Gist Mortgage Risk Toolkit and Repository (National Credit Default Database) – “MRTR”

Description: - Interactive National Mortgage Default Credit Repository 2014

Executive Summary

The “Mortgage Risk Toolkit and Repository” (MRTR) is a financially faceted data library which will be dynamically crafted to address emerging operational, credit and compliance issues facing the Mortgage Default Service Industry. Through the integration of; Mortgage Law, Finance, Technology, and the creation of a Secure Client Delivery Facility, the program will serve multiple constituents within the lifecycle of the mortgage. Unique and progressive, business logic will be leveraged into the MRTR program to be used to query quickly and quietly large volumes of loans for potential mortgage compliance deficiencies (Including RESPA) and credit evaluation (Probability of Default-PD).

Extraordinary in scope, the MRTR will periodically refresh (as needed) and provide specific updated loan level default profiles down to the zip code and or district levels. Ownership/access to the MRTR tool will allow organizational staff to spend more time executing critical internal tasks rather than investigating and manually updating audit/compliance solutions of potentially hundreds/thousands of files.

Team

Mortgage Law: Will be led by an experienced Mortgage Default Law Firm which as vetted and tested many of the operational

compliance components of the library, which will be deployed. Note: regulatory changes scheduled for Jan 2014 are currently under review.

Finance: Mortgage Evaluations will be led by the founding Executive Director of the Masters of Financial Engineering Program at the UCLA Anderson School of Management. He is also an active high profile Global Advisory Consultant in Financial Risk Management.

Technology-Delivery Facility: Experienced successful Global Senior Technology and Operations Executive with specialties in: Development,

Infrastructure, Operations, and Technology for financial institutions worldwide. Budget management and planning as well as cost reduction.

Construction/Components Underlying modules/functionality of MRTR will contain but is not limited to the following basic components:

Rules Library Legal will initiate a rules based library that can be used in a scan of data with attributes based on pre-determined/selected criteria from the library to produce data, for the reporting tool, that will identify Mortgage Default Regulatory and RESPA breaches. The rules library will be built according to local bankruptcy laws for each jurisdiction, as well as the national federal laws. This rule-based engine will be used as a tool to scan and evaluate compliance risk.

Remediation Tools:

MRTR contains a remediation toolkit to allow entities to identify what aspects of the mortgages are not in compliance with the regulatory law. These consist of a combination of technologies that will allow analog (paper) formatted data to be scanned and scrubbed for missing information. The additional data entry/acquisition methodology also allows for missing data to be added to the primary records for the purpose of remediation.

Reporting, Data Preparation:

Reporting/analytics is key to the repository for large data scan’s, this aspect of the toolkit will allow for pre-processed data to be scanned according to a series of attributes to determine specific risk/characteristics for further review as raw data for downstream systems. The key factor for this aspect of the toolkit is the rules library and relevant market data contained in the repository.

Market Data:

Accurate market data is critical to examining existing mortgage information. A valuation rules based repository will be built and maintained on a frequency calendar to be determined. The data inputs and valuation data will require periodic maintenance in order to be deemed “Trusted” and will be subject to a rigorous validation schedule.

Suite of Applications (Partial) AADS™ Data distribution to electronic recipients ACDS™ Logical comparison and fractal analysis ADRS™ Formatted data redaction

AIRS™ Data gathering from websites and other data sources without interface automation

AARS™ Data gathering from authorized data

repositories and data re‐presentation SYDCAFA™

Prepares affidavits / certifications, review, look back

MRTR Overview of Regulatory Compliance Testing (Partial ) RESPA Test: 2I DAY & 180 DAY RULES (Reporting) POC Test: For allowable fees, proofs, & sequential execution

SCRA Test: for potential SCRA violations. Final Judgement

Test: For allowable fees, proofs, & sequential execution

District Test: For District level Trustee regulatory payment compliance. Insurance Test: For permissible fee/procedural compliance.

Beneficiaries Parties who would benefit from using MRTR’s attributes to solve issues associated with Mortgages Default and new RESPA rules include:

Public Private

* Local Municipalies: City Development, Mayor, Council * Servicers, Specialty Servicers, Banks & Board Members

* State Level: Government, State Government * Asset Management Firms, Hedge Fund’s

* National Level: Congress, Senate, Regulators * Law Firms: Mortgage Default, Consumer Advocacy, Financial-Legal Counsel