Rationale

S&P Global Ratings' ranking on Fay Servicing LLC (Fay) is AVERAGE as a residential mortgage loan special servicer. On March 4, 2021, we affirmed the ranking (please see "Fay Servicing LLC AVERAGE Residential Special Servicer Ranking Affirmed; Outlook Stable," published March 4, 2021). The outlook on the ranking is stable.

Our ranking reflects:

• An executive and senior management team that exhibits good industry experience levels;
• Continued investment in personnel and infrastructure commensurate with portfolio growth;
• An internal control framework with multiple lines of oversight that continues to season along with its developing internal audit program;
• Capable technology systems that provide a level of automation to support the servicing operations of its size that is consistent with similarly ranked peers;
• Well-controlled core loan administration practices; and
• Demonstrated capability to resolve defaults for private investor portfolios, which is supported by its high-touch approach.

Furthermore, Fay continues to invest in technology and servicing operational infrastructure to support its growing portfolio. Many of these enhancements provide efficiencies and foundational controls that we believe are beneficial to service a larger portfolio in a controlled manner. This comes in what is an increasingly complex servicing environment and considerably heightened regulatory scrutiny, notably around distressed borrowers. While the technology and infrastructure investments somewhat mitigate this risk, many of these are common amongst our similarly ranked servicers with like sized or larger portfolios.

Fay maintains a disaster recovery and business continuity plan, including response procedures to address operational disruption as a result of a pandemic event. It implemented its plan due to the COVID-19 pandemic. Management reported that there were no material disruptions to the company's operations or data facilities.

Since our prior review (see "Servicer Evaluation: Fay Servicing LLC," published June 20, 2018), the following changes and/or developments have occurred:

• Fay made strategic organizational changes promoting a senior leader to president and head of servicing, and shifted related support areas such as compliance and human resources closer to the servicing organization.
• Fay hired a new chief information officer, senior vice president of loan administration, and senior vice president of account management.
• The former corporate controller transitioned to lead the internal audit team in 2019.
• An internal cyber security committee was established, and it insourced its internal chief information security officer.
• Fay implemented annual risk and control reviews.
• Fay began using a vendor-based quality management software for quality control (QC) testing.
• Fay engaged an offshore vendor to co-source handling customer service calls.
• Fay outsourced loss draft administration to a third-party provider.
• Fay implemented separate vendor-based systems for loss mitigation workflow and underwriting, as well as managing real estate-owned (REO) assets.

The outlook on the ranking is stable. While the special servicing portfolio has remained relatively flat, Fay's overall servicing portfolio has continued to grow at a moderate pace. With the current growth strategy, we believe that the organizational changes, increasing the management team's depth with good experience, and technology platform investments should continue to provide a stable mortgage servicing operation. We will monitor servicer performance over the next surveillance period.

In addition to conducting a virtual meeting with servicing management, our review includes current and historical Servicer Evaluation Analytical Methodology data through Dec. 31, 2020, as well as other supporting documentation provided by the company.

Profile

Fay was founded in 2008 and operates as a wholly owned subsidiary of Fay Management LLC, which is owned by Fay Financial LLC. It is primarily a third-party servicer of distressed residential loans (non-performing and re-performing loans) in addition to non-qualified mortgage (non-QM) loans. It also services business purpose loans, which are outside of the scope of our analysis and this report.

Its servicing model is centered on its single point of contact (SPOC) approach that provides high-touch servicing. It is an approved Fannie Mae, Freddie Mac, and Housing and Urban Development (HUD) servicer as well as an approved Ginnie Mae issuer.

Inclusive of the special servicing portfolio, Fay services approximately 88,000 residential loans. Performing and seasoned re-performing loans represent a growing share of the overall portfolio, as the non-performing loan market has dwindled in recent years. However, we believe that the economic effects from the COVID-19 pandemic may lead to more non-performing loans over time and serve as a tailwind for growth in the special servicing portfolio (see "Servicer Evaluation Spotlight Report: Are Special Servicers Poised For A "Prime" Comeback Due To COVID-19?," published June 8, 2020).

Table 1

Table 2

Management And Organization

The management and organization subranking is AVERAGE for residential mortgage special servicing.

Organizational structure, staff, and turnover

Fay's servicing operations are aligned under the president of servicing who, along with leaders of key support functions such as compliance, people management, and IT, reports to the president of Fay Financial. We believe the structure effectively addresses operational needs.

The senior management team exhibits satisfactory levels of industry experience with an adequate company tenure average that is largely reflective of the company's continued growth. We consider the overall staff turnover to be manageable. Industry experience, company tenure, and turnover levels in our analysis, are as follows:

• Senior managers average 19 years' industry experience and four years' company tenure, which are lower than its peer averages.
• Middle managers average four years' company tenure. The company did not report middle managers' average length of experience.
• Management turnover is 11% annualized, which is similar to the peer average.
• The 6% overall staff turnover, a significant improvement from the first half of 2020, compares favorably to peers.

In our last review, we noted that Fay added several senior leaders (some in newly created roles) in 2016 and 2017 as the servicing portfolio expanded. Since that time, Fay continued to add or promote senior leaders with good industry experience as it positions the organization for further growth. In particular, Fay hired a new chief information officer and new senior vice president of loan administration, and promoted a new head of servicing and a new chief people officer.

Training

Fay provides its new hires and existing management and staff with a diversified range of internal and external training programs that incorporate various formats (e.g., classroom, computer-based, and on-the-job instruction). Key training factors we considered in our analysis include the following:

• A learning management system pushes required training modules to employees and tracks completion of required courses.
• Dedicated trainers, based in Chicago, travel to various sites to facilitate training as needed.
• Servicing employees complete annually a comprehensive compliance refresher training.
• New account managers (Fay's primary customer-contact role) complete a three-week account manager academy.
• Fay also provides additional ongoing training, such as formal training for new managers and a program for high-performing employees.

Systems and technology

Fay has effective technology in place to support its special servicing portfolios. Its technology group, with support from a vendor, manages and maintains the technology for all mortgage-related functions. The company continues to invest in projects to further build out its infrastructure and systems to support platform growth. In our view, it has well-designed data backup routines and adequate disaster recovery preparedness.

Servicing system applications 

The company uses a combination of vendor and proprietary systems. Key systems and functionality include:

• Black Knight's MSP® as its servicing system;
• Its customer website, which provides loan information and self-service options such as payments and payoff statement requests;
• A proprietary account manager portal as the user interface and case management system for customer-facing account managers;
• A foreclosure and bankruptcy management workflow system; and
• Separate vendor-hosted systems for loss mitigation workflow and underwriting and REO asset management.

Business continuity and disaster recovery 

Fay maintains a business continuity plan (BCP) and disaster recovery procedures to mitigate business disruption, including response procedures to address operational disruption as a result of a pandemic event. Its BCP is managed within a management system, which, in our view, provides a level of structure and rigor around plan maintenance, including documenting appropriate recovery needs. A disaster recovery test was most recently performed in November 2020, and no material issues were reported.

There was no BCP test exercise in 2019 due to a transition to a new BCP methodology, and Fay implemented its BCP in 2020 due to the COVID-19 pandemic. Management reported that there were no material disruptions to the company's operations or data facilities. Although the company exercised its BCP in response to the COVID-19 pandemic, we commonly see BCP testing at least annually among similarly ranked servicers. Notable components we considered in our analysis include the following:

• Employees use virtualized desktops.
• Many of Fay's servicing functions are redundant between multiple site locations.
• Its primary and back-up data centers are geographically dispersed.
• Fay utilizes data replication and tape backups as part of its disaster recovery program.
• Recovery time objectives are satisfactory for its designated critical systems.

Cybersecurity 

Fay's information and cybersecurity program includes practices and tools to manage cybersecurity risks including the following:

• Intrusion detection systems and annual third-party penetration testing are in place to monitor for threats and detect vulnerabilities.
• An email security system monitors for data loss prevention.
• Weekly vulnerability scans are performed internally and semiannual vulnerability assessments are performed by an independent party.
• Fay has industry-standard virus and malware detection systems and firewalls.
• Fay conducts an annual tabletop exercise of its incident response plan using simulated threat scenarios.
• Fay carries out cyber awareness activities geared toward employees, such as annual training and phishing tests.

Internal controls

Fay's risk management and compliance framework has multiple lines of monitoring and testing to detect risk. A dedicated team monitors corrective actions for identified open issues and a centralized business controls team liaises between business units and control groups, allowing the business units to focus on operations. Performance, trends, and issues are appropriately reported to management teams. The executive team also meets monthly to review control issues and other risk indicators such as compliant trends.

Policies and procedures 

Policies and procedures (P&Ps) governance practices are satisfactory in our view. P&Ps are managed in a centralized system, which provides a level of control that tracks versioning, changes, and periodic reviews. Procedures are certified at least annually, and new P&Ps or changes to existing P&Ps require compliance and legal review.

Quality assurance (and call monitoring) 

Fay's first line of defense incorporates quality assurance measures such as in-line reviews of key servicing processes, exception reporting, and call monitoring. A dedicated quality assurance team performs in-line reviews of a sample of key servicing processes. The testing is well organized and structured. The monthly results and trends are reported to the senior leadership, compliance, and internal audit teams.

An outsourced vendor team is responsible for monitoring customer-facing staff's calls. Fay uses a call-monitoring application and a standard set of evaluation questions to grade each call.

Compliance and quality control (QC) 

The compliance area oversees regulatory change management, provides advisory support to the business units, and monitors compliance with regulatory and investor requirements. The change management framework includes resources to identify, communicate, and oversee business units as they execute required changes. Changes are tiered based on complexity, and high-complexity projects are assigned to the project management office. A designated business controls team works with the business units to help manage change projects and business processes.

The department monitors compliance through its formal QC testing program and conducts targeted reviews of high-risk processes for difficult-to-test risks. Beginning in 2020, a process was added to review key risks and associated controls, which will identify and address control gaps.

The QC team performs transactional testing to ensure compliance with regulatory and investor requirements. Performance is appropriately reported to other lines of defense and senior management. Key factors we considered include the following:

• The QC team is independent of the servicing organization.
• Servicing functions are tested monthly.
• Issues are tracked by a dedicated issues management team for corrective action.
• Key issues are reported at the monthly compliance committee to the senior leadership team, and quarterly to the board of directors.
• Fay transitioned its transactional QC testing to an industry-recognized QC software system.
• QC testing was augmented to include applicable components of the CARES Act.

Internal and external audits 

Fay's third line of defense is its independent internal audit department. In mid-2019, a senior employee was promoted to lead the department, and reports to the board of directors' audit committee. Fay also employs third-party vendors to handle some field work and audits that require specialized expertise.

In our view, the internal audit program continues to evolve, including the following developments:

• The program operates on a three-year audit plan that is adjusted based on the company's annual risk assessment, which includes a targeted audit of high-risk areas every 12 to 18 months.
• Internal audit reports were augmented in 2019 to include more information and formality. Specifically, an audit rating framework was introduced, which is a component that, along with the more formalized report structure, is more in line with what we typically see amongst our ranked servicers.
• Identified audit issues are tracked in the compliance issue tracking system.

We reviewed audit reports completed in 2019 and 2020. We note that Fay did not complete its audit plan for 2020 due to capacity constraints, among other factors, which we view as a risk. The audits we reviewed revealed no findings that we consider to be material. We believe the audit reports are appropriately communicated to the senior leadership and the board's audit committee. We also reviewed the 2019 Regulation AB, Uniform Single Attestation Program, and Service Organization Controls reports. No material instances of non-compliance or exceptions were identified.

Complaint management

A complaint resolution team handles the research for, and responses to, customer complaints. The complaints and response timelines are tracked in the servicing system, and complaint data and trends are reported to the executive team weekly. As a QC mechanism, the quality assurance and QC teams review a sample of responses. In addition, responses to regulatory complaints are reviewed by legal before they are delivered. Fay reported resolving customer inquiries in an average of 24 days and resolving regulatory inquiries within 12 days, which both are generally in line with the peer averages.

Vendor management

Key vendor management practices we factored into our analysis include:

• A centralized team to evaluate and procure new vendors with dedicated staff for vendor performance oversight and default attorney oversight;
• A due diligence review and risk assessment for prospective vendors;
• Monthly scorecards to monitor performance against service-level agreements;
• A periodic questionnaire-based audit on an 18- to 36-month cycle depending on risk tier;
• Onsite reviews as needed determined by questionnaire responses; and
• A vendor management team to maintain scorecard records and oversee the remediation process if needed.

Since our last review, Fay has updated its vendor management framework to perform onsite reviews on an as-needed basis depending on its review of questionnaire responses. Prior to this change, Fay conducted onsite reviews for high-risk-tier vendors. The questionnaire is comprehensive in our view; however, the determination to conduct onsite reviews on an as-needed basis is more subjective than we typically see among our ranked servicers. In addition, we typically see periodic onsite reviews for high-risk-rated vendors at similarly ranked servicers.

Insurance and legal proceedings

Fay has represented that its directors and officers as well as its errors and omissions insurance coverage is in line with the requirements of its portfolio size.

Fay entered into a consent order on June 6, 2017, with the Consumer Financial Protection Bureau related to certain loss mitigation and foreclosure dual tracking practices. The enforcement action included a $1.15 million redress to certain affected customers. No civil money penalty was assessed. It also included a requirement to send solicitations offering loss mitigation to affected customers and to enhance P&Ps in connection with its servicing practices to ensure compliance with regulatory requirements. The company indicated that to date, it has timely complied with all required submissions under the consent order.

Loan Administration--Special

The loan administration subranking is AVERAGE for residential mortgage special servicing.

New-loan boarding

Fay utilizes a project plan approach along with Black Knight's loan boarding application to board loans to its system. All loans are boarded electronically, thus mitigating the risk of data input error. The company reported that it boards loans in three days. Fay sends a personalized welcome card in addition to calling borrowers after boarding their loan to its system. We considered the following factors and control activities in our analysis:

• Fay has experience with boarding bulk transactions of seasoned loans.
• Fay runs data validation and error detection routines on preliminary loan data to identify and reconcile issues before boarding.
• A property tax search is completed for all newly boarded loans.
• Fay compares system-to-document terms for adjustable-rate loans and modified loans.
• Fay uses optical character recognition technology to inventory and index loan documents to its imaging system.

Payment processing

Fay has satisfactory cash management procedures and controls, with secured areas at its designated sites to handle payments. It provides borrowers with multiple payment options, including scheduled biweekly drafts, which we believe has the potential to increase the likelihood of collection. The vast majority (86%) of payments are processed electronically or through its lockbox, which is better than the peer average. We considered the following key metrics, processes, and controls in our analysis:

• A system-based suspense sweep process automatically posts suspense funds when loan conditions allow.
• Payment processing teams are located at two servicing sites, mitigating business disruption risk.
• Suspense funds are monitored daily through reporting.
• A dedicated staff posts bankruptcy funds.
• Fay's website handles 23% of payments, which is an increase over the prior year.
• Turnover in the cash management area was 17%, which increased from our prior review and is elevated compared to peers.

Investor reporting

Fay has dedicated staff members for the investor reporting, remitting, and reconciling functions, which demonstrates appropriate separation of those activities. It has specialized agency and private investor reporting teams, and the management team has good experience with agency and private investor reporting. Controls and metrics we considered in our analysis include:

• Reporting and remittances are 100% electronic.
• Clearing accounts are reconciled daily. Custodial accounts are reconciled monthly.
• The accounting team verifies servicing fee calculations against servicing agreements.
• Dual signoff is required for wire transfers.
• Fay reported no open reconciliation items aged 60 or more days.

Table 3

Escrow administration

Fay uses separate industry-recognized tax and insurance vendors to monitor and disburse funds for tax and insurance lines. During 2018, it transitioned its tax administration to a new vendor. It also transitioned the loss draft administration, which was previously done internally, to its insurance vendor during 2020. Outsourcing loss draft administration is common among servicers that we rank. An internal escrow team performs oversight of the vendor as well as the escrow analysis process.

Our analysis of escrow processes, metrics, and controls considered the following:

• There were no non-reimbursable tax penalties for the period, which compares favorably to peers.
• There are internal resources to oversee vendor performance.
• The insurance vendor monitors coverage for non-escrowed loans.
• A backward search of the three prior years was conducted for newly boarded loans, which we view as a positive for special servicing non-performing loans.
• Fay reviewed borrower calls and calibration meetings with the insurance vendor to ensure calls were handled and evaluated as expected.
• Internal escrow staff turnover was 12.5%, which we consider manageable.
• Fay monitors loans that may be eligible for private mortgage insurance termination.
• Fay handles tax and insurance-related calls internally.
• Escrow shortages may be spread, based on a matrix, to minimize payment increase shock due to escrow shortages.

Mortgage reconveyance

The company reported 2.6% of lien releases completed out of statutory compliance, which is higher compared to the peer average. It has not incurred any reconveyance penalties.

Special loans administration

For adjustable-rate loans (ARM), there is a dual verification process to confirm that the indices are correctly input into the system. For loans affected by the Servicemember's Civil Relief Act, there are multiple reviews performed before foreclosure referral/sale to confirm the borrower is not affected by these regulations. Fay also indicated that it established an internal committee and project management team to oversee the transition from London Interbank Reference Rate (LIBOR) to a replacement index for those ARM loans referencing LIBOR as its index rate.

Customer service

Fay maintains processes, training, and infrastructure to address customer service requests. Its website and interactive voice response unit provide self-service functionality to handle common service requests such as one-time payments, payoff statement requests, and provide loan-level information.

Fay continues to build out a more traditional customer service model with a team, initially established in 2017, to handle inbound calls for performing loans. The team manages the higher volume of customer service-centric calls that typically come with a performing loan portfolio. Fay also engaged an offshore vendor to take an increasing percentage of the calls. With its growing portfolio of performing loans, the company also expanded its combined customer service team by roughly 40% between June 30, 2019, and Dec. 31, 2020. Customer service controls and metrics we considered in our analysis include the following:

• A customer survey is used to monitor and measure the customer experience.
• Fay reported that it does not track the percentage of borrowers that are registered to use its website, which is a commonly reported metric amongst our ranked servicers.
• The average speed of answer (ASA) is 62 seconds. The abandonment rate is 3.56%. We consider the call metrics to be satisfactory.
• A minimum of 10 calls are monitored monthly, which is in line with peers, as well as three emails and voicemails monitored monthly for each account manager.

Default management

Fay primarily focuses on servicing distressed or seasoned re-performing assets for private clients, which is reflected in many of its default practices. The company deploys strategies to engage borrowers, and it offers a broad menu of solutions to cure defaults and mitigate loss (see table 6). It designs calling strategies based on prior payment patterns and investor requirements. Once the loan becomes 60 or more days delinquent, or a request for loss mitigation is received, the assigned account manager (SPOC) handles all borrower contact. Once contact is made, the SPOC utilizes a budget analysis tool to evaluate and model loss mitigation solutions.

Fay's strategies to establish contact and build rapport with borrowers benefits its ability to provide solutions to resolve delinquencies and mitigate loss. In addition, Fay's SPOC compensation structure incentivizes staff to provide sustainable loss mitigation alternatives based on borrower affordability. The inclusion of slippage rates is a factor that we do not commonly see in the marketplace.

Delinquency rates for the special servicing portfolio have increased compared to the prior period.

Table 4

Fay does not track industry experience for collectors or collections management; however, using company tenure as a proxy, collections management and collectors exhibit at least adequate levels of industry experience. Management and staff of other default areas have generally solid experience levels. Except for foreclosure management, the industry experience averages are largely competitive with peers.

Table 5

Collections

Fay uses a dialer system in conjunction with manual calling to contact borrowers. The dialer is used largely for early stage collection activity as it provides scale. Fay also implemented a new dialer platform in mid-2020, which helps provide additional workforce management functionality.

Fay utilizes a system to identify and prioritize loans for account managers to call borrowers. This system incorporates event triggers and data, such as payment history and credit scores. It also has built-in controls to manage compliance with federal and state-level calling restrictions. Key collection strategies, metrics, and controls we factor in our analysis include the following:

• Normal collection hours of operation include traditional prime-time hours and weekend calling.
• Account managers mail out a welcome card with a direct contact number.
• Combined manual and dialer calls increased contact rates.
• The account manager portal provides a controlled system to queue outbound calls for account managers.
• Fay reported promise-to-pay success rates for its 30-day-delinquent and 60-day-delinquent loan buckets of 84% and 81%, respectively, which we consider solid.
• A minimum of 10 calls are monitored per month for each agent, which is similar to the peer average.
• Credit scores are updated quarterly, allowing Fay to update calling models based on borrower changes.
• The abandonment and ASA rates for collection calls are 3.56% and 62 seconds, respectively, which we consider good considering the increased call volume as a result of the COVID-19 pandemic.

Loss mitigation

The loss mitigation structure comprises account managers to handle borrower communication, underwriters, and a borrower assistance team to manage gathering and reviewing loss mitigation application documents. This specialization allows a dedicated team to handle loss mitigation application complexities, underwriters to focus on solutions, and the account manager to handle communication with the borrower. Fay transitioned to BackInTheBlack (BITB) for loss mitigation workflow, and is in the process of migrating evaluation and underwriting for all investor types to BITB. The new system also provides document upload capabilities via the web portal, which is an enhancement since our last review and a feature we commonly see across similarly and higher ranked servicers. Factors and controls considered in our evaluation include the following:

• Fay has experience with streamlined modifications and customizing loss mitigation waterfalls based on investor requirements.
• Cash for keys is utilized as an incentive for short sale and deed-in-lieu workouts.
• As a proactive approach, account managers are engaged in the short sale process by helping borrowers locate real estate agents when needed, and they actively monitor the listing as part of their pipeline.
• Fay has an internally developed modification underwriting tool, which management indicated is appropriately controlled.
• There is a quality assurance review of all loss mitigation application documents received, and an in-line review of 80% of income calculations.
• Fay performs a quality assurance review on all modification approvals and denials.
• Fay reviews all modification agreements for accuracy before they are mailed to ensure the agreement's terms match the approved terms.
• Automation is used to update modified loan terms to the servicing system. Additionally, there is a quality assurance review to confirm that the system is consistent with the modification agreement's terms.

Table 6

Foreclosure and bankruptcy

Fay uses Black Knight's LoanSphere system to track foreclosure proceedings and communicate with attorneys. Its foreclosure department performs various reviews before initiating foreclosure and before a foreclosure sale to confirm it is in compliance with regulatory requirements. Management indicated it updated its procedures and reporting to account for state and federal foreclosure moratoriums stemming from the COVID-19 pandemic. Controls and procedures factored into our assessment include the following:

• Automated reports are used to identify loans potentially eligible to start foreclosure as well as monitor key service levels of its foreclosure pipeline.
• A checklist followed by a secondary review must be completed before initiating foreclosure.
• The decision to proceed with a foreclosure sale is determined by a committee.
• There is a centralized document execution team, which benefits from recurring training.
• The quality assurance team performs in-line reviews of key processes on a sample of the population.
• In 2019, Fay implemented a data-to-document audit to verify critical data fields for its foreclosure referral package.
• An in-line review of all foreclosure bids is conducted prior to communicating the amount to the attorney.
• A dedicated property preservation team provides oversight and direction to its vendor for property preservation field work.

The company leverages an industry-recognized service provider to identify new bankruptcy filings and changes to existing case status for loans in its portfolio. It reviews all bankruptcy court documents prior to filing, and there is a review of all loans prior to closing the bankruptcy case in the system. It maintains a preferred default attorney list based on capacity, quality of work, and other factors. In addition to annual reviews, attorney performance is monitored through monthly scorecards.

Real estate-owned (REO)

We believe Fay, through its affiliate, takes a comprehensive approach to managing REO assets. Its strategy is to maximize recovery through retail sales and rehabilitation when appropriate. Fay also utilizes the online auction channel in some cases. Its strategies are reflected in the gross sales to market value of 111% and 101% for its special servicing portfolio, which outpaces its peer averages.

During 2018, it converted to a different industry-recognized, web-based platform to manage its REO assets. Management indicated the new system provides improved workflow and tracking capability. We also note that the 50%-plus year-over-year decline in REO assets under its administration is largely due to market factors and the change in its servicing portfolio mix to more performing loans. The company largely transitioned REO staff to other areas of the company; however, it maintained its REO team of asset managers, and evictions, property preservation, and closing specialists. Procedures and controls we considered in our analysis include the following:

• The marketing, asset management, and closing processes are tracked through a web-based system.
• An asset plan was developed that includes a return on investment analysis for rehabilitation for all REO assets.
• The marketing is actively monitored with discretion to adjust price if the property begins to age.
• Fay utilizes two valuations to determine asset value and has a trained employee to reconcile the property valuations.
• A process is in place to validate a contractor's license and insurance.
• Real estate agents are scored for performance following the sale of each asset.
• Fay also monitors realtor performance using a scorecard that measures key service levels.

Financial Position

The financial position is SUFFICIENT.

Related Research

• Fay Servicing LLC AVERAGE Residential Special Servicer Ranking Affirmed; Outlook Stable, March 4, 2021
• Select Servicer List, Feb. 3, 2021
• Servicer Evaluation Spotlight Report: Environmental, Social, And Governance Factors Have Consistently Powered Our Servicer Evaluation Rankings, Nov. 16, 2020
• Servicer Evaluation Spotlight Report: Are Special Servicers Poised For A "Prime" Comeback Due To COVID-19?, June 8, 2020
• U.S. Residential Mortgage Servicers Gear Up To Face COVID-19 Related Challenges, April 10, 2020
• Analytical Approach: Global Servicer Evaluations Rankings, Jan. 7, 2019
• Servicer Evaluation: Fay Servicing LLC, June 20, 2018