, including regulatory actions,
customer complaints, and data migration issues.
• Compliance Program Development
• Complaint Management
• Monitoring and Reporting
• Training
• Independent Audit
Compliance Management System
Development
• Corrective Action Planning
• Corrective Action Management
• Corrective Action Effectiveness
Testing
• Settlement Administration
Remediation Services
NEWOAK’S SUITE OF SERVICES
• Non-Performing & Performing Loan
Review
• Policy and Procedures Review and
Development
• Gap Analysis
Operations Review
• Program Validation
• Foreclosure Audits
• Contracts Review
• Selection Monitoring
Service Provider Oversight
• Identification and Management Risk
During Transfer
• Servicing Due Diligence
• Data Integrity
Servicing Transfer Review
Minimize Compliance Risk & Improve Customer
Satisfaction
Obtain Compliance Assurance & Mitigate Risk
Minimize Regulatory Scrutiny
Remediate Identified Issues
NewOak has the requisite talent,
infrastructure and systems to help
clients:
NewOak’s Servicing Oversight and Advisory services
provide our clients with the enhanced assessment,
monitoring, reporting, and compliance tools necessary
to stay ahead of the challenges of today’s marketplace.
We provide customized solutions and guidance for
proactive compliance management tailored to our clients’
needs. Additionally, NewOak provides remediation services
if a servicer finds itself in the regulatory spotlight.
3
7. Servicing Oversight & Advisory
CASE STUDIES
Situation
The client, a mid-sized regional lender, through its internal
risk/compliance management efforts, identified payment calculation
errors in several pools of loans acquired over the course of many years
and from various entities. The client’s outside counsel retained NewOak
as an independent consultant to quantify the size and scope of the issue,
in addition to the root causes, and develop a plan for remediation.
Services Offered & Deliverables
NewOak spent several weeks on-site gathering information and
performing internal reviews. Using this information, NewOak
rebuilt an independent and flexible payment amortization
schedule with historical indices, calculated payments, and then
compared calculated payments to the historical payments. As a
result, the client was able to offer a plan for remediation prior to
additional scrutiny and fines, mitigating money damages and
reputational risk.
Situation
The client, a top tier bank, owned a portion of a venture formed by the
FDIC as a receiver and collateral agent of certain assets that were the
result of the failure of a number of banks. Pursuant to its Operating
Agreement, the client was required to service and manage a pool of
residential mortgage loans with over $300 million in unpaid balances on
behalf of the FDIC. During the course of the Agreement, the client
received a Notice of Events of Default from the FDIC, citing the client’s
failure to comply with the Operating Agreement and perform its servicing
and asset management obligations, resulting in the non-payment of
millions of dollars to the client.
Services Offered & Deliverables
Through outside counsel, NewOak was retained as an
independent consultant to assess the client’s servicing and asset
management standards, offering expert opinions on: the
appropriateness of offering non-HAMP modifications; acquiring
distressed assets during and in the aftermath of the financial
crisis; the methodology used to determine whether to sell a pool
of performing loans; the client’s performance in comparison with
securitization cohorts across key subsectors; industry defaults
and non-performance in relation to the bankrupt servicer’s
actions; and the validity of the FDIC’s specific findings.
MORTGAGE SERVICING OPERATIONAL AUDIT
MORTGAGE SERVICING STRATEGIC CONSULTING
4
8. DO FHA LOANS HAVE YOU CONCERNED?
NEWOAK HAS A TESTED SOLUTION
Increased scrutiny is resulting in claims against lenders that
originate FHA loans and sell HUD insured loans.
FHA Risk Management
• Confirm adherence to underwriting
policy and procedures
• Identify potential challenges based on
violations of underwriting guidelines
• Identify issues that may impact FHA
Insuring
• Identify trends for training purposes
Quality Control Reviews
• Conduct loan-level servicing due
diligence reviews
• Review policies and procedures
• Conduct operational reviews
Servicing Reviews
NEWOAK’S SUITE OF SERVICES
• Litigation support in defense of False
Claims Act cases
• Perform loan-level reviews and provide
an independent analysis, including a
materiality assessment
Strategy & Defense Services
• Provide clarifications using alternative
loan file documentation
• Conduct additional analysis of FHA
approved compensating factors
• Outline any loan attributes supporting
underwriting decisions
Remediation Services
• Provide end-to-end departmental
analysis to identify areas of
opportunity to mitigate existing and
future risks and improve efficiencies
• Identify lending risks
• Identify procedural and process gaps
QC Process & Procedure Reviews
Challenges of FHA Lending
Volume of Rules:
Isolating current rules can be daunting with the myriad of
requirements spread across regulations, guidance, handbooks,
mortgagee letters, and circular letters.
Frequency of Rule Changes:
The historical regulatory framework has been further
complicated by recent CFPB rulemaking and by overhauls at
the state level.
Disparate Agency Guidelines:
Agency rules do not always align, making compliance difficult.
For example, there is inconsistency between the FHA and
Fannie Mae’s loss mitigation waterfalls.
Leverage the NewOak team’s operational and compliance
FHA expertise to mitigate the risks or liability of FHA
underwriting by conducting loan-level reviews, preparing for
and responding to DOJ inquiries or False Claims Act
Litigation, and performing operational risk assessments.
Guideline Interpretation:
There is ambiguity and inconsistency of guideline
interpretation between the four jurisdictional Homeownership
Center’s (HOC) compared to HUD Washington, DC.
5
9. CASE STUDIES
Situation
A top tier bank was being sued by the DOJ under the Financial Institutions
Reform, Recovery, and Enforcement Act (FIRREA). The bank’s outside
counsel sought expert re-underwriting services to respond to the plaintiff’s
claims.
Services Offered & the Deliverable
NewOak was engaged by the bank’s outside counsel to conduct a re-
underwriting review and responded to the loan-level allegations brought by
the DOJ. Throughout the litigation process NewOak provided expert
support, including; allegation and loan-level analysis, report writing, and
expert deposition preparation. Delivered loan-level reports that included:
the plaintiff’s allegations; a rebuttal re-underwriting response to each
allegation with citations for relied upon documents and guidelines; an
independent assessment; and an allegation and overall loan grade. The
report was configured to the client and expert’s specific needs. Additionally,
in support of the expert throughout the litigation process, NewOak provided
expert report drafting and identified exemplar loan examples that
reinforced our re-underwriting methodology and highlighted discrepancies
with the plaintiff’s methodology.
Situation
A top bank was being investigated by the DOJ, for its FHA lending
practices. The bank’s outside counsel sought expert re-underwriting
services in response to the DOJ’s loan-level allegations that the loans did
not comply with the FHA guidelines at origination.
Services Offered & the Deliverable
NewOak was engaged by the bank’s outside counsel to conduct a re-
underwriting review and responded to the loan-level allegations brought
by the DOJ. Over the course of the response process, NewOak
accommodated a variable schedule and adjusted our team size as required
to work with the law firm on a variety of projects related to the review.
Delivered loan-level reports that included: the allegations; a rebuttal re-
underwriting response to each allegation with citations for relied upon
documents and guidelines; an independent assessment; and an allegation
and overall loan grade. The report was configured to the specific needs of
the client. Additionally, NewOak utilized the same employees and their
familiarity with the client to enable the client to meet multiple tight deadlines
on similar related matters and to assist outside counsel with post-review
deposition preparation.
Situation
The client, a national mortgage lender, sought an independent third-party
consultant to assess its FHA lending and servicing operations across all of
the department functions within the mortgage division. The lender retained
NewOak to conduct an operational review.
Services Offered & the Deliverable
NewOak conducted a gap analysis of the loan files as well as a loan-level
servicing due diligence review, focusing on loss mitigation, and identifying
areas of potential compliance risk. The client was delivered a written
validation report including the review results. For each loan reviewed, a
loan-level servicing and compliance report was provided. The report was
configured to the client’s needs and included any compliance related
issues for each loan reviewed. Where compliance related issues were
identified, recommendations for correction and remediation were
presented. NewOak then worked with the client to implement said
recommendations and monitor both newly implemented protocols as well
as those previously established.
RESPONDING TO DOJ INQUIRIES
COMPLIANCE & OPERATIONAL REVIEW
LITIGATION SUPPORT
FHA LOAN RISK ASSESSMENT
FHA Risk Management
6
Situation
The client, a leading US financial institution, was being investigated by the
DOJ for its FHA lending practices. The DOJ had informed the client that it
planned to bring loan-level allegations that the client breached FHA
underwriting standards. The client sought to take preemptive steps to
better understand its risks.
Services Offered & the Deliverable
Through outside counsel, NewOak was retained to identify a sub-set of
loans representative of the full sample and conduct a loan-level review to
assess whether the loans were in compliance with the FHA requirements in
effect at the time the loan was originated, including: assessment of the
consistency of information throughout the loan file; analysis of the loan’s
underwriting; assessment of the adequacy of the loan file documentation;
and assessment of the compensating factors or mitigating circumstances
for any issues identified. Additionally, potential DOJ findings were
identified. NewOak delivered loan-level reports that included an
assessment of: critically missing documentation; appraisal; employment;
DTI ratio; assets; housing history; and LTV. The report was configured to
the project’s specific needs.
10. RMBS Litigation & Enforcement Action
Consultants for: Banks ▪ Finance Companies ▪ Credit Unions ▪ Servicers ▪ Investors ▪ Specialty Finance Companies
WHAT ARE YOU DOING TO STRENGTHEN
YOUR DEFENSE?
NewOak Credit Services’ Residential Mortgage Backed
Securities (RMBS) Litigation & Enforcement Action offers
a suite of services that focus on the development and
support of our client’s legal strategy necessary in today’s
heavily regulated and litigious mortgage backed security
industry.
Utilizing NewOak’s proprietary platform, we perform
customized loan-level reviews, providing the transparency
necessary to understand and mitigate potential liability.
Clients look to NewOak’s subject matter experts for support
throughout the litigation process; from performing
comprehensive data collections and loan file and guideline
matching during the discovery phase, loan-level reviews and
preparation of expert reports, to deposition preparation. Our
team consists of credit and project management professionals
who understand the issues and risks faced by financial
institutions We help break down informational siloes to enable
easier access to data, comprehensive data collection reviews,
qualitative and quantitative loan-level analysis, and scalable
solutions.
SUBJECT MATTER
EXPERTS
PROJECT
MANAGERSCREDIT
PROFESSIONALS
Stipulation Support Services
Risk Assessment
NEWOAK’S SUITE OF SERVICES
Rebuttal Re-Underwriting Review
Reverse Mortgage Review
Re-Underwriting Review
Insurance Rescission Review
FHA Review
Repurchase Review
Operational Review
Expert Services
Reps & Warrants Review
THE NEWOAK
TEAM ADVANTAGE
Developing Customized
Litigation Strategies
7
11. RMBS Litigation & Enforcement Action
CASE STUDIES
Enforcement Support Services
Affirmative Review ServicesRe-underwriting Rebuttal
Stipulations Services
Situation
A seller of RMBS, the defendant, was being sued by an investor, the
plaintiff, for alleged fraud in the sale of RMBS. The defendant’s outside
counsel sought expert re-underwriting services in response to the plaintiff’s
claims that the mortgages did not comply with the guidelines at origination.
Services Offered & the Deliverable
NewOak conducted a re-underwriting review and responded to the loan-
level allegations brought by the investor. Throughout the litigation process
NewOak provided expert support, including; allegation and loan-level
analysis, report writing, and expert deposition preparation. NewOak
delivered loan-level reports that included: the plaintiff’s allegations; a
rebuttal re-underwriting response to each allegation with citations for relied
upon documents and guidelines; an independent assessment; and an
allegation and overall loan grade. The report was configured to the client
and experts specific needs. Additionally, in support of the expert throughout
the litigation process, NewOak provided expert report drafting and
identified exemplar loan examples that reinforced our re-underwriting
methodology and highlighted discrepancies with the plaintiff’s
methodology.
Situation
A seller of Residential Mortgage Backed Securities (RMBS), the defendant,
was being sued by an investor, the plaintiff, for the alleged fraud in the sale
of RMBS. The defendant’s outside counsel sought guideline and loan file
matching services and process management during the stipulation phase
of discovery.
Services Offered & the Deliverable
In support of defendant’s counsel, NewOak conducted the stipulation
phase with opposing counsel. Specifically, NewOak reviewed the
guidelines to identify all unique guideline documents and extract key
information necessary to execute guideline matches; determined originator
specific guideline matching methodologies; and reviewed and responded to
plaintiff’s proposed loan file and guideline bates ranges on a loan-by-loan
basis. As a result, defendant’s counsel was presented with loan matches to
the best available guidelines with the determined originator specific
matching methodologies. Additionally, provided was a list of all loan file and
underwriting guideline documents that comprised the relevant universe and
that were later utilized during the re-underwriting rebuttal for each subject
loan.
Situation
The client, a top tier bank, was being investigated by the DOJ for its FHA
lending practices. The DOJ had informed the client that it planed to bring
loan-level allegations that the client breached FHA underwriting standards.
The client sought to take preemptive steps to better understand its risks.
Services Offered & the Deliverable
Through outside counsel, NewOak was retained to conduct a loan-level
affirmative review of the sample to assess whether the loans complied with
the guidelines in effect at origination. Additionally, potential DOJ findings
were identified. NewOak delivered loan-level reports that included an
assessment of: critically missing documentation; appraisal; employment;
DTI ratio; assets; housing history; and LTV. The report was configured to
the client and counsel’s specific needs.
Situation
A seller of RMBS, the defendant, was being sued by an investor, the
plaintiff, for alleged fraud in the sale of RMBS. The defendant’s counsel
determined that the court mandated deadline did not reasonably allow for a
re-underwrite of all loans in the sample. They sought expert re-underwriting
services in response to the plaintiff’s claims that included a way to gain
necessary efficiencies to meet the mandated deadline.
Services Offered & the Deliverable
NewOak conducted a loan-level re-underwriting review prior to the receipt
of plaintiff’s allegations. NewOak delivered loan-level reports that included
an analysis of the most common components of mortgage underwriting that
an underwriter would evaluate in order to approve a loan with citations for
relied upon documents and guidelines; an independent assessment; and a
section level and overall loan grade. The report was configured to the client
and experts specific needs. The results of the affirmative review were
made available to the underwriter performing the re-underwriting rebuttal
via NewOak’s platform, resulting in significant efficiencies, allowing
NewOak and named expert to respond to all loans in the sample and
meeting the mandated deadline.
8
12. Residential Mortgage Services
Client Relations Team
212-209-0707
CreditServicesInfo@NewOak.com
New York Headquarters
212-209-0850
685 Third Avenue, 21st Floor
New York, NY 10017
www.newoak.com
DISCLAIMER This document has been prepared solely for informational purposes and does not constitute an offer to sell or solicitation of an offer to purchase any security. All
information contained herein is subject to change without notice, revision or update. NewOak Credit Services LLC (“NewOak”) makes no representation or warranty, express or implied, as
to the accuracy or completeness of the information contained herein and nothing contained herein may be relied upon as a representation or promise; any such reliance shall be
unreasonable. This document is intended solely for the person to whom it has been delivered and may not be reproduced or forwarded to any other person without the express written
consent of NewOak. This document is also subject to the disclaimers set forth at http://newoak.com/disclaimers.
NEWOAK CREDIT SERVICES is an independent consultancy specializing in credit and regulatory compliance services for the residential mortgage, consumer
finance, and specialty finance industries.
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