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Making Home Affordable Program Performance Report Through January 2012 Report Highlights Over 950,000 Homeowners Granted Permanent Modifications • Program to date, homeowners in permanent modifications have saved an estimated $11 billion in monthly mortgage payments. Homeowners in active first lien permanent modifications are currently saving a median of $533 per month – more than one-third of the median before-modification payment. • 85% of eligible homeowners entering a HAMP trial modification since June 1, 2010 have received a permanent modification, with an average trial period of 3.5 months. • For homeowners currently in HAMP permanent modifications with the Principal Reduction Alternative feature, the median amount of principal reduced is $68,063. This amounts to over $3.7 billion in principal reductions. These homeowners are further underwater and more seriously delinquent at trial start than the overall population of HAMP participants. 88% of homeowners in the PRA program are at least 60 days delinquent at trial start (compared to 80% of the overall HAMP portfolio) with a before-modification loan-to-value ratio of 159% (compared to 120% for the overall portfolio). This Month: Q4 2011 Servicer Assessment Results • For the fourth quarter of 2011, no servicers were determined to need substantial improvement in their performance under MHA guidelines. • Two servicers were found to need minor improvement on the areas reviewed for the fourth quarter, while seven servicers were found to need moderate improvement. Servicers will need to continue to demonstrate progress in areas identified in follow-up program reviews. SUMMARY RESULTS: Inside: 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 Outreach to 60+ Delinquent Homeowners Average Delinquency at Trial Start Trial Length Conversion Rate Homeowner Experience Disposition of Homeowners Not in HAMP 9 10 11 12 13 14 15 16-17 SERVICER ASSESSMENT RESULTS: Overview Servicer Results Description of Metrics 18-20 21-38 39 APPENDICES: Participants in MHA Programs 40-41 Making Home Affordable: Summary Results Program Performance Report Through January 2012 HAMP Activity: First Lien Modifications HAMP Trials Started (As of Dec. 31, 2011) Trial Modifications Permanent Modifications 884,910 Trial Plan Offers Extended (Cumulative)3 1,971,644 All Trials Started 1,791,354 1,700 1,640 1,650 16,759 Trial Modifications Canceled (Cumulative)5 763,692 1,450 Active Trials 76,343 1,400 All Permanent Modifications Started 951,319 1,350 Permanent Modifications Reported Since December 2011 Report 17,992 Permanent Modifications Canceled (Cumulative)6 182,546 Active Permanent Modifications 768,773 1,500 1,688 1,730 1,747 50 1,545 1,511 Jan 2011 Feb Mar Apr May June July Aug Sep Oct Note: Unless specified, exhibits in this report refer to HAMP first lien modification activity. Nov Dec Jan 2012 0 Source: HAMP system of record. Servicers may enter new trial modifications into the HAMP system of record at any time. For example, 16,759 trials have entered the HAMP system of record since the prior report; 12,335 were trials with a first payment recorded in January 2012. Permanent Modifications Started (Cumulative) 1,000 eligible 60+ day delinquent loans as reported by servicers as of December 31, 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 January 31, 2012. The reduction is due to Wells Fargo Bank, NA restating the number of trial offers extended from the previous month. 4 Servicers may enter new trial modifications into the HAMP system of record at anytime. 5 716,737 had trial start dates prior to June 1, 2010 when Treasury implemented a verified income requirement. 6 A permanent modification is canceled when the borrower has missed three consecutive monthly payments. Includes 3,124 loans paid off. 1,779 1,791 1,580 1,550 Trials Reported Since December 2011 Report4 1,665 1,709 1,763 1,613 1,600 All Permanent Modifications Started (000s) 1 Estimated Eligible Delinquent Borrowers2 1,750 2,520,402 All Trials Started (000s) HAMP Eligibility Eligible Delinquent Loans1 Monthly Trial Starts (Right Axis) 1,800 Total 100 Cumulative Trial Starts (Left Axis) New Trials Started (000s) 1,850 HAMP is designed to lower monthly mortgage payments to help struggling homeowners stay in their homes and prevent avoidable foreclosure. 900 857 800 763 700 600 608 634 670 699 791 883 910 933 951 817 731 500 400 Jan 2011 Feb Mar Source: HAMP system of record. Apr May June July Aug Sep Oct Nov Dec Jan 2012 2 Making Home Affordable: Summary Results Program Performance Report Through January 2012 Homeowner Benefits and First Lien Modification Characteristics • Aggregate savings to homeowners who received HAMP first lien permanent modifications are estimated to total approximately $11.0 billion, program to date, compared with unmodified mortgage obligations. • The primary hardship reasons for homeowners in active permanent modifications are: • 66.4% experienced loss of income (curtailment of income or unemployment) • 11.7% reported excessive obligation • 3.3% reported an illness of the principal borrower • The median monthly savings for borrowers in active permanent first lien modifications is $532.73, or 37% of the median monthly payment before modification. • Of trial modifications started, 80% 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: • 97.9% feature interest rate reductions • 59.3% offer term extension • 30.7% include principal forbearance Modifications by Investor Type (Large Servicers) GSE Private Portfolio Total Active Modifications 1,273 26,747 0 28,020 Bank of America, NA1 81,914 63,158 10,649 155,721 CitiMortgage, Inc. 31,977 5,632 17,073 54,682 GMAC Mortgage, LLC 25,086 5,919 11,783 42,788 JPMorgan Chase NA2 63,045 55,938 24,625 143,608 Ocwen Loan Servicing, LLC 3 6,820 36,650 124 43,594 OneWest Bank 15,028 15,650 2,677 33,355 Servicer American Home Mortgage Servicing, Inc. Saxon Mortgage Services, Inc. 1,407 10,008 1,941 13,356 520 15,947 2,518 18,985 Wells Fargo Bank, NA 4 52,411 15,635 47,258 115,304 Other HAMP Servicers 157,184 23,221 15,298 195,703 Total 436,665 274,505 133,946 845,116 Select Portfolio Servicing Select Median Characteristics of Active Permanent Modifications Before Modification After Modification Median Decrease Front-End Debt-to-Income Ratio1 45.3% 31.0% -14.4 pct pts Back-End Debt-to-Income Ratio2 76.8% 59.3% -14.7 pct pts $1,431.54 $828.62 -$532.73 Loan Characteristic Median Monthly Housing Payment3 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 Ocwen Loan Servicing, LLC includes Litton Loan Servicing LP. 4 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 January 2012 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 greater than 115% or 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. To encourage investors to consider or expand the use of principal reduction, Treasury issued program guidance on February 16, 2012 tripling financial incentives under PRA for investors who agree to reduce principal for eligible underwater homeowners. The new program guidance applies to all permanent modifications of non-GSE loans under HAMP that include PRA and have a trial period plan effective date on or after March 1, 2012. 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. 46% of non-GSE trial starts that were reported in January 2012 included principal reduction. To date, the 10 largest MHA servicers account for 98% 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 67,835 PRA Trial Modifications Active 16,213 All PRA Permanent Modifications Started 47,114 PRA Permanent Modifications Active $68,063 Median Principal Amount Reduced for Active Permanent Modifications (%)2 31.3% PRA Trials Started as a % of Non-GSE Trials Started by Month 50% 20% 10% 0% 14% 6% 20% 23% 28% 32% 32% 32% 32% All 1MP3 1MP with PRA - At least 60 days delinquent 80% 88% - Up to 59 days delinquent or current and in imminent default 20% 12% - California 25% 31% - Florida 12% 17% - Illinois 5% 6% Top three States’ Percent of Total 42% 54% Loan Characteristics Of trials started, delinquency at trial start: Top three States by Activity4, Percent of Total Activity: Active Permanent Modifications – Median Loan-to-Value (LTV) ratio: Total Outstanding Principal Balance Reduced on Active Permanent Modifications under PRA 30% Overall, homeowners receiving permanent loan modifications with the PRA feature also have a higher before-modification LTV ratio than those without the PRA feature. 44,058 Median Principal Amount Reduced for Active Permanent Modifications1 40% 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 homeowners. 36% - Before Modification 120% 159% - After Modification5 122% 115% $3,708,011,613 Active Permanent Modifications – Median before Modification Debt-to-Income (DTI) ratio: 46% 43% 45% 41% 42% 40% - Front-End DTI 45.3% 45.3% - Back-End DTI 76.8% 67.9% Under the PRA program, principal is vested over a 3 year period. The amounts noted reflect the entire amount that may be forgiven. 2 PRA amount as a percentage of before-modification UPB, excluding capitalization. 3 Includes HAMP first lien modifications with and without the PRA feature. 4 Figures reflect active trials and active permanent modifications. 5 Because the first step of the standard HAMP waterfall includes the capitalization of accrued interest, out-of-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 loan-to-value ratio can increase in the modification process. 1 4 Making Home Affordable: Summary Results Program Performance Report Through January 2012 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 modifications and partial extinguishments require that the first lien HAMP modification be permanent and active and that the second lien have an unpaid balance of $5,000 or more and a monthly payment of at least $100. 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 20% 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 49,443 HAFA Agreements Active 9,822 HAFA Transactions Completed 31,426 All Second Lien Modifications Started (Cumulative)1 65,708 Second Lien Modifications Involving Full Lien Extinguishments 14,142 Second Lien Modifications Disqualified2 1,762 Completed Transactions – Short Sale Active Second Lien Modifications3 49,804 Completed Transactions – Deed-in-Lieu Of the Active Second Lien Modifications: 30,583 843 1 Servicer Second Lien Partially Extinguished 2,160 Second Lien Loan Modifications4 47,644 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 Median Amount of Full Extinguishment $61,850 Median Amount of Partial Extinguishment for Active Second Lien Modifications $6,694 1 Includes second lien modifications reported into HAMP system of record through the end of cycle for January 2012 data, though the effective date may occur in February 2012. Number of modifications is net of cancellations, which are primarily due to servicer data corrections. 2 Includes 96 loans paid off. 3 Includes 2,144 loans in active non-payment status whereby the 1MP has disqualified from HAMP. As a result, the servicer is no longer required to report payment activity on the 2MP modification. 4Second 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 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 Dec. 2011) 18,403 UP Forbearance Plans With Some Payment Required 15,768 UP Forbearance Plans With No Payment Required 2,635 Note: Data is as reported by servicers via survey for UP participation through Dec. 31, 2011. The Treasury FHA-HAMP Program provides assistance to eligible homeowners with FHAinsured mortgages. All Treasury FHA-HAMP Trial Modifications Started 8,441 All Treasury FHA-HAMP Permanent Modifications Started 5,159 See Appendix A2 for servicer participants in additional Making Home Affordable programs. 5 Making Home Affordable: Summary Results Program Performance Report Through January 2012 HAMP Activity by State State % of U.S. State HAMP Active Permanent Trials Modifications Total1 Activity State Modification Activity by State % of U.S. Active Permanent State HAMP Trials Modifications Total1 Activity AK 43 332 375 0.0% MT 86 881 967 0.1% AL 490 4,224 4,714 0.6% NC 1,368 13,617 14,985 1.8% AR 172 1,664 1,836 0.2% ND 8 128 136 0.0% AZ 2,334 32,858 35,192 4.2% NE 103 1,006 1,109 0.1% CA 18,138 193,910 212,048 25.1% NH 337 3,479 3,816 0.5% CO 975 10,642 11,617 1.4% NJ 2,649 24,586 27,235 3.2% CT 1,040 9,475 10,515 1.2% NM 263 2,499 2,762 0.3% DC 128 1,317 1,445 0.2% NV 1,473 18,864 20,337 2.4% DE 223 2,310 2,533 0.3% NY 4,789 36,294 41,083 4.9% FL 9,796 92,432 102,228 12.1% OH 1,767 16,394 18,161 2.1% GA 2,869 27,623 30,492 3.6% OK 210 HI 285 2,914 3,199 0.4% OR 812 IA 170 1,883 2,053 0.2% PA 1,591 ID 244 2,982 3,226 0.4% RI 314 IL 3,829 40,763 44,592 5.3% SC IN 724 7,195 7,919 0.9% SD KS 180 1,794 1,974 0.2% TN 831 KY 266 2,829 3,095 0.4% TX 2,512 LA 520 4,200 4,720 0.6% UT 566 1,746 1,956 0.2% 8,405 9,217 1.1% 15,512 17,103 2.0% 3,880 4,194 0.5% 719 7,030 7,749 0.9% 31 273 304 0.0% 7,680 8,511 1.0% 19,924 22,436 2.7% 7,231 7,797 0.9% MA 1,949 18,568 20,517 2.4% VA 1,626 18,226 19,852 2.3% MD 2,356 24,398 26,754 3.2% VT 65 659 724 0.1% ME 231 2,125 2,356 0.3% WA 1,750 15,632 17,382 2.1% MI 2,002 24,380 26,382 3.1% WI 765 7,238 8,003 0.9% MN 934 12,734 13,668 1.6% WV 100 1,057 1,157 0.1% MO 772 7,689 8,461 1.0% WY 32 379 411 0.0% MS 263 2,735 2,998 0.4% Other2 643 2,177 2,820 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: 4th 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 January 2012 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 Miami-Fort Lauderdale-Pompano Beach, FL Chicago-Joliet-Naperville, IL-IN-WI MSA Riverside-San Bernardino-Ontario, CA Washington-Arlington-Alexandria, DC-VA-MD-WV Total MSA % of U.S. HAMP HAMP Activity Activity Active Trials Permanent Modifications 6,009 59,161 65,170 7.7% 5,881 48,873 54,754 6.5% 4,533 39,041 43,574 5.2% 3,723 39,576 43,299 5.1% 40,067 43,274 5.1% 2,264 26,049 28,313 3.4% 1,716 26,585 28,301 3.3% Atlanta-Sandy Springs-Marietta, GA 2,281 22,351 24,632 2.9% San Francisco-Oakland-Fremont, CA 1,731 16,300 18,031 2.1% Las Vegas-Paradise, NV 1,250 15,472 16,722 2.0% Detroit-Warren-Livonia, MI 1,225 14,784 16,009 1.9% 1,306 14,094 15,400 1.8% 1,340 14,051 15,391 1.8% 1,344 13,418 14,762 1.7% 1,154 13,202 14,356 1.7% Orlando-Kissimmee-Sanford, FL MSA San Diego-Carlsbad-San Marcos, CA Boston-Cambridge-Quincy, MA-NH Sacramento-Arden-Arcade-Roseville, CA January Total Number of Calls Taken at 1-888-995-HOPE 2,815,564 80,335 Borrowers Referred for Free Housing Counseling Assistance Through the Homeowner’s HOPETM Hotline 1,341,003 39,443 Source: Homeowner’s HOPETM Hotline. Numbers reflect calls that resulted in customer records. 3,207 Phoenix-Mesa-Glendale, AZ MSA Program to Date Selected Homeowner Outreach Measures Homeowner Outreach Events Hosted Nationally by Treasury and Partners (cumulative) Homeowners Attending Treasury-Sponsored Events (cumulative) 63 60,897 Servicer Solicitation of Borrowers (cumulative)1 8,212,279 Page views on MakingHomeAffordable.gov (January 2012) 3,328,363 Page views on MakingHomeAffordable.gov (cumulative) 137,406,910 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. The reduction is due to Wells Fargo Bank, NA restating the number of solicitation numbers from the previous month. 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 January 2012 Aged Trials1 200,000 190,412 The number of active trials lasting 6 months or longer is approximately 21,200. 165,543 Program guidance directs servicers to cancel or convert trial modifications after 3 or 4 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 27,345 26,362 25,390 23,552 23,014 23,061 19,793 18,359 20,332 21,002 21,211 0 May 2010 June July Aug Sept Oct Nov Dec Jan 2011 Feb March April May June July Aug Sep Oct Nov Dec Jan 2012 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, but not reported as such to the HAMP system of record. 8 Making Home Affordable: Servicer Results Program Performance Report Through January 2012 HAMP Modification Activity by Servicer As of Dec. 31, 2011 Cumulative As of Jan. 31, 2012 Estimated Eligible 60+ Day Delinquent Borrowers1 Trial Plan Offers Extended2 All HAMP Trials Started3 All HAMP Permanent Modifications Started3 Active Trial Modifications3 Active Trial Modifications Lasting 6 Months or Longer4 Active Permanent Modifications3 American Home Mortgage Servicing, Inc 35,016 43,309 39,432 31,777 2,751 189 25,269 Bank of America, NA5 165,223 531,361 380,925 174,624 16,936 12,443 138,785 CitiMortgage, Inc. 51,933 199,303 136,401 60,590 3,999 1,582 50,683 GMAC Mortgage, LLC 22,704 83,176 67,974 50,562 2,610 49 40,178 JPMorgan Chase Bank, NA6 133,076 350,910 307,072 155,666 17,970 2,339 125,638 Ocwen Loan Servicing, LLC7 67,803 95,889 90,152 53,785 5,145 1,213 38,449 OneWest Bank 31,551 76,397 59,132 35,004 3,587 224 29,768 Saxon Mortgage Services, Inc. 13,100 44,670 40,169 17,259 537 60 12,819 Select Portfolio Servicing 9,294 69,770 42,948 24,039 506 13 18,479 Servicer NA8 108,668 290,479 254,281 126,432 10,202 1,263 105,102 Other SPA servicers9 83,259 186,380 190,380 107,539 4,721 584 88,119 Other GSE Servicers10 163,283 NA 182,488 114,042 7,379 1,252 95,484 Total 884,910 1,971,644 1,791,354 951,319 76,343 21,211 768,773 Wells Fargo Bank, 1 Estimated eligible 60+ day delinquent borrowers as reported by servicers as of Dec. 31, 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. As reported in the monthly servicer survey of large SPA servicers through Jan. 31, 2012. The reduction is due to Wells Fargo Bank, NA restating the number of trial offers extended from the previous month. 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. 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, but not reported as such 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. 2 7 Ocwen Loan Servicing, LLC includes Litton Loan Servicing LP. Fargo Bank, NA includes all loans previously reported under Wachovia Mortgage, FSB. 9 Other SPA servicers are entities excluding the 10 largest servicers 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. 8 Wells 9 Making Home Affordable: Servicer Results Program Performance Report Through January 2012 Making Home Affordable Programs by Servicer1 Trials Started3 Permanent Modifications Started3 Trials Started3 Permanent Modifications Started3 Second Lien Modification (2MP) Second Lien Modifications Started4 American Home Mortgage Servicing, Inc. 39,432 31,777 0 0 Bank of America, NA6 380,925 174,624 14,643 CitiMortgage, Inc. 136,401 60,590 2,184 Principal Reduction Alternative (PRA)2 HAMP First Lien Modifications Servicer Home Affordable Foreclosure Alternatives (HAFA) Agreements Started5 Agreements Completed N/A 581 272 11,982 23,036 7,677 6,506 1,610 8,767 149 110 GMAC Mortgage, LLC 67,974 50,562 1,195 665 3,822 1,882 1,252 JPMorgan Chase Bank, NA7 307,072 155,666 15,957 9,369 15,261 19,956 11,776 Ocwen Loan Servicing, LLC8 90,152 53,785 12,649 8,130 N/A 1,770 925 OneWest Bank 59,132 35,004 3,578 2,248 1,771 1,592 713 Saxon Mortgage Services, Inc. 40,169 17,259 576 514 N/A 366 109 Select Portfolio Servicing 42,948 24,039 2 2 N/A 2,004 1,272 Wells Fargo Bank, NA9 254,281 126,432 15,733 11,494 10,817 10,944 6,580 Other Servicers 372,868 221,581 1,318 1,100 2,234 2,522 1,911 1,791,354 951,319 67,835 47,114 65,708 49,443 31,426 Total 1 MHA Program Effective Dates: HAMP First Lien: April 6, 2009 PRA: October 1, 2010 2MP: August 13, 2009 HAFA: April 5, 2010 2 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. 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. 4 See Appendix A1 and A2 for servicer participants in Making Home Affordable programs. N/A – Servicer does not participate in the program. 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 Ocwen Loan Servicing, LLC includes Litton Loan Servicing LP. 9 Wells Fargo Bank, NA includes all loans previously reported under Wachovia Mortgage, FSB. 10 Making Home Affordable: Servicer Results Program Performance Report Through January 2012 Servicer Outreach to 60+ Day Delinquent Homeowners: Cumulative Servicer Results, Jan. 2011 – Dec. 2011 Per program guidance, servicers are directed to establish Right Party Contact (RPC) with homeowners of delinquent HAMP eligible loans1 and then evaluate the homeowners' eligibility for HAMP. There is a range of performance results across top program servicers with respect to making RPC and completing the evaluations. 100% 97% 95% 92% 90% 93% 87% 85% 90% 87% 85% 80% 75% 70% 60% 50% 95% 40% 81% 76% 76% 61% 30% 79% 86% 68% 68% SPS Wells Fargo 59% 20% 10% 0% Am. Home Servicing 1 Homeowners Bank of America Citi GMAC JPMorgan Chase Right Party Contact Ratio2 Ocwen OneWest Saxon HAMP Evaluations Complete Ratio3 with HAMP eligible loans, which include conventional loans that were originated on or before Jan. 1, 2009 and were owner-occupied at origination; excludes FHA and VA loans, loans where investor pooling and servicing agreements preclude modification, and manufactured housing loans with title/chattel issues that exclude them from HAMP. 2 Right Party Contact (RPC) is achieved when a servicer has successfully communicated directly with the homeowner obligated under the mortgage about resolution of their delinquency in accordance with program guidelines. The RPC ratio reflects the share of homeowners with which the servicer has established RPC as a percent of HAMP eligible loans, excluding homeowners where RPC or HAMP evaluation is no longer needed. 3 HAMP evaluations complete ratio reflects the share of homeowners who have been evaluated for HAMP as a percent of HAMP eligible loans, excluding homeowners where RPC or HAMP evaluation is no longer needed. Evaluated homeowners include those offered a trial plan, those that are denied or did not accept a trial plan and homeowners that failed to submit a complete HAMP evaluation package by program-specified timelines. Source: Survey of 10 largest participating servicers as of December 31, 2011. 11 Making Home Affordable: Servicer Results Program Performance Report Through January 2012 Average Homeowner Delinquency at Trial Start1 Servicers are instructed to follow a series of steps in order to evaluate homeowners for HAMP, including: • Identifying and soliciting the homeowners in the early stages of delinquency; • Making reasonable efforts to establish contact with the homeowners; • Gathering required documentation once contact is established in order to evaluate the homeowners for a HAMP trial; and, • Communicating decisions to the homeowners. Effective 10/1/11, a new servicer compensation structure exists to encourage servicers to work with struggling homeowners in the early stages of delinquency with the highest incentives paid for permanent modifications completed when the homeowner is 120 days delinquent or less at the trial start. 250 Maximum servicer incentive is paid for converting a permanent modification that was 120 days delinquent or less at trial start. 200 150 100 50 0 Am. Home Servicing Bank of America Citi GMAC JPMorgan Chase Ocwen OneWest Saxon SPS Wells Fargo Other Servicers 1 For all permanent modifications started, the average number of days delinquent as of the trial plan start date. Delinquency is calculated as the number of days between the homeowner's last paid installment before the trial plan and the first payment due date of the trial plan. 12 Making Home Affordable: Servicer Results Program Performance Report Through January 2012 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 4.5 4 3 3.5 3.4 3.5 3.3 3.0 3.0 3.0 3.2 3.5 3.3 3.3 2 1 0 Am. Home Servicing Bank of America CitiMortgage Trials Started Before 6/1/10 GMAC JPMorgan Chase Ocwen Trials Started On/After 6/1/10 OneWest Saxon SPS Before 6/1/10 Average (5.3) Wells Fargo Other SPA Servicers Other GSE 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. 13 Making Home Affordable: Servicer Results Program Performance Report Through January 2012 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: 43% Converted to Permanent Modification 0.7% Pending Processing or Decision 100% 88% Of Eligible Trials Started On/After 6/1/10: 85% Converted to Permanent Modification 5.7% Pending Processing or Decision 84% 82% 80% Conversion Rate 84% 90% 83% 84% 80% 89% 87% 86% 82% 60% 40% 20% 0% Am. Home Servicing Bank of America CitiMortgage GMAC JPMorgan Chase Ocwen Average of Trials Started Before 6/1/10 (43%) OneWest Saxon SPS Wells Fargo Other SPA Servicers Other GSE Servicers Average of Trials Started On/After 6/1/10 (85%) 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. 14 Making Home Affordable: Servicer Results Program Performance Report Through January 2012 Homeowner Experience (10 Largest Servicers) Average Speed to Answer Homeowner Calls (December 2011) 60 Program to date, there have been 1,389,426 calls to the Homeowner’s HOPETM Hotline regarding a specific SPA servicer, of which 6.6% included complaints. Below shows specific complaint rates. Average Speed to Answer Calls to Homeowner’s HOPETM Hotline for December: 16.9 Seconds 50 Servicer Complaint Rate to Homeowner’s HOPETM Hotline (Program to Date, Through January) 11% 40 % of Calls for Specific Servicer Seconds 30 20 9% 8% 7% 6% 5% 10 0 Program to Date Average: 6.6% 10% 4% 3% Am. Home Servicing Bank of America CitiMortgage GMAC JPMorgan Chase Ocwen OneWest Saxon SPS Wells Fargo Am. Home Complaints Servicing (PTD): 2,727 Bank of America CitiMortgage GMAC JPMorgan Chase Ocwen OneWest Saxon 31,881 7,116 3,560 18,068 4,577 295 1,225 SPS 699 Wells Fargo 11,887 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, 9.6% included complaints.) Source: Survey data through December 31, 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 – Jan. 31, 2012) Call Abandon Rate (December 2011) 6% 60 Homeowner’s HOPETM Hotline Average Call Abandon Rate for December: 2.9% Target: 30 Calendar Days 50 Calendar Days 4% 2% 40 30 20 10 0 0% Am. Home Servicing Bank of America CitiMortgage GMAC JPMorgan Chase Ocwen OneWest Saxon SPS Source: Survey data through December 31, 2011, from servicers on call volume to loss mitigation lines; Homeowner’s HOPETM Hotline. Wells Fargo Am. Home Servicing Resolved Cases 759 Post-2/1/11 Bank of America CitiMortgage GMAC JPMorgan Chase Ocwen OneWest Saxon SPS Wells Fargo 10,856 1,184 695 4,301 1,254 927 292 172 2,987 Source: MHA Support Centers. GSE and Non-GSE escalations escalated on or after Feb. 1, 2011. Investor denial cases escalated prior to Nov.1, 2011, 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. 15 Making Home Affordable: Servicer Results Program Performance Report Through January 2012 Disposition Path Homeowners in Canceled HAMP Trial Modifications Survey Data Through December 2011 (10 Largest Servicers) Homeowners Whose HAMP Trial Modification Was Canceled Who Are in the Process of: Action Not Allowed – Action Bankruptcy Borrower Pending1 in Process Current Servicer American Home Mortgage Servicing, Inc. Total (As of Short Sale/ Alternative Payment Deed-in- Foreclosure Foreclosure December 2011) Modification Plan2 Loan Payoff Lieu Starts Completions 179 88 178 2,609 56 288 349 674 182 4,603 Bank of America, NA 14,273 7,087 18,943 69,752 1,787 5,025 17,453 25,501 23,791 183,612 CitiMortgage Inc. 1,660 5,922 6,235 29,792 2,011 4,773 5,541 5,599 9,574 71,107 GMAC Mortgage, LLC 1,944 423 969 5,484 101 542 1,156 1,715 1,981 14,315 JP Morgan Chase Bank NA4 7,036 3,022 21,299 45,635 288 1,451 11,962 19,820 10,867 121,380 Ocwen Loan Services LLC5 5,170 940 8,765 5,820 2,374 404 20 3,909 1,550 28,952 313 332 592 12,035 81 100 1,191 1,777 4,116 20,537 Saxon Mortgage Services, Inc. 2,146 923 3,071 2,362 360 476 871 4,190 3,926 18,325 Select Portfolio Servicing 1,120 371 1,224 5,551 277 449 1,314 1,389 3,659 15,354 Wells Fargo Bank NA6 3,168 822 11,217 51,336 878 24,070 2,681 16,715 7,014 117,901 37,009 6.2% 19,930 3.3% 72,493 12.2% 230,376 38.6% 8,213 1.4% 37,578 6.3% 42,538 7.1% 81,289 13.6% 66,660 11.2% 596,086 100.0% 3 OneWest Bank TOTAL (These 10 Largest Servicers) Note: Data is as reported by servicers for actions completed through December 31, 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 Ocwen Loan Servicing, LLC includes Litton Loan Servicing LP. 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 16 Making Home Affordable: Servicer Results Program Performance Report Through January 2012 Disposition Path Homeowners Not Accepted for HAMP Trial Modifications Survey Data Through December 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 December 2011) Modification Plan2 Loan Payoff Lieu Starts Completions American Home Mortgage Servicing, Inc. 2,527 1,569 13,771 40,994 1,558 2,353 2,824 9,734 2,158 77,488 Bank of America, NA3 33,449 16,074 92,517 149,517 8,333 11,100 40,386 66,128 50,840 468,344 CitiMortgage Inc. 10,723 13,093 19,723 55,446 7,171 17,688 16,103 15,731 18,013 173,691 GMAC Mortgage, LLC 27,365 6,069 37,386 37,190 1,591 5,877 9,689 16,793 16,298 158,258 JP Morgan Chase Bank NA4 39,436 12,498 159,777 123,041 2,066 39,589 46,265 69,764 22,948 515,384 Ocwen Loan Services LLC5 23,807 5,040 29,960 54,104 9,748 4,816 163 15,403 8,265 151,306 OneWest Bank 5,835 2,594 25,978 27,774 1,079 2,149 5,096 8,583 11,293 90,381 Saxon Mortgage Services, Inc. 4,483 1,395 6,029 7,698 597 1,101 584 5,633 3,012 30,532 Select Portfolio Servicing 2,440 444 2,932 5,391 370 385 1,321 1,599 2,070 16,952 Wells Fargo Bank NA6 15,368 5,210 49,929 52,198 1,641 32,182 15,684 24,265 15,827 212,304 165,433 8.7% 63,986 3.4% 438,002 23.1% 553,353 29.2% 34,154 1.8% 117,240 6.2% 138,115 7.3% 233,633 12.3% 150,724 8.0% 1,894,640 100.0% TOTAL (These 10 Largest Servicers) Note: Data is as reported by servicers for actions completed through December 31, 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 Ocwen Loan Servicing, LLC includes Litton Loan Servicing LP. 6 Wells Fargo Bank, NA includes all loans previously reported under Wachovia Mortgage, FSB. Note: Excludes loans removed from servicing portfolios. 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 17 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 the largest servicers participating in MHA. During the fourth quarter of 2011, Litton Loan Servicing, LP transferred its loan portfolio to Ocwen Loan Servicing, LLC. Therefore, there is no servicer assessment for Litton Loan Servicing, LP for this quarter nor will there be for future quarters. Subsequent servicer assessments will be published for the remaining largest servicers, who comprise the majority of MHA activity. 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. 18 (Continued on next page) 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 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 20 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. 19 MHA Servicer Assessment Overview 4th 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 Moderate Minor American Home Mortgage Servicing, Inc. Bank of America, NA CitiMortgage, Inc. GMAC Mortgage, LLC JPMorgan Chase Bank, NA Ocwen Loan Servicing, LLC Wells Fargo Bank, NA OneWest Bank Select Portfolio Servicing For the fourth quarter of 2011, Select Portfolio Servicing and OneWest Bank were determined to need minor improvement in their performance under MHA guidelines. American Home Mortgage Servicing, Inc., GMAC Mortgage, LLC, Ocwen Loan Servicing, LLC and Wells Fargo Bank, NA were determined to need moderate improvement and their performance for the fourth quarter approached the level required for a determination of minor improvement. CitiMortgage, Inc. was also found to need moderate improvement. Bank of America, NA was found to need moderate improvement and was found to have substantially remediated previously identified items. JPMorgan Chase Bank, NA was found to need moderate improvement for the fourth quarter and has made progress in remediating previously identified items. Treasury has agreed to release all currently withheld incentives as part of the proposed $25 billion settlement of mortgage servicing deficiencies between the five largest mortgage servicers, the Federal government, and 49 state attorneys general . Treasury continues to retain the right to withhold incentives in future periods. Please refer to the following MHA Servicer Assessment pages for further detail on the Fourth Quarter 2011 servicer assessment results. 20 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. Fourth 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 Did not meet benchmark; moderate improvement needed Met benchmark; minor improvement may be indicated 1.5% < 10% 0.0% - < 5% 1.0% - < 5% 3.0% - 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 Result American Home Mortgage Servicing, Inc. has areas requiring moderate improvement. After considering all relevant factors, American Home Mortgage Servicing, Inc. servicer incentives will not be withheld at this time. 21 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 1% 2% 4% Best Servicer Performance American Home Mortgage Servicing Inc. 19% 8% 6% 20% 40% 67% 60% 80% 0% American Home Mortgage Servicing Inc. 31 Worst Servicer Performance 40 60% 60 Sep. 2011 Dec. 2011 72% 79% 80% 100% 0.4% 0.2% 0.1% 3.4% 3.6% 3.7% Worst Servicer Performance 39 36 20 40% June 2011 0.0% 0.0% 0.0% American Home Mortgage Servicing Inc. 28 20% Results as of: Missing Modification Status Reports (%) Best Servicer Performance 9 8 0 62% Worst Servicer Performance Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance 85% 86% 88% American Home Mortgage Servicing Inc. 34% 35% Worst Servicer Performance 0% 88% 90% 90% Best Servicer Performance 0% 1% 2% 3% 4% Note: The best and worst performance reflect the best and worst result of the largest servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 and Q4 2011 only includes non-GSE cases escalated on or after 2/1/2011. 22 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. Fourth 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 Did not meet benchmark; moderate improvement needed Met benchmark; minor improvement may be indicated 1.0% < 10% 1.0% - < 5% 6.0% - < 5% 1.3% - 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 Bank of America, NA has areas requiring moderate improvement. Treasury has agreed to release Bank of America, NA withheld servicer incentives in connection with the proposed mortgage servicer settlement. 23 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 1% 2% 4% Best Servicer Performance 26% Bank of America, NA 35% 20% 40% 80% Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance 0% 32 29 Bank of America, NA Worst Servicer Performance 39 36 20 40 60 20% 40% 60% Results as of: June 2011 Sep. 2011 Dec. 2011 76% 81% 72% 79% 80% 100% Missing Modification Status Reports (%) 0.0% 0.0% 0.0% Best Servicer Performance 9 8 0 62% Worst Servicer Performance 67% 60% 62% Bank of America, NA 67% 34% 35% Worst Servicer Performance 0% 88% 90% 90% Best Servicer Performance Bank of America, NA 3.4% 3.6% 3.7% Worst Servicer Performance 3.4% 3.6% 3.7% 0% 1% 2% 3% 4% Note: The best and worst performance reflect the best and worst result of the largest servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 and Q4 2011 only includes non-GSE cases escalated on or after 2/1/2011. 24 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. Fourth 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 Did not meet benchmark; substantial improvement needed Did not meet benchmark; moderate improvement needed Met benchmark; minor improvement may be indicated 1.0% < 10% 1.0% - < 5% 3.0% - < 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 Benchmark Result CitiMortgage, Inc. has areas requiring moderate improvement. After considering all relevant factors, CitiMortgage, Inc. servicer incentives will not be withheld at this time. 25 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 Results as of: 1% 2% 4% Best Servicer Performance 34% 35% 43% CitiMortgage, Inc. 20% 40% 67% 60% 80% 0% 28 27 CitiMortgage, Inc. Worst Servicer Performance 40 40% 60% Dec. 2011 72% 79% 80% 0.9% 100% 2.3% 2.1% 3.4% 3.6% 3.7% Worst Servicer Performance 60 Sep. 2011 0.0% 0.0% 0.0% CitiMortgage, Inc. 39 36 20 20% June 2011 Missing Modification Status Reports (%) Best Servicer Performance 9 8 0 62% Worst Servicer Performance Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance 75% 81% 83% CitiMortgage, Inc. 34% 35% Worst Servicer Performance 0% 88% 90% 90% Best Servicer Performance 0% 1% 2% 3% 4% Note: The best and worst performance reflect the best and worst result of the largest servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 and Q4 2011 only includes non-GSE cases escalated on or after 2/1/2011. 26 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. Fourth 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 Did not meet benchmark; moderate improvement needed Met benchmark; minor improvement may be indicated 0.5% < 10% 0.0% - < 5% 6.5% - < 5% 2.1% - 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 Result GMAC Mortgage, LLC has areas requiring moderate improvement. After considering all relevant factors, GMAC Mortgage, LLC servicer incentives will not be withheld at this time. 27 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 1% 2% 4% Best Servicer Performance GMAC Mortgage, LLC 1% 2% 4% GMAC Mortgage, LLC 34% 35% Worst Servicer Performance 0% 20% 40% 80% Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance 12 12 0% 40 40% 60% 60 Sep. 2011 Dec. 2011 72% 79% 80% 100% 0.0% 0.0% 0.0% 0.1% 0.1% 0.1% 3.4% 3.6% 3.7% Worst Servicer Performance 39 36 20 20% June 2011 Missing Modification Status Reports (%) GMAC Mortgage, LLC Worst Servicer Performance 0 62% Best Servicer Performance 9 8 GMAC Mortgage, LLC 80% 84% 84% Worst Servicer Performance 67% 60% 88% 90% 90% 0% 1% 2% 3% 4% Note: The best and worst performance reflect the best and worst result of the largest servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 and Q4 2011 only includes non-GSE cases escalated on or after 2/1/2011. 28 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. Fourth 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 Did not meet benchmark; moderate improvement needed Met benchmark; minor improvement may be indicated 0.7% < 10% 1.0% - < 5% 10.0% - < 5% 3.8% - 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 JPMorgan Chase Bank, NA has areas requiring moderate improvement. Treasury has agreed to release JPMorgan Chase Bank, NA withheld servicer incentives in connection with the proposed mortgage servicer settlement. 29 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: 1% 2% 4% Best Servicer Performance 17% 23% 13% JPMorgan Chase Bank, NA 20% 40% 67% 60% 62% Worst Servicer Performance 80% Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance 66% 72% JPMorgan Chase Bank, NA 34% 35% Worst Servicer Performance 0% 88% 90% 90% Best Servicer Performance 0% JPMorgan Chase Bank, NA 39 36 JPMorgan Chase Bank, NA Worst Servicer Performance 39 36 Worst Servicer Performance 0 20 40 60 40% 60% Sep. 2011 Dec. 2011 83% 72% 79% 80% 100% Missing Modification Status Reports (%) 0.0% 0.0% 0.0% Best Servicer Performance 9 8 20% June 2011 0.5% 0.2% 0.2% 3.4% 3.6% 3.7% 0% 1% 2% 3% 4% Note: The best and worst performance reflect the best and worst result of the largest servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 and Q4 2011 only includes non-GSE cases escalated on or 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. Fourth 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 Did not meet benchmark; moderate improvement needed Met benchmark; minor improvement may be indicated 0.7% < 10% 0.0% - < 5% 2.0% - < 5% 0.2% - 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 Ocwen Loan Servicing, LLC has areas requiring moderate improvement. After considering all relevant factors, Ocwen Loan Servicing, LLC servicer incentives will not be withheld at this time. 31 MHA Servicer Assessment: Ocwen Loan Servicing, LLC1 Program Results Conversion Rate for Trials Started On or After 6/1/2010 Aged Trials as a Percentage of Active Trials Results as of: 1% 2% 4% Best Servicer Performance 18% 13% 21% Ocwen Loan Servicing, LLC 20% 40% 67% 60% 80% Average Calendar Days to Resolve Escalated Cases2 Best Servicer Performance 11 11 40 40% 60% 72% 79% 80% 60 100% 0.0% 0.0% 0.0% 0.5% 0.5% 0.5% 3.4% 3.6% 3.7% Worst Servicer Performance 39 36 20 20% Sep. 2011 Missing Modification Status Reports (%) Ocwen Loan Servicing, LLC Worst Servicer Performance 0 0% Best Servicer Performance 9 8 Ocwen Loan Servicing, LLC 62% Worst Servicer Performance June 2011 Dec. 2011 79% 82% 79% Ocwen Loan Servicing, LLC 34% 35% Worst Servicer Performance 0% 88% 90% 90% Best Servicer Performance 0% 1% 2% 3% 4% Note: The best and worst performance reflect the best and worst result of the largest servicers for the period. See appendix for descriptions of the metrics. 1Beginning in Q4 2011, Litton Loan Servicing, LP is reported with Ocwen Loan Servicing, LLC on a consolidated basis. 2The population in Q3 and Q4 2011 only includes non-GSE cases escalated on or 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. Fourth 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 0.0% < 10% 0.0% - < 5% 0.0% - < 5% 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 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: 1% 2% 4% Best Servicer Performance 6% 5% 10% OneWest Bank 34% 35% 20% 40% 67% 60% 80% Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance 9 8 19 17 OneWest Bank Worst Servicer Performance 20 40 0% 20% 40% 60% 60 Sep. 2011 72% 79% 80% 100% Missing Modification Status Reports (%) Best Servicer Performance 0.0% 0.0% 0.0% OneWest Bank 0.0% 0.0% 0.0% 3.4% 3.6% 3.7% Worst Servicer Performance 39 36 0 62% Worst Servicer Performance June 2011 Dec. 2011 79% 77% 82% OneWest Bank Worst Servicer Performance 0% 88% 90% 90% Best Servicer Performance 0% 1% 2% 3% 4% Note: The best and worst performance reflect the best and worst result of the largest servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 and Q4 2011 only includes non-GSE cases escalated on or 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. Fourth 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 0.0% < 10% 0.0% - < 5% 1.0% - < 5% 0.2% - 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: 1% 2% 4% Best Servicer Performance 5% 5% 4% Select Portfolio Servicing 34% 35% Worst Servicer Performance 0% 20% 40% 88% 90% 90% Select Portfolio Servicing 88% 90% 90% 62% Worst Servicer Performance 67% 60% Best Servicer Performance 80% Average Calendar Days to Resolve Escalated Cases1 0% 9 8 Best Servicer Performance Select Portfolio Servicing 9 8 Select Portfolio Servicing 20 40 60% 60 Dec. 2011 72% 79% 80% 100% 0.0% 0.0% 0.0% 0.0% 0.1% 0.0% 3.4% 3.6% 3.7% Worst Servicer Performance 39 36 0 40% Sep. 2011 Missing Modification Status Reports (%) Best Servicer Performance Worst Servicer Performance 20% June 2011 0% 1% 2% 3% 4% Note: The best and worst performance reflect the best and worst result of the largest servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 and Q4 2011 only includes non-GSE cases escalated on or 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. Fourth 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% 4.0% - < 5% 0.8% - 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 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: 1% 2% 4% Best Servicer Performance 11% 12% 14% Wells Fargo Bank, NA 34% 35% 20% 40% 67% 60% 80% 0% 25 24 Wells Fargo Bank, NA Worst Servicer Performance 40 40% 60% Dec. 2011 72% 79% 80% 100% 0.3% 0.5% 0.2% 3.4% 3.6% 3.7% Worst Servicer Performance 60 Sep. 2011 0.0% 0.0% 0.0% Wells Fargo Bank, NA 39 36 20 20% June 2011 Missing Modification Status Reports (%) Best Servicer Performance 9 8 0 62% Worst Servicer Performance Average Calendar Days to Resolve Escalated Cases1 Best Servicer Performance 84% 88% 89% Wells Fargo Bank, NA Worst Servicer Performance 0% 88% 90% 90% Best Servicer Performance 0% 1% 2% 3% 4% Note: The best and worst performance reflect the best and worst result of the largest servicers for the period. See appendix for descriptions of the metrics. 1The population in Q3 and Q4 2011 only includes non-GSE cases escalated on or 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 to only include non-GSE cases escalated on or after 2/1/2011. The Q4 2011 figures exclude investor denial cases escalated prior to 11/1/2011; Q3 figures exclude all investor denial cases. Cases involving bankruptcy and those 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 January 2012 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 Home Mortgage Servicing, Inc AMS Servicing, LLC Aurora Loan Services, LLC Bank of America, N.A.1 Bank United 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 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. 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, LLC3 OneWest Bank ORNL Federal Credit Union Park View Federal Savings Bank Pathfinder Bank PennyMac Loan Services, LLC PNC Bank, National Association PNC Mortgage4 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, NA5 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 Ocwen Loan Servicing, LLC includes Litton Loan Servicing LP. 4 Formerly National City Bank. 5 Wells Fargo Bank, NA includes all loans previously reported under Wachovia Mortgage, FSB. 40 Making Home Affordable Program Performance Report Through January 2012 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