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Making Home Affordable Program Performance Report Through October 2011 Report Highlights More Than 880,000 Homeowners Granted Permanent Modifications • Program to date, homeowners in permanent modifications have saved an estimated $9.4 billion in monthly mortgage payments. Homeowners in active first lien permanent modifications save a median of $527 per month – more than onethird of the median before-modification payment. • This month, additional detail on the Principal Reduction Alternative (PRA) is available, including activity by servicer. Homeowners in modifications with the PRA feature have experienced a median principal reduction of nearly one-third of the before-modification principal balance. • Program data indicate that participants in PRA are further underwater and more seriously delinquent at trial start than the overall population of HAMP participants. 89% of homeowners in the PRA program are at least 60 days delinquent at trial start (compared to 79% of the overall portfolio) with a beforemodification loan-to-value ratio of 158% (compared to 120% for the overall HAMP portfolio). This Month: Q3 2011 Servicer Assessment Results • For the third quarter of 2011, one servicer was determined to need substantial improvement in their compliance with MHA guidelines. This servicer was also in need of substantial improvement for the first and second quarter of 2011, and their servicer incentives will continue to be withheld. • Two servicers met the established benchmarks for program compliance, indicating that they require just minor improvement on the areas reviewed for the third quarter. Seven servicers were found to need moderate improvement, with the continued withholding of servicer incentives for one of them. Inside: SUMMARY RESULTS: First Lien Modification Activity First Lien Modification Characteristics/ Modifications By Investor Type Principal Reduction Alternative Activity for 2MP, Treasury FHA-HAMP, HAFA and UP HAMP Activity by State HAMP Activity by MSA/ Homeowner Outreach Aged Trials 2 3 4 5 6 7 8 SERVICER RESULTS: First Lien Modification Activity by Servicer First Lien, PRA, 2MP, and HAFA Activity by Servicer Trial Length Conversion Rate Homeowner Experience Disposition of Homeowners Not in HAMP 9 10 11 12 13 14-15 SERVICER ASSESSMENT RESULTS: Overview Servicer Results Description of Metrics APPENDICES: Participants in MHA Programs 16-18 19-38 39 40-41 Making Home Affordable: Summary Results Program Performance Report Through October 2011 HAMP Activity: First Lien Modifications HAMP Trials Started (As of Sep. 30, 2011) Eligible Delinquent Loans1 Eligible Delinquent Borrowers2 Trial Plan Offers Extended (Cumulative)3 All Trials Started Trial Modifications Permanent Modifications 965,579 1,948,316 1,735,457 1,650 1,638 1,500 21,445 Trial Modifications Canceled (Cumulative) 767,321 1,450 Active Trials 85,060 1,400 All Permanent Modifications Started 883,076 1,350 26,102 Permanent Modifications Canceled (Cumulative)5 147,612 Active Permanent Modifications 735,464 1,735 1,580 50 1,511 0 Jan 2011 Permanent Modifications Reported Since September 2011 Report 1,684 1,722 1,545 1,550 Trials Reported Since September 2011 Report4 1,663 1,704 1,612 1,600 Feb Mar Apr May June July Aug Sep Oct Source: HAMP system of record. Servicers may enter new trial modifications into the HAMP system of record at any time. For example, 21,445 trials have entered the HAMP system of record since the prior report; 13,067 were trials with a first payment recorded in October 2011. Permanent Modifications Started (Cumulative) 1,000 eligible 60+ day delinquent loans as reported by servicers as of September 30, 2011, include conventional loans: in foreclosure and bankruptcy. with a current unpaid principal balance less than $729,750 on a one-unit property, $934,200 on a two-unit property, $1,129,250 on a three-unit property and $1,403,400 on a four-unit property. on a property that was owner-occupied at origination. originated on or before January 1, 2009. Estimated eligible 60+ day delinquent loans exclude: FHA and VA loans. loans that are current or less than 60 days delinquent, which may be eligible for HAMP if a borrower is in imminent default. 2 The estimated eligible 60+ day delinquent borrowers are those in HAMP-eligible loans, minus estimated exclusions of loans on vacant properties, loans with borrower debt-to-income ratio below 31%, loans that fail the NPV test, properties no longer owner-occupied, unemployed borrowers, manufactured housing loans with title/chattel issues that exclude them from HAMP, loans where the investor pooling and servicing agreements preclude modification, and trial and permanent modifications disqualified from HAMP. Exclusions for DTI and NPV results are estimated using market analytics. 3 As reported in the monthly servicer survey of large SPA servicers through October 31, 2011. 4 Servicers may enter new trial modifications into the HAMP system of record at anytime. 5 A permanent modification is canceled when the borrower has missed three consecutive monthly payments. Includes 2,399 loans paid off. All Permanent Modifications Started (000s) 1 Estimated 1,700 2,507,171 All Trials Started (000s) HAMP Eligibility Monthly Trial Starts (Right Axis) 1,750 Total 100 Cumulative Trial Starts (Left Axis) New Trials Started (000s) 1,800 HAMP is designed to lower monthly mortgage payments to help struggling homeowners stay in their homes and prevent avoidable foreclosure. 900 857 800 763 700 600 608 634 699 817 731 500 400 Jan 2011 Feb Source: HAMP system of record. Note: Unless specified, exhibits in this report refer to HAMP first lien modification activity. 670 791 883 Mar Apr May June July Aug Sep Oct 2 Making Home Affordable: Summary Results Program Performance Report Through October 2011 Homeowner Benefits and First Lien Modification Characteristics • Aggregate savings to homeowners who received HAMP first lien permanent modifications are estimated to total nearly $9.4 billion, program to date, compared with unmodified mortgage obligations. • The primary hardship reasons for homeowners in active permanent modifications are: • 62.2% experienced loss of income (curtailment of income or unemployment) • 11.0% reported excessive obligation • 3.0% reported an illness of the principal borrower • The median monthly savings for borrowers in active permanent first lien modifications is $527.05, or 37% of the median monthly payment before modification. • Of trial modifications started, 79% of homeowners were at least 60 days delinquent at trial start. The rest were up to 59 days delinquent or current and in imminent default. • Active permanent modifications feature the following modification steps: • 98.3% feature interest rate reductions • 58.8% offer term extension • 30.9% include principal forbearance Modifications by Investor Type (Large Servicers) Servicer American Home Mortgage Servicing Inc. GSE Private Total Active Modifications Portfolio 1,307 25,743 - 27,050 Bank of America, NA1 96,741 60,370 10,152 167,263 CitiMortgage, Inc. 31,701 5,653 17,289 54,643 GMAC Mortgage, LLC 24,816 5,800 11,568 42,184 JPMorgan Chase NA2 58,731 51,145 23,922 133,798 81 11,924 8 12,013 6,990 23,635 112 30,737 14,673 14,755 2,513 31,941 523 16,282 2,536 19,341 Wells Fargo Bank, NA 3 51,277 15,876 44,815 111,968 Other HAMP Servicers 139,484 33,650 16,452 189,586 Total 426,324 264,833 129,367 820,524 Litton Loan Servicing LP Ocwen Loan Servicing, LLC OneWest Bank Select Portfolio Servicing Select Median Characteristics of Active Permanent Modifications Loan Characteristic Before After Modification Modification Median Decrease Front-End Debt-to-Income Ratio1 45.2% 31.0% -14.3 pct pts Back-End Debt-to-Income Ratio2 78.2% 61.3% -14.7 pct pts Median Monthly Housing Payment3 $1,427.88 $830.54 -$527.05 1 Ratio of housing expenses (principal, interest, taxes, insurance and homeowners association and/or condo fees) to monthly gross income. Ratio of total monthly debt payments (including mortgage principal and interest, taxes, insurance, homeowners association and/or condo fees, plus payments on installment debts, junior liens, alimony, car lease payments and investment property payments) to monthly gross income. Borrowers who have a back-end debt-to-income ratio of greater than 55% are required to seek housing counseling under program guidelines. 3 Principal and interest payment. 2 1 Bank of America, NA includes all loans previously reported under BAC Home Loans Servicing LP, Home Loan Services and Wilshire Credit Corporation. 2 JPMorgan Chase Bank, NA includes all loans previously reported under EMC Mortgage Corporation. 3 Wells Fargo Bank, NA includes all loans previously reported under Wachovia Mortgage, FSB. Note: Figures reflect active trials and active permanent modifications. 3 Making Home Affordable: Summary Results Program Performance Report Through October 2011 Principal Reduction Alternative (PRA) The Principal Reduction Alternative (PRA) was implemented in October 2010. PRA requires servicers of non-GSE loans to evaluate the benefit of principal reduction for mortgages with a loan-to-value (LTV) ratio of 115% or greater when evaluating a homeowner for a HAMP first lien modification. While servicers are required to evaluate homeowners for PRA, they are not required to offer principal reduction and generally may only do so when permitted by the mortgage investor. PRA pays investors incentives for every dollar of principal forgiven, according to a sliding scale and depending on the degree to which the homeowner's unmodified balance is greater than the market value of the home. PRA can be a feature of a HAMP trial or permanent modification. PRA Activity Modification Characteristics While both GSE and non-GSE loans are eligible for HAMP, at the present time due to GSE policy, servicers can only offer PRA on non-GSE modifications under HAMP. Servicer volume can vary based on the investor composition of the servicer’s portfolio and respective policy with regards to PRA. To date, the 10 largest MHA servicers account for 97% of all trial modifications started with PRA, and the top three MHA servicers account for 68% of all PRA volume (and over 50% of overall HAMP volume). (See page 10 for additional servicer detail.) All PRA Trial Modifications Started PRA Trial Modifications Active 53,323 While the population of loan modifications with the PRA feature is still relatively small, the program data indicate that there are more homeowners seriously delinquent at the time of trial start than the overall population of HAMP borrowers. Overall, homeowners receiving permanent loan modifications with the PRA feature also have a higher before-modification LTV ratio than those without the PRA feature. Loan Characteristics All 1MP2 1MP with PRA Of trials started, delinquency at trial start: - At least 60 days delinquent 79% 89% - Up to 59 days delinquent or current and in imminent default 21% 11% 25% 12% 5% 42% 30% 17% 6% 53% 17,046 Top three States by Activity3, Percent of Total Activity: All PRA Permanent Modifications Started 33,376 PRA Permanent Modifications Active 32,171 Median Principal Amount Reduced for Active Permanent Modifications $65,172 Median Principal Amount Reduced for Active Permanent Modifications (%)1 31.3% - California - Florida - Illinois Top three States’ Percent of Total Active Permanent Modifications – Median Loan-to-Value (LTV) ratio: PRA amount as a percentage of before-modification UPB, excluding capitalization. Includes HAMP first lien modifications with and without the PRA feature. 3 Figures reflect active trials and active permanent modifications. 4 Because the first step of the standard HAMP waterfall includes the capitalization of accrued interest, outof-pocket escrow advances to third parties, any escrow advances made to third parties during the trial period plan, and servicing advances that are made for costs and expenses incurred in performing servicing obligations, this can result in an increase in the principal balance after modification. As a result, the loanto-value ratio can increase in the modification process. - Before Modification 120% 158% - After Modification4 123% 115% 1 2 Active Permanent Modifications – Median before Modification Debt-to-Income (DTI) ratio: - Front-End DTI 45.2% 44.8% - Back-End DTI 78.2% 71.9% 4 Making Home Affordable: Summary Results Program Performance Report Through October 2011 Second Lien Modification Program (2MP) Activity The Second Lien Modification Program (2MP) provides assistance to homeowners in a first lien permanent modification who have an eligible second lien with a participating HAMP servicer. This assistance can result in a modification of the second lien and even full or partial extinguishment of the second lien. 2MP requires that the first lien HAMP modification be permanent and active and that the second lien have an unpaid balance of more than $5,000 and a monthly payment of $100 or greater. All Second Lien Modifications Started (Cumulative)1 50,434 Second Lien Modifications Involving Full Lien Extinguishments 8,634 Second Lien Modifications Disqualified2 Active Second Lien Modifications 922 40,878 Home Affordable Foreclosure Alternatives (HAFA) Activity The Home Affordable Foreclosure Alternatives Program (HAFA) offers incentives for homeowners looking to exit their homes through a short sale or deed-in-lieu of foreclosure. HAFA has established important homeowner protections and an industry standard for streamlined transactions. In 22% of HAFA agreements started, the homeowner began a HAMP trial modification but later requested a HAFA agreement or was disqualified from HAMP. All HAFA Agreements Started1 34,605 HAFA Agreements Active 8,818 HAFA Transactions Completed 20,701 Completed Transactions – Short Sale Completed Transactions – Deed-in-Lieu 20,110 591 1 Servicer Of the Active Second Lien Modifications: Second Lien Partially Extinguished 1,569 Second Lien Loan Modifications3 39,309 agreement with homeowner for terms of potential short sale, which lasts at least 120 days; or agreement for a deed-in-lieu transaction. A short sale requires a third-party purchaser and cooperation of junior lienholders and mortgage insurers to complete the transaction. All HAFA Agreements Started include HAFA Agreements Active, HAFA Transactions Completed, and HAFA Transactions Canceled. Unemployment Program (UP) Activity Second Lien Extinguishment Details Average Amount of Full Extinguishment $70,356 Average Amount of Partial Extinguishment $7,037 1 Includes second lien modifications reported into HAMP system of record through the end of cycle for October 2011 data, though the effective date may occur in November. Number of modifications is net of cancellations, which are primarily due to servicer data corrections. 2 Includes 70 loans paid off. 3 Second lien modifications follow a series of steps and may include capitalization, interest rate reduction, term extension and principal forbearance or forgiveness. Treasury FHA-HAMP Modification Activity The Treasury FHA-HAMP Program provides assistance to eligible homeowners with FHA-insured mortgages. All Treasury FHA-HAMP Trial Modifications Started 6,952 Treasury FHA-HAMP Permanent Modifications Started 4,900 The Treasury MHA Unemployment Program (UP) provides a temporary forbearance to homeowners who are unemployed. Under Treasury guidelines, unemployed homeowners must be considered for a minimum of 12 months’ forbearance. All UP Forbearance Plans Started (through Sep. 2011) 16,151 UP Forbearance Plans With Some Payment Required 13,313 UP Forbearance Plans With No Payment Required 2,838 Note: Data is as reported by servicers via survey for UP participation through Sep. 30, 2011. See Appendix A2 for servicer participants in additional Making Home Affordable programs. 5 Making Home Affordable: Summary Results Program Performance Report Through October 2011 HAMP Activity by State State % of U.S. Active Permanent State HAMP Trials Modifications Total1 Activity State Modification Activity by State % of U.S. Active Permanent State HAMP Trials Modifications Total1 Activity AK 48 316 364 0.0% MT 90 849 939 0.1% AL 502 4,111 4,613 0.6% NC 1,403 13,220 14,623 1.8% AR 197 1,599 1,796 0.2% ND 16 120 136 0.0% AZ 2,618 32,361 34,979 4.3% NE 105 997 1,102 0.1% CA 20,457 182,514 202,971 24.7% NH 390 3,320 3,710 0.5% CO 1,065 10,104 11,169 1.4% NJ 2,963 23,525 26,488 3.2% CT 1,056 9,118 10,174 1.2% NM 304 2,371 2,675 0.3% DC 165 1,227 1,392 0.2% NV 1,761 18,433 20,194 2.5% DE 272 2,229 2,501 0.3% NY 5,095 34,119 39,214 4.8% FL 11,311 88,022 99,333 12.1% OH 1,872 15,980 17,852 2.2% GA 3,157 26,538 29,695 3.6% OK 237 1,666 1,903 HI 270 2,800 3,070 0.4% OR 860 8,028 8,888 1.1% IA 217 1,824 2,041 0.2% PA 1,754 15,005 16,759 2.0% ID 304 2,840 3,144 0.4% RI 396 3,809 4,205 0.5% IL 4,480 39,180 43,660 5.3% SC 821 6,843 7,664 0.9% IN 833 6,999 7,832 1.0% SD 28 269 297 0.0% KS 231 1,717 1,948 0.2% TN 946 7,498 8,444 1.0% KY 311 2,759 3,070 0.4% TX 2,631 19,065 21,696 2.6% LA 606 4,027 4,633 0.6% UT 620 6,943 7,563 0.9% 0.2% MA 1,966 17,963 19,929 2.4% VA 1,770 17,610 19,380 2.4% MD 2,545 23,451 25,996 3.2% VT 88 615 703 0.1% ME 273 2,026 2,299 0.3% WA 1,952 14,747 16,699 2.0% MI 2,365 23,618 25,983 3.2% WI 848 7,005 7,853 1.0% MN 1,068 12,408 13,476 1.6% WV 105 1,044 1,149 0.1% MO 840 7,501 8,341 1.0% WY 32 374 406 0.0% MS 324 2,699 3,023 0.4% Other2 492 2,058 2,550 0.3% 1 Total reflects active trials and active permanent modifications. 2 Includes Guam, Puerto Rico and the U.S. Virgin Islands. HAMP Modifications Note: Includes active trial and permanent modifications from the official HAMP system of record. 5,000 and lower 20,001 – 35,000 5,001 – 10,000 35,001 and higher 10,001 – 20,000 Mortgage Delinquency Rates by State Source: 3rd Quarter 2011 National Delinquency Survey, Mortgage Bankers Association. 60+ Day Delinquency Rate 5.0% and lower 5.01% - 10.0% 10.01% - 15.0% 15.01% - 20.0% 20.01% and higher 6 Making Home Affordable: Summary Results Program Performance Report Through October 2011 Homeowner’s HOPETM Hotline Volume 15 Metropolitan Areas With Highest HAMP Activity Metropolitan Statistical Area Los Angeles-Long Beach-Santa Ana, CA New York-Northern New JerseyLong Island, NY-NJ-PA Chicago-Joliet-Naperville, IL-IN-WI Riverside-San Bernardino-Ontario, CA Miami-Fort Lauderdale-Pompano Beach, FL Total MSA % of U.S. HAMP HAMP Activity Activity Active Trials Permanent Modifications 6,949 54,693 61,642 7.5% 6,424 45,989 52,413 6.4% 4,336 37,967 42,303 5.2% 3,461 38,594 42,055 5.1% Program to Date October Total Number of Calls Taken at 1-888-995-HOPE 2,605,355 67,411 Borrowers Receiving Free Housing Counseling Assistance Through the Homeowner’s HOPETM Hotline 1,237,497 31,662 Source: Homeowner’s HOPETM Hotline. Numbers reflect calls that resulted in customer records. 5,272 36,360 41,632 5.1% Phoenix-Mesa-Glendale, AZ 1,965 26,294 28,259 3.4% Washington-Arlington-Alexandria, DC-VA-MD-WV 2,476 24,992 27,468 3.3% Atlanta-Sandy Springs-Marietta, GA 2,513 21,446 23,959 2.9% San Francisco-Oakland-Fremont, CA 2,064 14,976 17,040 2.1% Las Vegas-Paradise, NV 1,467 15,142 16,609 2.0% Detroit-Warren-Livonia, MI 1,435 14,323 15,758 1.9% Orlando-Kissimmee-Sanford, FL MSA 1,479 13,615 15,094 1.8% San Diego-Carlsbad-San Marcos, CA 1,490 13,147 14,637 1.8% Boston-Cambridge-Quincy, MA-NH 1,426 12,903 14,329 1.7% Sacramento-Arden-Arcade-Roseville, CA 1,323 12,633 13,956 1.7% Selected Homeowner Outreach Measures Homeowner Outreach Events Hosted Nationally by Treasury and Partners (cumulative) Homeowners Attending Treasury-Sponsored Events (cumulative) 60 59,519 Servicer Solicitation of Borrowers (cumulative)1 8,039,131 Page views on MakingHomeAffordable.gov (October 2011) 2,407,850 Page views on MakingHomeAffordable.gov (cumulative) 129,244,991 1 Source: Survey data provided by SPA servicers. Servicers are encouraged by HAMP to solicit information from borrowers 60+ days delinquent, regardless of eligibility for a HAMP modification. Note: Total reflects active trials and active permanent modifications. A complete list of HAMP activity for all metropolitan areas is available at http://www.treasury.gov/initiatives/financial-stability/results/MHA-Reports/ 7 Making Home Affordable: Summary Results Program Performance Report Through October 2011 Aged Trials1 200,000 190,412 The number of active trials lasting 6 months or longer is below 18,400. 165,543 Program guidance directs servicers to cancel or convert trial modifications after three or four monthly payments, depending on circumstances. 150,000 117,574 94,269 100,000 76,502 69,418 49,229 50,000 39,753 36,184 32,017 26,362 25,390 23,552 23,014 23,061 27,345 19,793 18,359 0 May 2010 June July Aug Sept Oct Nov Dec Jan 2011 Feb March April May June July Aug Sep Oct Trials Lasting 6 Months or Longer At End of Month 1 Active trials initiated at least six months ago. See page 9 for number of aged trials by servicer. These figures include trial modifications that have been converted to permanent modifications or cancelled by the servicer and are pending reporting to the HAMP system of record. 8 Making Home Affordable: Servicer Results Program Performance Report Through October 2011 HAMP Modification Activity by Servicer As of Sep. 30, 2011 Cumulative As of Oct. 31, 2011 All HAMP Trials Started3 All HAMP Permanent Modifications Started3 Trial Modifications Reported Since September 2011 Report3 Active Trial Modifications3 Active Trial Modifications Lasting 6 Months or Longer4 Active Permanent Modifications3 41,067 37,058 29,101 1,021 3,227 237 23,823 221,612 508,498 416,925 181,284 3,475 15,043 5,569 152,220 CitiMortgage, Inc. 71,333 189,961 134,759 58,369 320 4,582 1,689 50,061 GMAC Mortgage, LLC 25,789 79,530 65,324 48,371 783 2,445 67 39,739 JPMorgan Chase Bank, NA6 158,829 337,767 288,816 134,269 7,559 24,362 4,931 109,436 Litton Loan Servicing LP7 32,742 43,955 38,309 13,503 14 1,686 477 10,327 Ocwen Loan Servicing, LLC 34,536 50,860 48,535 37,880 470 2,710 403 28,027 OneWest Bank 33,707 73,765 56,871 32,361 679 3,883 201 28,058 Select Portfolio Servicing 3,893 68,726 42,526 23,552 135 530 17 18,811 Estimated Eligible 60+ Day Delinquent Borrowers1 Trial Plan Offers Extended2 American Home Mortgage Servicing Inc. 38,485 Bank of America, NA5 Servicer Wells Fargo Bank, NA8 123,003 333,917 246,738 118,689 2,303 10,364 1,364 101,604 Other SPA Servicers9 93,509 220,270 220,304 115,966 2,501 7,290 1,244 96,795 Other GSE Servicers10 128,141 NA 139,292 89,731 2,185 8,938 2,160 76,563 Total 965,579 1,948,316 1,735,457 883,076 21,445 85,060 18,359 735,464 1 Estimated eligible 60+ day delinquent borrowers as reported by servicers as of Sep. 30, 2011, include those in conventional loans: in foreclosure and bankruptcy. with a current unpaid principal balance less than $729,750 on a one-unit property, $934,200 on a two-unit property, $1,129,250 on a three-unit property and $1,403,400 on a four-unit property. on a property that was owner-occupied at origination. originated on or before January 1, 2009. Estimated eligible 60+ day delinquent borrowers exclude: Those in FHA and VA loans. Those in loans that are current or less than 60 days delinquent, which may be eligible for HAMP if a borrower is in imminent default. Those borrowers with debt-to-income ratios less than 31% or a negative NPV test. Owners of vacant properties or properties otherwise excluded. HAMP Trials and Permanent Modifications disqualified from HAMP. Unemployed borrowers. Exclusions for DTI and NPV are estimated using market analytics. 2 As reported in the monthly servicer survey of large SPA servicers through Oct. 31, 2011. 3 As reported into the HAMP system of record by servicers. Excludes FHAHAMP modifications. Subject to adjustment based on servicer reconciliation of historic loan files. Totals reflect impact of servicing transfers. In cases where servicing transfers exceed new trial modifications reported, negative numbers are not presented. Servicers may enter new trial modifications into the HAMP system of record at any time. 4 These figures include trial modifications that have been converted to permanent modifications or cancelled by the servicer and are pending reporting to the HAMP system of record. 5 Bank of America, NA includes all loans previously reported under BAC Home Loans Servicing LP, Home Loan Services and Wilshire Credit Corporation. 6 JPMorgan Chase Bank, NA includes all loans previously reported under EMC Mortgage Corporation. Due to the acquisition of Litton Loan Servicing LP (Litton) by Ocwen Loan Servicing, LLC (Ocwen), Litton’s portfolio is being transferred to Ocwen. As a result, Litton’s August survey results for the estimated eligible 60+ Day Delinquent Borrowers are used in this month’s report. In the future, Ocwen Loan Servicing, LLC and Litton Loan Servicing LP will be reported on a consolidated basis. 8 Wells Fargo Bank, NA includes all loans previously reported under Wachovia Mortgage, FSB. 9 Other SPA servicers are entities excluding the 10 largest servicers, by cap amount, that have signed participation agreements with Treasury and Fannie Mae. A full list of participating servicers is in Appendix A1. 10 Includes servicers of loans owned or guaranteed by Fannie Mae and Freddie Mac. Includes GSE loans previously transferred from SPA servicers. 7 9 Making Home Affordable: Servicer Results Program Performance Report Through October 2011 Making Home Affordable Programs by Servicer1 HAMP First Lien Modifications HAMP First Lien Modifications With Principal Reduction Alternative (PRA)2 Second Lien Modification (2MP) Home Affordable Foreclosure Alternatives (HAFA) Trials Started3 Permanent Modifications Started3 Trials Started3 Permanent Modifications Started3 Modifications Started4 Agreements Started5 Agreements Completed American Home Mortgage Servicing Inc. 37,058 29,101 0 0 N/A 415 165 Bank of America, NA6 416,925 181,284 13,203 9,922 19,177 4,938 3,808 CitiMortgage, Inc. 134,759 58,369 1,949 1,370 7,161 26 19 GMAC Mortgage, LLC 65,324 48,371 835 429 2,751 1,260 754 JPMorgan Chase Bank, NA7 288,816 134,269 10,401 3,862 9,350 12,575 7,230 Litton Loan Servicing LP 38,309 13,503 3,297 2,222 N/A 1,312 713 Ocwen Loan Servicing, LLC 48,535 37,880 6,845 4,400 N/A 258 92 OneWest Bank 56,871 32,361 2,694 1,515 1,091 1,026 463 Select Portfolio Servicing 42,526 23,552 1 1 N/A 1,821 959 Wells Fargo Bank, NA8 246,738 118,689 12,658 8,459 9,222 9,039 5,238 Other Servicers 359,596 205,697 1,440 1,196 1,682 1,935 1,260 1,735,457 883,076 53,323 33,376 50,434 34,605 20,701 Servicer Total 1 MHA Program Effective Dates: HAMP First Lien: April 6, 2009 PRA: October 1, 2010 2MP: August 13, 2009 HAFA: April 5, 2010 2While both GSE and non-GSE loans are eligible for HAMP, at the present time due to GSE policy, servicers can only offer PRA on non-GSE modifications under HAMP. Servicer volume can vary based on the investor composition of the servicer’s portfolio and respective policy with regards to PRA. See page 3 for additional servicer detail on HAMP activity by investor type. 3 As reported into the HAMP system of record by servicers. Excludes FHA-HAMP modifications. Subject to adjustment based on servicer reconciliation of historic loan files. Totals reflect impact of servicing transfers. Servicers may enter new trial modifications into the HAMP system of record at any time. See Appendix A1 and A2 for servicer participants in Making Home Affordable programs. 4 Number of second lien modifications started is net of cancellations, which are primarily due to servicer data corrections. 5 Servicer agreement with homeowner for terms of potential short sale, which lasts at least 120 days; or agreement for a deed-in-lieu transaction. A short sale requires a thirdparty purchaser and cooperation of junior lienholders and mortgage insurers to complete the transaction. 6 Bank of America, NA includes all loans previously reported under BAC Home Loans Servicing LP, Home Loan Services and Wilshire Credit Corporation. 7 JPMorgan Chase Bank, NA includes all loans previously reported under EMC Mortgage Corporation. 8 Wells Fargo Bank, NA includes all loans previously reported under Wachovia Mortgage, FSB. N/A – Servicer does not participate in the program. 10 Making Home Affordable: Servicer Results Program Performance Report Through October 2011 Length of Trial Upon Conversion1 9 The average length of the trial period for those converted to a permanent HAMP modification has decreased from 5.3 months for trials started prior to June 1, 2010, to 3.5 months for trials started June 1, 2010 or later. 8 7 Months 6 5 4.6 4 3.5 3.4 3 3.6 3.3 3.0 3.0 3.2 3.5 3.3 3.3 3.0 2 1 0 Am. Home Servicing Bank of America CitiMortgage Trials Started Before 6/1/10 GMAC JP Morgan Chase Litton Trials Started On/After 6/1/10 Ocwen OneWest SPS Before 6/1/10 Average (5.3) Wells Fargo Other GSE servicers Other SPA Servicers On/After 6/1/10 Average (3.5) 1 For all permanent modifications started. Note: Per program guidelines, effective June 1, 2010 all trials must be started using verified income. Prior to June 1, 2010, some servicers initiated trials using stated income information. 11 Making Home Affordable: Servicer Results Program Performance Report Through October 2011 Conversion Rate1 Following the implementation of verified income documentation in June 2010, rates of converting trial modifications into permanent modifications have risen substantially. Of Trials Started Before 6/1/10: 42% Converted to Permanent Modification 0.3% Pending Processing or Decision 100% 88% Of Eligible Trials Started On/After 6/1/10: 82% Converted to Permanent Modification 8.5% Pending Processing or Decision 82% Conversion Rate 84% 79% 80% 90% 88% 81% 84% Other GSE Servicers Other SPA Servicers 79% 76% 77% 83% 60% 40% 20% 0% Am. Home Servicing Bank of America CitiMortgage GMAC JPMorgan Chase Litton Average of Trials Started Before 6/1/10 (42%) Ocwen OneWest SPS Wells Fargo Average of Trials Started On/After 6/1/10 (82%) 1 Per program guidelines, effective June 1, 2010 all trials must be started using verified income. Before June 1, 2010, some servicers initiated trials using stated income information. Chart depicts conversion rates as measured against trials eligible to convert – those three months in trial, or four months if the borrower was at risk of imminent default at trial modification start. Permanent modifications transferred among servicers are credited to the originating servicer. Trial modifications transferred are reflected in the current servicer’s population. 12 Making Home Affordable: Servicer Results Program Performance Report Through October 2011 Homeowner Experience (10 Largest Servicers) Average Speed to Answer Homeowner Calls (September) Servicer Complaint Rate to Homeowner’s HOPETM Hotline (Program to Date, Through October) 60 Program to date, there have been 1,282,914 calls to the Homeowner’s HOPETM Hotline regarding a specific SPA servicer, of which 6.7% included complaints. Below shows specific complaint rates. Average Speed to Answer Calls to Homeowner’s HOPETM Hotline for September: 4 Seconds 50 40 11% % of Calls for Specific Servicer 30 Seconds Program to Date Average: 6.7% 10% 20 9% 8% 7% 6% 5% 10 4% 3% 0 Am. Home Servicing Bank of America CitiMortgage GMAC JPMorgan Chase Litton Ocwen OneWest SPS Wells Fargo Bank of America CitiMortgage GMAC JPMorgan Chase Litton Ocwen OneWest SPS Wells Fargo 29,864 6,810 3,377 17,260 1,709 2,530 274 667 11,032 Source: Homeowner’s HOPETM Hotline. Numbers reflect calls that resulted in customer records. Note: Complaint rate is the share of a specific servicer’s call volume that are complaints (e.g., for all calls about OneWest, 9.8% included complaints.) Source: Survey data through September 30, 2011, from servicers on call volume to loss mitigation lines; Homeowner’s HOPETM Hotline. Servicer Time to Resolve Third-Party Escalations (Cases Reported Feb. 1, 2011 – Oct. 31, 2011) Call Abandon Rate (September) 12% Homeowner’s HOPETM Hotline Average Call Abandon Rate for September: 1.1% 10% Am. Home Servicing Complaints (PTD): 2,489 60 Target: 30 Calendar Days 50 Calendar Days 8% 6% 4% 40 30 20 10 2% 0 0% Am. Home Servicing Bank of America CitiMortgage GMAC JPMorgan Chase Litton Ocwen OneWest SPS Source: Survey data through September 30, 2011, from servicers on call volume to loss mitigation lines; Homeowner’s HOPETM Hotline. Wells Fargo Am. Home Servicing Resolved Cases 614 Post-2/1/11 Bank of America 8,844 CitiMortgage 1,001 GMAC JPMorgan Chase 571 3,675 Litton 292 Ocwen 716 OneWest SPS Wells Fargo 793 149 2,319 Source: MHA Support Centers. GSE and Non-GSE escalations resolved on or after Feb. 1, 2011. Investor denial cases, cases involving bankruptcy and those that did not require servicer actions are not included in calculation of servicer time to resolve escalations. Target of 30 calendar days, effective Feb. 1, 2011, includes an estimated 5 days of processing by MHA Support Centers. 13 Making Home Affordable: Servicer Results Program Performance Report Through October 2011 Disposition Path Homeowners in Canceled HAMP Trial Modifications Survey Data Through September 2011 (10 Largest Servicers) Homeowners Whose HAMP Trial Modification Was Canceled Who Are in the Process of: Action Pending1 Servicer American Home Mortgage Servicing Inc. Action Not Allowed – Bankruptcy Borrower in Process Current Total (As of Short Sale/ Alternative Payment Deed-in- Foreclosure Foreclosure September 2011) Modification Plan2 Loan Payoff Lieu Starts Completions 202 73 182 2,572 49 274 311 666 125 4,454 25,785 8,533 29,809 76,324 2,532 4,325 17,682 32,868 18,101 215,959 CitiMortgage Inc. 16,774 3,639 5,532 28,823 988 1,448 1,730 9,425 2,047 70,406 GMAC Mortgage, LLC 1,763 387 1,024 5,663 164 493 1,078 1,748 1,766 14,086 JPMorgan Chase Bank NA4 6,654 763 4,405 53,794 560 7,082 7,684 23,266 12,970 117,178 Litton Loan Servicing LP5 554 218 606 12,157 64 194 1,189 628 1,013 16,623 Ocwen Loan Servicing, LLC 634 132 458 2,998 465 38 367 2,053 641 7,786 OneWest Bank 435 601 727 10,302 153 56 1,150 3,211 3,937 20,572 Select Portfolio Servicing 1,187 410 1,323 5,466 315 415 1,321 1,697 3,380 15,514 Wells Fargo Bank NA6 2,134 803 12,128 54,594 1,031 19,474 3,047 16,196 8,843 118,250 TOTAL (These 10 Largest Servicers) 56,122 9.3% 15,559 2.6% 56,194 9.4% 252,693 42.1% 6,321 1.1% 33,799 5.6% 35,559 5.9% 91,758 15.3% 52,823 8.8% 600,828 100.0% Bank of America, NA3 Note: Data is as reported by servicers for actions completed through September 30, 2011. Survey data is not subject to the same data quality checks as data uploaded into the HAMP system of record. 1 Trial loans that have been canceled, but no further action has yet been taken. 2 An arrangement with the borrower and servicer that does not involve a formal loan modification. 3 Bank of America, NA includes all loans previously reported under BAC Home Loans Servicing LP, Home Loan Services and Wilshire Credit Corporation. 4 JPMorgan Chase Bank, NA includes all loans previously reported under EMC Mortgage Corporation. 5 Due to the acquisition of Litton Loan Servicing LP (Litton) by Ocwen Loan Servicing, LLC (Ocwen), Litton’s portfolio is being transferred to Ocwen. As a result, Litton’s August survey results for the estimated eligible 60+ Day Delinquent Borrowers are used in this month’s report. In the future, Ocwen Loan Servicing, LLC and Litton Loan Servicing LP will be reported on a consolidated basis. 6 Wells Fargo Bank, NA includes all loans previously reported under Wachovia Mortgage, FSB. Note: Excludes cancellations pending data corrections and loans otherwise removed from servicing portfolios. The most common causes of trial cancellations from all servicers are: • Insufficient documentation • Trial plan payment default • Ineligible borrower: first lien housing expense is already below 31% of household income 14 Making Home Affordable: Servicer Results Program Performance Report Through October 2011 Disposition Path Homeowners Not Accepted for HAMP Trial Modifications Survey Data Through September 2011 (10 Largest Servicers) Homeowners Not Accepted for a HAMP Trial Modification Who Are in the Process of: Servicer Action Pending1 Action Not Allowed – Bankruptcy Borrower in Process Current Total (As of Short Sale/ Alternative Payment Deed-in- Foreclosure Foreclosure September 2011) Modification Plan2 Loan Payoff Lieu Starts Completions American Home Mortgage Servicing Inc. 1,897 1,310 10,986 37,639 1,250 2,281 2,195 8,147 1,370 67,075 Bank of America, NA3 56,346 17,371 114,006 98,321 10,138 8,912 40,225 90,440 40,506 476,265 CitiMortgage Inc. 22,904 9,504 20,208 24,294 4,430 16,107 1,383 6,954 7,641 113,425 GMAC Mortgage, LLC 24,274 5,746 35,644 36,906 2,319 4,619 8,624 16,577 14,188 148,897 JPMorgan Chase Bank NA4 85,607 6,158 81,194 138,231 2,284 65,906 28,660 73,684 24,593 506,317 Litton Loan Servicing LP5 2,995 1,256 4,057 16,407 282 857 4,537 2,860 4,438 37,689 Ocwen Loan Servicing, LLC 6,396 1,494 30,805 33,004 4,792 135 426 4,537 2,190 83,779 OneWest Bank 5,314 3,039 24,718 19,690 1,471 1,578 4,543 11,856 10,502 82,711 Select Portfolio Servicing 2,599 437 3,011 4,599 378 309 1,191 1,881 1,839 16,244 Wells Fargo Bank NA6 17,314 5,131 51,033 50,726 1,866 26,613 15,704 22,218 15,122 205,727 TOTAL (These 10 Largest Servicers) 225,646 13.0% 51,446 3.0% 375,662 21.6% 459,817 26.5% 29,210 1.7% 127,317 7.3% 107,488 6.2% 239,154 13.8% 122,389 7.0% 1,738,129 100.0% The most common causes of trials not accepted from all servicers are: • Insufficient documentation • Ineligible borrower: first lien housing expense is already below 31% of household income • Ineligible mortgage Note: Data is as reported by servicers for actions completed through September 30, 2011. Survey data is not subject to the same data quality checks as data uploaded into the HAMP system of record. 1 Homeowners who were not approved for a HAMP trial modification, but no further action has yet been taken. 2 An arrangement with the borrower and servicer that does not involve a formal loan modification. 3 Bank of America, NA includes all loans previously reported under BAC Home Loans Servicing LP, Home Loan Services and Wilshire Credit Corporation. 4 JPMorgan Chase Bank, NA includes all loans previously reported under EMC Mortgage Corporation. 5 Due to the acquisition of Litton Loan Servicing LP (Litton) by Ocwen Loan Servicing, LLC (Ocwen), Litton’s portfolio is being transferred to Ocwen. As a result, Litton’s August survey results for the estimated eligible 60+ Day Delinquent Borrowers are used in this month’s report. In the future, Ocwen Loan Servicing, LLC and Litton Loan Servicing LP will be reported on a consolidated basis. 6 Wells Fargo Bank, NA includes all loans previously reported under Wachovia Mortgage, FSB. Note: Excludes loans removed from servicing portfolios. 15 MHA Servicer Assessment Overview Background Since the Making Home Affordable Program’s (MHA) inception in the spring of 2009, Treasury has monitored the performance of participating mortgage servicers. Treasury has been publicly reporting information about servicer performance through two types of data: compliance data, which reflects servicer compliance with specific MHA guidelines; and program results data, which reflects how timely and effectively servicers assist eligible homeowners and report program activity. When MHA began, most servicers did not have the staff, procedures, or systems in place to respond to the volume of homeowners struggling to pay their mortgages, or to respond to the housing crisis generally. Very few mortgage modifications were even occurring. Treasury sought to get servicers to join MHA and to improve their operations quickly, so as to implement a national mortgage modification program. Through ongoing compliance reviews, Treasury has required participating servicers to take specific actions to improve their servicing processes. While the servicers have improved their performance, they still have more progress to make. Toward that end, Treasury is publishing servicer assessments for each of the 10 largest servicers participating in MHA. Not only will the assessments provide more transparency to the public about servicer performance in the program, but the assessments are also intended to encourage servicers to correct identified instances of non-compliance. Servicer participation in MHA is voluntary, based on a contract with Fannie Mae as financial agent on behalf of Treasury. Although Treasury does not regulate these institutions and does not have the authority to impose fines or penalties, Treasury can, pursuant to the contract, take certain remedial actions against servicers not in compliance with MHA guidelines. Such remedial actions include requiring servicers to correct identified instances of non-compliance, as noted above. In addition, Treasury can implement financial remedies such as withholding incentive payments owed to servicers. Such incentive payments, which are the only payments Treasury makes for the benefit of servicers under the program, include payments for every successful permanent modification under the Home Affordable Modification Program, and payments for completed short sale/deed-in-lieu transactions pursuant to the Home Affordable Foreclosure Alternative Program. It is important to note that Treasury’s compliance work related to MHA applies only to those servicers that have agreed to participate in MHA for mortgage loans that are not owned or guaranteed by Fannie Mae or Freddie Mac (Government Sponsored Enterprises, or GSEs). Treasury cannot and does not perform compliance reviews of (1) mortgage loans or activities that fall outside of MHA, (2) GSE loans or (3) those loans insured through the Federal Housing Administration. For each servicer, the loans that are eligible for MHA represent only a portion of that servicer’s overall mortgage servicing operation. Treasury’s foremost goal is to assist struggling homeowners who may be eligible for MHA. These servicer assessments set a new benchmark for providing detailed information about how mortgage servicers are performing against key metrics. But, in addition to this direct effect, MHA has had an important indirect effect on the market as well. MHA has established standards that have improved mortgage modifications across the industry, and has led to important changes in the way mortgage servicers assist struggling homeowners generally. These changes include standards for how mortgage modifications should be designed so that they are sustainable, standards for communications with homeowners so that the process is as efficient and as understandable as possible, and a variety of standards for protecting homeowners, such as prohibitions on “dual tracking” – simultaneously evaluating a homeowner for a modification while proceeding to foreclose. Going forward, Treasury hopes these assessments will also set the standard for transparency about mortgage servicer efforts to assist homeowners. Below are general descriptions of the data, the evaluation process, and the consequences for servicers needing improvement. (Continued on next page) 16 MHA Servicer Assessment Overview The Performance Data: Compliance and Program Results Freddie Mac, acting as Treasury’s compliance agent for MHA, has created a separate division known as Making Home Affordable–Compliance (MHA-C) to evaluate servicer performance through reviews of program compliance. MHAC tests and evaluates a range of servicer activities for compliance with MHA guidelines. Once MHA-C’s reviews are complete, MHA-C shares its results with the servicers and identifies areas that need remediation. Each compliance activity tested falls into one of three overall compliance categories – Identifying and Contacting Homeowners, Homeowner Evaluation and Assistance, and Program Management, Reporting and Governance. The compliance results shared with the servicers are then used to generate the servicer assessments. The assessments highlight particular compliance activities tested by MHA-C that had significant impact on homeowners and include for those highlighted activities a one-star, two-star, or three-star rating for the most recent evaluations. One star means the servicer did not meet Treasury’s benchmark required for that particular activity, and the servicer needs substantial improvement in its performance of that activity. Two stars mean the servicer did not meet Treasury’s benchmark required for that particular activity, and the servicer needs moderate improvement in its performance of that activity. Three stars mean the servicer met Treasury’s benchmark required for that particular activity, but the servicer may nonetheless need minor improvement in its performance of that activity. Although the compliance reviews emphasize objective measurements and observed facts, compliance reviews still involve a certain level of judgment. Compliance reviews are also retrospective in nature – looking backward, not forward, which means that activities identified as needing improvement in a given quarter may already be under remediation by the servicer. In addition, not every compliance activity is evaluated every quarter, which means that a rating from one quarter might carry forward to the subsequent quarter’s assessment if that activity was not retested in that subsequent quarter. Finally, the compliance reviews use “sampling” as a testing methodology. Sampling, an industry-accepted auditing technique, looks at a subset of a particular population of activity transactions, rather than the entirety of the population of activity transactions, to extrapolate a servicer’s overall performance in that particular activity. In addition to the ratings for compliance data, the assessments also include program results metrics. Fannie Mae, acting as Treasury’s program administrator for MHA, collects servicer data used to measure program results. These metrics are key indicators of how timely and effectively servicers assist eligible homeowners under MHA guidelines and report program data. Although the servicers are not given an overall rating for this data, the results metrics nonetheless compare a servicer’s performance for a given quarter against the “best” and “worst” performing servicer of the 10 largest servicers participating in the program. The results metrics provide a snapshot of how each of those servicers compares in specific areas under MHA. The Determination Process: Results of the Data Treasury reviews the compliance data and ratings, the program results metrics, and other relevant factors affecting servicer performance (including, but not limited to, a servicer’s progress in implementing previously identified improvements) in determining whether a servicer needs substantial improvement, moderate improvement, or minor improvement to its performance under MHA guidelines. The assessments summarize the significant factors impacting those decisions. Based on those assessments, Treasury may take remedial action against servicers. Page 18 summarizes the overall level of improvement needed for each servicer. Consequences for Servicers For servicers in need of substantial improvement, Treasury will, absent extenuating circumstances, withhold financial incentives owed to those servicers until they make certain identified improvements. In certain cases, particularly where there is a failure to correct identified problems within a reasonable time, Treasury may also permanently reduce the financial incentives. Servicers in need of moderate improvement may be subject to withholding in the future if they fail to make certain identified improvements. All withholdings apply only to incentives owed to servicers for their participation in MHA; these withholdings do not apply to incentives paid to servicers for the benefit of homeowners or investors. Additional Information See the “Metrics Description” on page 39 for a description of each of the compliance and results metrics presented in the assessments. For more information on the assessments, please visit: www.FinancialStability.gov. 17 MHA Servicer Assessment Overview 3rd Quarter 2011 Servicer Assessment Results The following table details the results of the Servicer Assessments, based on compliance and program results: Improvement Needed Servicer Name Substantial JPMorgan Chase Bank, NA Moderate American Home Mortgage Servicing, Inc. Bank of America, NA CitiMortgage, Inc. GMAC Mortgage, LLC 1 Litton Loan Servicing, LP Ocwen Loan Servicing, LLC Wells Fargo Bank, NA Minor OneWest Bank Select Portfolio Servicing After evaluating the Third Quarter 2011 MHA Servicer Assessments, Treasury will continue to withhold servicer incentives owed to JPMorgan Chase Bank, NA, which requires substantial improvement due to their lack of progress in implementing previously identified improvements. With the exception of Bank of America, NA, Treasury is not withholding servicer incentives for servicers requiring moderate improvement for this quarter. However, those servicers that fail to improve in those areas identified may be subject to servicer incentive withholding in the future, and Treasury will continue to withhold servicer incentives from Bank of America, NA, until it makes additional improvements. Two servicers have been identified as needing minor improvement for this quarter. Please refer to the following MHA Servicer Assessment pages for further detail on the Third Quarter 2011 servicer assessment results. 1Effective November 1, 2011 Litton Loan Servicing, LP transferred its loan portfolio to Ocwen Loan Servicing, LLC. 18 MHA Servicer Assessment: American Home Mortgage Servicing Inc. Compliance Results Overview These metrics reflect the results of compliance reviews of the servicer's adherence to MHA Program Requirements. Quantitative results reflect percentages of tests that did not have a desired outcome. Servicers are rated qualitatively on the effectiveness of their internal control in the three Performance Categories as well as for each quantitative result. Third Quarter 2011 Performance Category Identifying and Contacting Homeowners Metric Second Look % Disagree Percentage of loans reviewed where MHA-C did not concur with the servicer's MHA determination Assesses whether the servicer identifies and communicates appropriately with potentially eligible MHA homeowners. Second Look % Unable to Determine Percentage of loans reviewed where MHA-C was not able to conclude on the servicer's MHA determination Assesses whether servicer correctly evaluates homeowners' eligibility for MHA programs, communicates decisions in a timely manner, and accurately executes appropriate MHA activities. Program Management, Reporting, and Governance Assesses whether the servicer has effective program management, governance processes, and timely and correct submission of program reports and program information. Internal Controls for Program Management, Reporting, and Governance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Legend 0.0% < 10% 0.0% - < 5% 2.0% - < 5% 6.8% - Incentive Payment Data Errors Average percentage of difference in calculated incentives resulting from data discrepancies between servicer files and the MHA system of record < 4% Internal Controls for Homeowner Evaluation and Assistance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Income Calculation Error % Percentage of loans for which MHA-C's income calculation differs from the servicer's by more than 5% Servicer Result Internal Controls for Identifying and Contacting Homeowners MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Homeowner Evaluation and Assistance Benchmark Result Did not meet benchmark; substantial improvement needed American Home Mortgage Servicing Inc. has areas requiring moderate improvement. Did not meet benchmark; moderate improvement needed After considering all relevant factors, American Home Mortgage Servicing Inc. servicer incentives will not be withheld at this time. Met benchmark; minor improvement may be indicated 19 MHA Servicer Assessment: American Home Mortgage Servicing Inc. Program Results Conversion Rate for Trials Started On or After 6/1/2010 Aged Trials as a Percentage of Active Trials 2% 1% 2% Best Servicer Performance American Home Mortgage Servicing Inc. 19% 8% 27% 10% 20% 30% 34% 35% 40% Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance American Home Mortgage Servicing Inc. 0% Worst Servicer Performance 30 40 40% 60% 50 March 2011 June 2011 Sep. 2011 72% 80% 100% 0.0% 0.0% 0.0% 0.6% 0.4% 0.2% 3.9% 3.4% 3.6% Worst Servicer Performance 39 20 20% Results as of: Missing Modification Status Reports (%) American Home Mortgage Servicing Inc. 28 10 54% 62% Worst Servicer Performance Best Servicer Performance 9 0 78% 85% 86% American Home Mortgage Servicing Inc. 29% Worst Servicer Performance 0% 84% 88% 90% Best Servicer Performance 0% 1% 2% 3% 4% 5% Note: The best and worst performance reflect the best and worst result of the largest 10 servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 2011 only includes non-GSE cases resolved after 2/1/2011. 20 MHA Servicer Assessment: Bank of America, NA Compliance Results Overview These metrics reflect the results of compliance reviews of the servicer's adherence to MHA Program Requirements. Quantitative results reflect percentages of tests that did not have a desired outcome. Servicers are rated qualitatively on the effectiveness of their internal control in the three Performance Categories as well as for each quantitative result. Third Quarter 2011 Performance Category Identifying and Contacting Homeowners Metric Second Look % Disagree Percentage of loans reviewed where MHA-C did not concur with the servicer's MHA determination Assesses whether the servicer identifies and communicates appropriately with potentially eligible MHA homeowners. Second Look % Unable to Determine Percentage of loans reviewed where MHA-C was not able to conclude on the servicer's MHA determination Homeowner Evaluation and Assistance Assesses whether servicer correctly evaluates homeowners' eligibility for MHA programs, communicates decisions in a timely manner, and accurately executes appropriate MHA activities. Program Management, Reporting, and Governance Assesses whether the servicer has effective program management, governance processes, and timely and correct submission of program reports and program information. Internal Controls for Program Management, Reporting, and Governance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Legend 1.0% < 10% 1.5% - < 5% 6.0% - < 5% 1.1% - Incentive Payment Data Errors Average percentage of difference in calculated incentives resulting from data discrepancies between servicer files and the MHA system of record < 4% Internal Controls for Homeowner Evaluation and Assistance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Income Calculation Error % Percentage of loans for which MHA-C's income calculation differs from the servicer's by more than 5% Servicer Result Internal Controls for Identifying and Contacting Homeowners MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Benchmark Result Did not meet benchmark; substantial improvement needed Bank of America, NA has areas requiring moderate improvement. Did not meet benchmark; moderate improvement needed After considering all relevant factors, Bank of America, NA servicer incentives will continue to be withheld at this time. Met benchmark; minor improvement may be indicated 21 MHA Servicer Assessment: Bank of America, NA Program Results Conversion Rate for Trials Started On or After 6/1/2010 Aged Trials as a Percentage of Active Trials 2% 1% 2% Best Servicer Performance 22% Bank of America, NA 26% 35% 29% Worst Servicer Performance 0% 10% 20% 30% 34% 35% 40% Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance Bank of America, NA 32 Worst Servicer Performance 39 10 54% 62% Bank of America, NA 54% 62% Worst Servicer Performance 0% 20 30 40 50 20% 40% 60% Results as of: March 2011 June 2011 Sep. 2011 76% 72% 80% 100% Missing Modification Status Reports (%) 0.0% 0.0% 0.0% Best Servicer Performance 9 0 84% 88% 90% Best Servicer Performance Bank of America, NA 3.9% 3.4% 3.6% Worst Servicer Performance 3.9% 3.4% 3.6% 0% 1% 2% 3% 4% 5% Note: The best and worst performance reflect the best and worst result of the largest 10 servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 2011 only includes non-GSE cases resolved after 2/1/2011. 22 MHA Servicer Assessment: CitiMortgage, Inc. Compliance Results Overview These metrics reflect the results of compliance reviews of the servicer's adherence to MHA Program Requirements. Quantitative results reflect percentages of tests that did not have a desired outcome. Servicers are rated qualitatively on the effectiveness of their internal control in the three Performance Categories as well as for each quantitative result. Third Quarter 2011 Performance Category Identifying and Contacting Homeowners Metric Second Look % Disagree Percentage of loans reviewed where MHA-C did not concur with the servicer's MHA determination Assesses whether the servicer identifies and communicates appropriately with potentially eligible MHA homeowners. Second Look % Unable to Determine Percentage of loans reviewed where MHA-C was not able to conclude on the servicer's MHA determination Assesses whether servicer correctly evaluates homeowners' eligibility for MHA programs, communicates decisions in a timely manner, and accurately executes appropriate MHA activities. Program Management, Reporting, and Governance Assesses whether the servicer has effective program management, governance processes, and timely and correct submission of program reports and program information. Internal Controls for Program Management, Reporting, and Governance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Legend 1.5% < 10% 0.5% - < 5% 6.0% - < 5% 8.4% - Incentive Payment Data Errors Average percentage of difference in calculated incentives resulting from data discrepancies between servicer files and the MHA system of record < 4% Internal Controls for Homeowner Evaluation and Assistance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Income Calculation Error % Percentage of loans for which MHA-C's income calculation differs from the servicer's by more than 5% Servicer Result Internal Controls for Identifying and Contacting Homeowners MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Homeowner Evaluation and Assistance Benchmark Result Did not meet benchmark; substantial improvement needed CitiMortgage, Inc. has areas requiring moderate improvement. Did not meet benchmark; moderate improvement needed After considering all relevant factors,CitiMortgage, Inc. servicer incentives will not be withheld at this time. Met benchmark; minor improvement may be indicated 23 MHA Servicer Assessment: CitiMortgage, Inc. Program Results Conversion Rate for Trials Started On or After 6/1/2010 Aged Trials as a Percentage of Active Trials 2% 1% 2% Best Servicer Performance 29% CitiMortgage, Inc. 29% Worst Servicer Performance 0% 10% 20% 30% 34% 35% 34% 35% 40% Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance 28 CitiMortgage, Inc. Worst Servicer Performance 54% 62% Worst Servicer Performance 0% 20 30 40 20% 40% 60% March 2011 June 2011 Sep. 2011 72% 80% 100% 0.0% 0.0% 0.0% 1.0% 0.9% 2.3% 3.9% 3.4% 3.6% Worst Servicer Performance 50 Results as of: Missing Modification Status Reports (%) CitiMortgage, Inc. 39 10 73% 75% 81% CitiMortgage, Inc. Best Servicer Performance 9 0 84% 88% 90% Best Servicer Performance 0% 1% 2% 3% 4% 5% Note: The best and worst performance reflect the best and worst result of the largest 10 servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 2011 only includes non-GSE cases resolved after 2/1/2011. 24 MHA Servicer Assessment: GMAC Mortgage, LLC Compliance Results Overview These metrics reflect the results of compliance reviews of the servicer's adherence to MHA Program Requirements. Quantitative results reflect percentages of tests that did not have a desired outcome. Servicers are rated qualitatively on the effectiveness of their internal control in the three Performance Categories as well as for each quantitative result. Third Quarter 2011 Performance Category Identifying and Contacting Homeowners Metric Second Look % Disagree Percentage of loans reviewed where MHA-C did not concur with the servicer's MHA determination Assesses whether the servicer identifies and communicates appropriately with potentially eligible MHA homeowners. Second Look % Unable to Determine Percentage of loans reviewed where MHA-C was not able to conclude on the servicer's MHA determination Assesses whether servicer correctly evaluates homeowners' eligibility for MHA programs, communicates decisions in a timely manner, and accurately executes appropriate MHA activities. Program Management, Reporting, and Governance Assesses whether the servicer has effective program management, governance processes, and timely and correct submission of program reports and program information. 1.0% < 10% 0.0% - < 5% 4.2% 1 - < 5% 2.9% 1 - Incentive Payment Data Errors Average percentage of difference in calculated incentives resulting from data discrepancies between servicer files and the MHA system of record < 4% Internal Controls for Homeowner Evaluation and Assistance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Income Calculation Error % Percentage of loans for which MHA-C's income calculation differs from the servicer's by more than 5% Servicer Result Internal Controls for Identifying and Contacting Homeowners MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Homeowner Evaluation and Assistance Benchmark Internal Controls for Program Management, Reporting, and Governance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines 1 - Rating carried forward from prior quarter. Rating Legend Result Did not meet benchmark; substantial improvement needed GMAC Mortgage, LLC has areas requiring moderate improvement. Did not meet benchmark; moderate improvement needed After considering all relevant factors, GMAC Mortgage, LLC servicer incentives will not be withheld at this time. Met benchmark; minor improvement may be indicated 25 MHA Servicer Assessment: GMAC Mortgage, LLC Program Results Conversion Rate for Trials Started On or After 6/1/2010 Aged Trials as a Percentage of Active Trials Results as of: Best Servicer Performance 2% 1% 2% Best Servicer Performance GMAC Mortgage, LLC 2% 1% 2% GMAC Mortgage, LLC 29% Worst Servicer Performance 0% 10% 20% 34% 35% 30% 40% Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance 12 10 0% 20 30 40 20% 40% 60% 50 June 2011 Sep. 2011 80% 100% Missing Modification Status Reports (%) 0.0% 0.0% 0.0% 0.1% 0.1% 1.4% 3.9% 3.4% 3.6% Worst Servicer Performance 39 March 2011 54% 62% 72% Worst Servicer Performance GMAC Mortgage, LLC Worst Servicer Performance 0 79% 80% 84% Best Servicer Performance 9 GMAC Mortgage, LLC 84% 88% 90% 0% 1% 2% 3% 4% 5% Note: The best and worst performance reflect the best and worst result of the largest 10 servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 2011 only includes non-GSE cases resolved after 2/1/2011. 26 MHA Servicer Assessment: JPMorgan Chase Bank, NA Compliance Results Overview These metrics reflect the results of compliance reviews of the servicer's adherence to MHA Program Requirements. Quantitative results reflect percentages of tests that did not have a desired outcome. Servicers are rated qualitatively on the effectiveness of their internal control in the three Performance Categories as well as for each quantitative result. Third Quarter 2011 Performance Category Identifying and Contacting Homeowners Metric Second Look % Disagree Percentage of loans reviewed where MHA-C did not concur with the servicer's MHA determination Assesses whether the servicer identifies and communicates appropriately with potentially eligible MHA homeowners. Second Look % Unable to Determine Percentage of loans reviewed where MHA-C was not able to conclude on the servicer's MHA determination Assesses whether servicer correctly evaluates homeowners' eligibility for MHA programs, communicates decisions in a timely manner, and accurately executes appropriate MHA activities. Program Management, Reporting, and Governance Assesses whether the servicer has effective program management, governance processes, and timely and correct submission of program reports and program information. Internal Controls for Program Management, Reporting, and Governance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Legend < 10% 0.9% - < 5% 6.0% - < 5% 5.7% - Result Did not meet benchmark; substantial improvement needed Did not meet benchmark; moderate improvement needed Met benchmark; minor improvement may be indicated 0.0% Incentive Payment Data Errors Average percentage of difference in calculated incentives resulting from data discrepancies between servicer files and the MHA system of record < 4% Internal Controls for Homeowner Evaluation and Assistance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Income Calculation Error % Percentage of loans for which MHA-C's income calculation differs from the servicer's by more than 5% Servicer Result Internal Controls for Identifying and Contacting Homeowners MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Homeowner Evaluation and Assistance Benchmark JPMorgan Chase Bank, NA has areas requiring substantial improvement due to their lack of progress in implementing previously identified improvements. After considering all relevant factors, JPMorgan Chase Bank, NA servicer incentives will continue to be withheld at this time. 27 MHA Servicer Assessment: JPMorgan Chase Bank, NA Program Results Conversion Rate for Trials Started On or After 6/1/2010 Aged Trials as a Percentage of Active Trials Results as of: 2% 1% 2% Best Servicer Performance 9% JPMorgan Chase Bank, NA 17% 29% 10% 20% 30% 34% 35% 40% Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance 54% 62% Worst Servicer Performance 0% JPMorgan Chase Bank, NA 39 JPMorgan Chase Bank, NA Worst Servicer Performance 39 Worst Servicer Performance 0 10 20 30 40 50 40% 60% June 2011 72% 80% 100% Missing Modification Status Reports (%) 0.0% 0.0% 0.0% Best Servicer Performance 9 20% March 2011 Sep. 2011 57% 66% 72% JPMorgan Chase Bank, NA 23% Worst Servicer Performance 0% 84% 88% 90% Best Servicer Performance 0.7% 0.5% 0.2% 3.9% 3.4% 3.6% 0% 1% 2% 3% 4% 5% Note: The best and worst performance reflect the best and worst result of the largest 10 servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 2011 only includes non-GSE cases resolved after 2/1/2011. 28 MHA Servicer Assessment: Litton Loan Servicing, LP Compliance Results Overview These metrics reflect the results of compliance reviews of the servicer's adherence to MHA Program Requirements. Quantitative results reflect percentages of tests that did not have a desired outcome. Servicers are rated qualitatively on the effectiveness of their internal control in the three Performance Categories as well as for each quantitative result. Third Quarter 2011 Performance Category Identifying and Contacting Homeowners Metric Second Look % Disagree Percentage of loans reviewed where MHA-C did not concur with the servicer's MHA determination Assesses whether the servicer identifies and communicates appropriately with potentially eligible MHA homeowners. Second Look % Unable to Determine Percentage of loans reviewed where MHA-C was not able to conclude on the servicer's MHA determination Assesses whether servicer correctly evaluates homeowners' eligibility for MHA programs, communicates decisions in a timely manner, and accurately executes appropriate MHA activities. Program Management, Reporting, and Governance Assesses whether the servicer has effective program management, governance processes, and timely and correct submission of program reports and program information. Internal Controls for Program Management, Reporting, and Governance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Legend 1.0% < 10% 2.0% - < 5% 1.0% - < 5% 1.9% - Incentive Payment Data Errors Average percentage of difference in calculated incentives resulting from data discrepancies between servicer files and the MHA system of record < 4% Internal Controls for Homeowner Evaluation and Assistance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Income Calculation Error % Percentage of loans for which MHA-C's income calculation differs from the servicer's by more than 5% Servicer Result Internal Controls for Identifying and Contacting Homeowners MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Homeowner Evaluation and Assistance Benchmark Result Did not meet benchmark; substantial improvement needed Litton Loan Servicing, LP has areas requiring moderate improvement. Did not meet benchmark; moderate improvement needed After considering all relevant factors,Litton Loan Servicing, LP servicer incentives will not be withheld at this time. Met benchmark; minor improvement may be indicated Note: Effective November 1, 2011 Litton Loan Servicing, LP transferred its loan portfolio to Ocwen Loan Servicing, LLC. 29 MHA Servicer Assessment: Litton Loan Servicing, LP Program Results Conversion Rate for Trials Started On or After 6/1/2010 Aged Trials as a Percentage of Active Trials Results as of: 2% 1% 2% Best Servicer Performance 11% 10% Litton Loan Servicing, LP 29% 10% 20% 30% 34% 35% 40% Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance Worst Servicer Performance 20 30 40 40% 60% 50 72% 80% 100% 0.0% 0.0% 0.0% 0.2% 0.6% 0.7% 3.9% 3.4% 3.6% Worst Servicer Performance 39 10 20% June 2011 Missing Modification Status Reports (%) Litton Loan Servicing, LP 18 0 0% Best Servicer Performance 9 Litton Loan Servicing, LP 54% 62% Worst Servicer Performance March 2011 Sep. 2011 74% 72% 81% Litton Loan Servicing, LP 18% Worst Servicer Performance 0% 84% 88% 90% Best Servicer Performance 0% 1% 2% 3% 4% 5% Note: The best and worst performance reflect the best and worst result of the largest 10 servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 2011 only includes non-GSE cases resolved after 2/1/2011. 30 MHA Servicer Assessment: Ocwen Loan Servicing, LLC Compliance Results Overview These metrics reflect the results of compliance reviews of the servicer's adherence to MHA Program Requirements. Quantitative results reflect percentages of tests that did not have a desired outcome. Servicers are rated qualitatively on the effectiveness of their internal control in the three Performance Categories as well as for each quantitative result. Third Quarter 2011 Performance Category Identifying and Contacting Homeowners Metric Second Look % Disagree Percentage of loans reviewed where MHA-C did not concur with the servicer's MHA determination Assesses whether the servicer identifies and communicates appropriately with potentially eligible MHA homeowners. Second Look % Unable to Determine Percentage of loans reviewed where MHA-C was not able to conclude on the servicer's MHA determination Assesses whether servicer correctly evaluates homeowners' eligibility for MHA programs, communicates decisions in a timely manner, and accurately executes appropriate MHA activities. Program Management, Reporting, and Governance Assesses whether the servicer has effective program management, governance processes, and timely and correct submission of program reports and program information. Internal Controls for Program Management, Reporting, and Governance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Legend 0.0% < 10% 2.4% - < 5% 2.0% - < 5% 2.3% - Incentive Payment Data Errors Average percentage of difference in calculated incentives resulting from data discrepancies between servicer files and the MHA system of record < 4% Internal Controls for Homeowner Evaluation and Assistance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Income Calculation Error % Percentage of loans for which MHA-C's income calculation differs from the servicer's by more than 5% Servicer Result Internal Controls for Identifying and Contacting Homeowners MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Homeowner Evaluation and Assistance Benchmark Result Did not meet benchmark; substantial improvement needed Ocwen Loan Servicing, LLC has areas requiring moderate improvement. Did not meet benchmark; moderate improvement needed After considering all relevant factors, Ocwen Loan Servicing, LLC servicer incentives will not be withheld at this time. Met benchmark; minor improvement may be indicated 31 MHA Servicer Assessment: Ocwen Loan Servicing, LLC Program Results Conversion Rate for Trials Started On or After 6/1/2010 Aged Trials as a Percentage of Active Trials Results as of: 2% 1% 2% Best Servicer Performance Ocwen Loan Servicing, LLC 13% 20% 18% 10% 20% 30% 34% 35% 40% Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance Worst Servicer Performance 20 30 40 40% 60% 50 72% 80% 100% 0.0% 0.0% 0.0% 0.4% 0.5% 0.5% 3.9% 3.4% 3.6% Worst Servicer Performance 39 10 20% June 2011 Missing Modification Status Reports (%) Ocwen Loan Servicing, LLC 11 0 0% Best Servicer Performance 9 Ocwen Loan Servicing, LLC 54% 62% Worst Servicer Performance March 2011 Sep. 2011 76% 79% 82% Ocwen Loan Servicing, LLC 29% Worst Servicer Performance 0% 84% 88% 90% Best Servicer Performance 0% 1% 2% 3% 4% 5% Note: The best and worst performance reflect the best and worst result of the largest 10 servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 2011 only includes non-GSE cases resolved after 2/1/2011. 32 MHA Servicer Assessment: OneWest Bank Compliance Results Overview These metrics reflect the results of compliance reviews of the servicer's adherence to MHA Program Requirements. Quantitative results reflect percentages of tests that did not have a desired outcome. Servicers are rated qualitatively on the effectiveness of their internal control in the three Performance Categories as well as for each quantitative result. Third Quarter 2011 Performance Category Identifying and Contacting Homeowners Metric Benchmark Servicer Result Rating < 4% 0.0% < 10% 0.0% - < 5% 2.0% 1 - < 5% 1.8% 1 - Second Look % Disagree Percentage of loans reviewed where MHA-C did not concur with the servicer's MHA determination Assesses whether the servicer identifies and communicates appropriately with potentially eligible MHA homeowners. Second Look % Unable to Determine Percentage of loans reviewed where MHA-C was not able to conclude on the servicer's MHA determination Internal Controls for Identifying and Contacting Homeowners MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Homeowner Evaluation and Assistance Assesses whether servicer correctly evaluates homeowners' eligibility for MHA programs, communicates decisions in a timely manner, and accurately executes appropriate MHA activities. Program Management, Reporting, and Governance Assesses whether the servicer has effective program management, governance processes, and timely and correct submission of program reports and program information. Income Calculation Error % Percentage of loans for which MHA-C's income calculation differs from the servicer's by more than 5% Internal Controls for Homeowner Evaluation and Assistance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Incentive Payment Data Errors Average percentage of difference in calculated incentives resulting from data discrepancies between servicer files and the MHA system of record Internal Controls for Program Management, Reporting, and Governance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines 1 - Rating carried forward from prior quarter. Rating Legend Did not meet benchmark; substantial improvement needed Result OneWest Bank has areas requiring minor improvement. Did not meet benchmark; moderate improvement needed Met benchmark; minor improvement may be indicated 33 MHA Servicer Assessment: OneWest Bank Program Results Conversion Rate for Trials Started On or After 6/1/2010 Aged Trials as a Percentage of Active Trials Results as of: 2% 1% 2% Best Servicer Performance 6% 5% OneWest Bank 14% 29% 10% 20% 30% 34% 35% 40% Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance 19 20 30 40 20% 40% 60% 50 June 2011 72% 80% 100% Missing Modification Status Reports (%) 0.0% 0.0% 0.0% 0.3% 0.0% 0.0% 3.9% 3.4% 3.6% Worst Servicer Performance 39 10 0% OneWest Bank Worst Servicer Performance 0 54% 62% Best Servicer Performance 9 OneWest Bank 79% 77% Worst Servicer Performance March 2011 Sep. 2011 67% OneWest Bank Worst Servicer Performance 0% 84% 88% 90% Best Servicer Performance 0% 1% 2% 3% 4% 5% Note: The best and worst performance reflect the best and worst result of the largest 10 servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 2011 only includes non-GSE cases resolved after 2/1/2011. 34 MHA Servicer Assessment: Select Portfolio Servicing Compliance Results Overview These metrics reflect the results of compliance reviews of the servicer's adherence to MHA Program Requirements. Quantitative results reflect percentages of tests that did not have a desired outcome. Servicers are rated qualitatively on the effectiveness of their internal control in the three Performance Categories as well as for each quantitative result. Third Quarter 2011 Performance Category Identifying and Contacting Homeowners Metric Second Look % Disagree Percentage of loans reviewed where MHA-C did not concur with the servicer's MHA determination Assesses whether the servicer identifies and communicates appropriately with potentially eligible MHA homeowners. Second Look % Unable to Determine Percentage of loans reviewed where MHA-C was not able to conclude on the servicer's MHA determination Assesses whether servicer correctly evaluates homeowners' eligibility for MHA programs, communicates decisions in a timely manner, and accurately executes appropriate MHA activities. Program Management, Reporting, and Governance Assesses whether the servicer has effective program management, governance processes, and timely and correct submission of program reports and program information. Internal Controls for Program Management, Reporting, and Governance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Legend Did not meet benchmark; substantial improvement needed 0.8% < 10% 0.8% - < 5% 3.2% - < 5% 2.3% - Incentive Payment Data Errors Average percentage of difference in calculated incentives resulting from data discrepancies between servicer files and the MHA system of record < 4% Internal Controls for Homeowner Evaluation and Assistance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Income Calculation Error % Percentage of loans for which MHA-C's income calculation differs from the servicer's by more than 5% Servicer Result Internal Controls for Identifying and Contacting Homeowners MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Homeowner Evaluation and Assistance Benchmark Result Select Portfolio Servicing has areas requiring minor improvement. Did not meet benchmark; moderate improvement needed Met benchmark; minor improvement may be indicated 35 MHA Servicer Assessment: Select Portfolio Servicing Program Results Conversion Rate for Trials Started On or After 6/1/2010 Aged Trials as a Percentage of Active Trials Results as of: 2% 1% 2% Best Servicer Performance Select Portfolio Servicing 10% 5% 5% 29% Worst Servicer Performance 0% 10% 20% 30% 34% 35% 40% Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance 84% 88% 90% March 2011 Select Portfolio Servicing 84% 88% 90% Sep. 2011 54% 62% Worst Servicer Performance 0% 9 Best Servicer Performance Select Portfolio Servicing 9 Select Portfolio Servicing 10 20 30 40 60% 50 80% 100% 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 3.9% 3.4% 3.6% Worst Servicer Performance 39 0 40% 72% Missing Modification Status Reports (%) Best Servicer Performance Worst Servicer Performance 20% June 2011 0% 1% 2% 3% 4% 5% Note: The best and worst performance reflect the best and worst result of the largest 10 servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 2011 only includes non-GSE cases resolved after 2/1/2011. 36 MHA Servicer Assessment: Wells Fargo Bank, NA Compliance Results Overview These metrics reflect the results of compliance reviews of the servicer's adherence to MHA Program Requirements. Quantitative results reflect percentages of tests that did not have a desired outcome. Servicers are rated qualitatively on the effectiveness of their internal control in the three Performance Categories as well as for each quantitative result. Third Quarter 2011 Performance Category Identifying and Contacting Homeowners Metric Second Look % Disagree Percentage of loans reviewed where MHA-C did not concur with the servicer's MHA determination Assesses whether the servicer identifies and communicates appropriately with potentially eligible MHA homeowners. Second Look % Unable to Determine Percentage of loans reviewed where MHA-C was not able to conclude on the servicer's MHA determination Assesses whether servicer correctly evaluates homeowners' eligibility for MHA programs, communicates decisions in a timely manner, and accurately executes appropriate MHA activities. Program Management, Reporting, and Governance Assesses whether the servicer has effective program management, governance processes, and timely and correct submission of program reports and program information. Internal Controls for Program Management, Reporting, and Governance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Legend 0.4% < 10% 1.3% - < 5% 5.5% - < 5% 1.9% - Incentive Payment Data Errors Average percentage of difference in calculated incentives resulting from data discrepancies between servicer files and the MHA system of record < 4% Internal Controls for Homeowner Evaluation and Assistance MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Rating Income Calculation Error % Percentage of loans for which MHA-C's income calculation differs from the servicer's by more than 5% Servicer Result Internal Controls for Identifying and Contacting Homeowners MHA-C assesses whether servicer business processes are conducted effectively and in accordance with MHA guidelines Homeowner Evaluation and Assistance Benchmark Result Did not meet benchmark; substantial improvement needed Wells Fargo Bank, NA has areas requiring moderate improvement. Did not meet benchmark; moderate improvement needed After considering all relevant factors,Wells Fargo Bank, NA servicer incentives will not be withheld at this time. Met benchmark; minor improvement may be indicated 37 MHA Servicer Assessment: Wells Fargo Bank, NA Program Results Conversion Rate for Trials Started On or After 6/1/2010 Aged Trials as a Percentage of Active Trials Results as of: 2% 1% 2% Best Servicer Performance 11% 11% 12% Wells Fargo Bank, NA 29% Worst Servicer Performance 0% 10% 20% 30% 34% 35% 40% Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance Wells Fargo Bank, NA Wells Fargo Bank, NA 75% 84% 88% 54% 62% Worst Servicer Performance 0% Worst Servicer Performance 30 40 40% 60% 50 June 2011 Sep. 2011 72% 80% 100% 0.0% 0.0% 0.0% 0.3% 0.5% 1.3% 3.9% 3.4% 3.6% Worst Servicer Performance 39 20 20% March 2011 Missing Modification Status Reports (%) Wells Fargo Bank, NA 25 10 84% 88% 90% Best Servicer Performance 9 0 Best Servicer Performance 0% 1% 2% 3% 4% 5% Note: The best and worst performance reflect the best and worst result of the largest 10 servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 2011 only includes non-GSE cases resolved after 2/1/2011. 38 MHA Servicer Assessment Metrics Descriptions Appendix conducting staff training on income calculation. Incentive Payment Data Errors: Treasury pays incentives to servicers, investors, and homeowners Second Look % Disagree: Second Look is a process in for permanent modifications completed under MHA. which MHA-C reviews loans not in a permanent Although intended for different recipients, all modification, to assess the accuracy of the servicer’s incentives are paid through the servicer. Data that determination of whether the homeowner is eligible servicers upload to the program system of record is for a modification. This metric measures the used to calculate the incentives paid to servicers, percentage of loans reviewed in Second Look with investors, and homeowners. This metric measures which MHA-C disagrees with a servicer’s how data anomalies between servicer loan files and determination. the reported information affect incentive payments. For Incentive Payment Data Error results, remedial Second Look % Unable to Determine: This metric actions Treasury requires servicers to take include, measures the percentage of loans reviewed in Second but are not limited to: correcting the identified errors Look for which MHA-C is not able to determine, based and correcting system and operational processes such on the documentation provided, how the servicer that accurate data is mapped to its appropriate places reached its loan-modification decision. in the program system of record. For both Second Look Disagree and Unable to Determine results, remedial actions Treasury requires Compliance Metrics (qualitative) servicers to take include, but are not limited to: Servicers establish processes and internal controls to reevaluating loans not offered HAMP modifications, help ensure their compliance with Program guidance. submitting additional documentation to support the For each of the performance categories, Treasury initial reason for denial of the modification, clarifying performs a qualitative assessment of those internal loan status, and engaging in systemic process controls based on MHA-C’s compliance reviews. That remediation. For such results, servicers are also assessment evaluates the nature, scope, and reminded of their obligation to suspend foreclosure of potential or actual impact on homeowners resulting the loan until the unresolved items are remediated. from instances of servicer non-compliance with its own internal controls. For ineffective internal Income Calculation Errors: Correctly calculating homeowner monthly income is a critical component controls, remedial actions Treasury requires servicers to take include, but are not limited to: identifying and of evaluating eligibility for MHA, as well as establishing an accurate modification payment. This reevaluating any affected loans, enhancing the metric measures how often MHA-C disagrees with a effectiveness of internal controls, and conducting servicer’s calculation of a borrower’s Monthly Gross staff training on servicer procedures. Compliance Metrics (quantitative) Income, allowing for up to a 5% differential from MHA-C’s calculations. For Income Calculation Error results, remedial actions Treasury requires servicers to take include, but are not limited to: correcting income errors exceeding the 5% differential, requiring the servicer to review their own income calculation accuracy, enhancing policies and procedures, and Program Metrics Conversion Rate: This cumulative metric looks at the rate of conversion to permanent modification for trials started on or after June 1, 2010, when all servicers were required to verify income documentation at trial start. Conversion rate is measured against all trials eligible to convert – those three months in trial, or four months if the borrower was at risk of imminent default at trial modification start. Permanent modifications transferred among servicers are credited to the originating servicer; trial modifications transferred are reflected in the current servicer’s population. Aged Trials as % of Active Trials: This monthly metric measures trials lasting six months or longer as a share of all active trials. These figures include trial modifications that have been converted to permanent modifications by the servicer and are pending reporting to the program system of record, plus some portion which may be canceled. Days to Resolve Escalated Cases: This cumulative metric measures servicer response time for homeowner inquiries escalated to MHA Support Centers. Effective Feb. 1, 2011, a target of 30 calendar days was established for non-GSE escalation cases, including an estimated 5 days processing by the MHA Support Centers. The methodology for calculating average days to respond to escalated cases was recently updated and the Q3 2011 figures reflect non-GSE cases escalated on or after 2/1/2011. Investor denial cases, cases involving bankruptcy, and those cases that did not require servicer actions are not included in the calculation of servicer time to resolve escalations. % of Missing Modification Status Reports: This monthly metric measures the servicer’s ability to promptly report on modification status. Inconsistent and untimely reporting of modification status reports may impact incentive compensation and loan performance analysis. For more information on the assessments, please visit: www.FinancialStability.gov. 39 Making Home Affordable Program Performance Report Through October 2011 Appendix A1: Non-GSE Participants in HAMP Servicers participating in the HAMP First Lien Modification Program may also offer additional support for homeowners, including Home Affordable Foreclosure Alternatives (HAFA), a forbearance for unemployed borrowers through the Unemployment Program (UP), and Principal Reduction Alternative (PRA). Effective October 3, 2010, the ability to make new financial commitments under the Troubled Asset Relief Program (TARP) terminated, and consequently no new Servicer Participation Agreements may be executed. In addition, effective June 25, 2010, no new housing programs may be created under TARP. Allstate Mortgage Loans & Investments, Inc. American Eagle Federal Credit Union American Home Mortgage Servicing, Inc AMS Servicing, LLC Aurora Loan Services, LLC Bank of America, N.A.1 Bank United Bay Federal Credit Union Bayview Loan Servicing, LLC Carrington Mortgage Services, LLC CCO Mortgage Central Florida Educators Federal Credit Union CitiMortgage, Inc. Citizens 1st National Bank Community Bank & Trust Company Community Credit Union of Florida CUC Mortgage Corporation DuPage Credit Union Fay Servicing, LLC Fidelity Homestead Savings Bank First Bank First Financial Bank, N.A. Franklin Credit Management Corporation Franklin Savings Fresno County Federal Credit Union Glass City Federal Credit Union GMAC Mortgage, LLC Grafton Suburban Credit Union Great Lakes Credit Union Greater Nevada Mortgage Services Green Tree Servicing LLC Hartford Savings Bank Hillsdale County National Bank HomEq Servicing HomeStar Bank & Financial Services Horicon Bank Horizon Bank, NA IBM Southeast Employees' Federal Credit Union IC Federal Credit Union Idaho Housing and Finance Association iServe Residential Lending LLC iServe Servicing Inc. JPMorgan Chase Bank, NA2 Lake City Bank Lake National Bank Liberty Bank and Trust Co. Litton Loan Servicing Los Alamos National Bank Magna Bank Marix Servicing, LLC Midland Mortgage Company Midwest Community Bank Mission Federal Credit Union Mortgage Center, LLC Nationstar Mortgage LLC Navy Federal Credit Union Ocwen Loan Servicing, LLC OneWest Bank ORNL Federal Credit Union Park View Federal Savings Bank Pathfinder Bank PennyMac Loan Services, LLC PNC Bank, National Association PNC Mortgage3 Purdue Employees Federal Credit Union QLending, Inc. Quantum Servicing Corporation Residential Credit Solutions RG Mortgage Corporation RoundPoint Mortgage Servicing Corporation Saxon Mortgage Services, Inc. Schools Financial Credit Union SEFCU Select Portfolio Servicing Servis One Inc., dba BSI Financial Services, Inc. ShoreBank Silver State Schools Credit Union Specialized Loan Servicing, LLC Sterling Savings Bank Suburban Mortgage Company of New Mexico Technology Credit Union The Golden 1 Credit Union U.S. Bank National Association United Bank United Bank Mortgage Corporation Vantium Capital, Inc. Vist Financial Corp. Wealthbridge Mortgage Corp. Wells Fargo Bank, NA4 Yadkin Valley Bank 1 Bank of America, NA includes all loans previously reported under BAC Home Loans Servicing LP, Home Loan Services and Wilshire Credit Corporation. 2 JPMorgan Chase Bank, NA includes all loans previously reported under EMC Mortgage Corporation. 3 Formerly National City Bank. 4 Wells Fargo Bank, NA includes all loans previously reported under Wachovia Mortgage, FSB. 40 Making Home Affordable Program Performance Report Through October 2011 Appendix A2: Participants in Additional Making Home Affordable Programs Second Lien Modification Program (2MP) Bank of America, NA1 Bayview Loan Servicing, LLC CitiMortgage, Inc. Community Credit Union of Florida GMAC Mortgage, LLC Green Tree Servicing LLC iServe Residential Lending, LLC iServe Servicing, Inc. JPMorgan Chase Bank, NA2 Nationstar Mortgage LLC OneWest Bank PennyMac Loan Services, LLC PNC Bank, National Association PNC Mortgage 3 Residential Credit Solutions Servis One Inc., dba BSI Financial Services, Inc. Wells Fargo Bank, NA 4 FHA First Lien Program (Treasury FHA-HAMP) Amarillo National Bank American Financial Resources Inc. Aurora Financial Group, Inc. Aurora Loan Services, LLC Banco Popular de Puerto Rico Bank of America, NA1 Capital International Financial, Inc. CitiMortgage, Inc. CU Mortgage Services, Inc. First Federal Bank of Florida First Mortgage Corporation Franklin Savings Gateway Mortgage Group, LLC GMAC Mortgage, LLC. Green Tree Servicing LLC Guaranty Bank iServe Residential Lending, LLC iServe Servicing, Inc. James B. Nutter & Company JPMorgan Chase Bank,NA2 M&T Bank Marix Servicing, LLC Marsh Associates, Inc. Midland Mortgage Company Nationstar Mortgage LLC Ocwen Loan Servicing, LLC PennyMac Loan Services, LLC PNC Mortgage 3 RBC Bank (USA) Residential Credit Solutions Saxon Mortgage Services, Inc. Schmidt Mortgage Company Select Portfolio Servicing Servis One Inc., dba BSI Financial Services, Inc. Stockman Bank of Montana Wells Fargo Bank, NA 4 Weststar Mortgage, Inc. FHA Second Lien Program (FHA 2LP) Bank of America, NA1 Bayview Loan Servicing, LLC CitiMortgage, Inc. Flagstar Capital Markets Corporation GMAC Mortgage, LLC. Green Tree Servicing LLC JPMorgan Chase Bank, NA2 Nationstar Mortgage LLC PNC Bank, National Association PNC Mortgage 3 Residential Credit Solutions Saxon Mortgage Services, Inc. Select Portfolio Servicing Wells Fargo Bank, NA 4 Rural Housing Service Modification Program (RD-HAMP) Banco Popular de Puerto Rico Bank of America, N.A. 1 Horicon Bank JPMorgan Chase Bank, NA 2 Magna Bank Marix Servicing, LLC Midland Mortgage Company Nationstar Mortgage LLC Wells Fargo Bank, NA 4 1 Bank of America, NA includes all loans previously reported under BAC Home Loans Servicing LP, Home Loan Services and Wilshire Credit Corporation. 2 JPMorgan Chase Bank, NA includes all loans previously reported under EMC Mortgage Corporation. 3 Formerly National City Bank. 4 Wells Fargo Bank, NA includes all loans previously reported under Wachovia Mortgage FSB. 41