Legal Seminar, Chicago, IL

CSBS PROPOSED “BASELINE” PRUDENTIAL STANDARDS

Capital: $2.5 million with an escalator of .25 percent of the unpaid principal balance of the serviced portfolio Liquidity: 3.5 basis points of the agency servicing portfolio if agency non- performing loans is less than or equal to 6 percent with an additional incremental charge of 200 basis points for non-performing loans if non- performing loans exceeds 6 percent of the portfolio Risk Management: Establish and update appropriate risk program Data Standards: Apply CFPB’s Mortgage Servicing Rules standard Data Protection: Appropriate controls in place Corporate Governance: Sound framework and controls Servicing Transfer Requirements: Incorporate CFPB and FHFA standards