OREANDA-NEWS. S&P Global Ratings today raised its overall ranking on Ocwen Loan Servicing LLC (Ocwen) to AVERAGE from BELOW AVERAGE as a residential master servicer. As part of the ranking actions, we raised our management and organization subranking to AVERAGE from BELOW AVERAGE, and we affirmed our ABOVE AVERAGE loan administration subranking. The outlook for the ranking is positive.

The ranking reflects our opinion of Ocwen's master servicing operations' seasoned and experienced management and staff, solid servicer and subservicer oversight and compliance, thorough policies and procedures, appropriate default management, and continued year-over-year portfolio runoff. Our opinion also reflects the improvement in the primary operation's internal audit department that has taken on some oversight responsibilities of master servicing since our last ranking actions on Sept. 29, 2015, and June 18, 2015 (see "Ocwen Loan Servicing LLC Residential Master Servicer Ranking Lowered To BELOW AVERAGE; Outlook Revised," published Sept. 29, 2015 and "Ocwen Loan Servicing LLC Residential Servicer Rankings Lowered To BELOW AVERAGE; Outlook Stable," published June 18, 2015). Ocwen's internal audit department has also revised its review cycle to conduct annual audits of the master servicing operations.

Since our prior review, Ocwen has made the following changes (see "Ocwen Loan Servicing LLC," published Nov. 9, 2015):Changed the organizational reporting of the master servicing operations to the chief investment officer from the chief servicing officer of the primary servicer operations;Replaced two senior managers that left the organization by transitioning an industry-experienced internal vice president to oversee the day-to-day master servicing operations, replacing two senior managers that left the organization; andReplaced the director of servicer oversight with an external industry-experienced candidate. Our outlook for the ranking is positive. The outlook reflects organizational reporting changes to further the independence of the master operations from the parent's primary servicing operations, existing and tenured first and second lines of defense, improvements in the internal audit practices of the primary operations and annual reviews, and no Regulation AB or Uniform Single Audit Program (USAP) findings noted in the past eight years.

We will continue to monitor the internal controls and regulatory developments of the primary operations; seasoning of the management and organization changes in the master operations; and the Regulation AB, USAP, and internal audit reports, which might warrant a ranking revision in the next 12 to 18 months.

The financial position is SUFFICIENT, and we will add Ocwen to the Select Servicer List.