SEC Comment Letter for ONITY GROUP INC. (ONIT) (CIK 0000873860) (ONIT) — Nov 19, 2013
ONITY GROUP INC. (ONIT) (CIK 0000873860)
Date: Nov. 19, 2013 · CIK: 0000873860 · Accession: 0000000000-13-063450
AI Filing Summary & Sentiment
Reasoning
Referenced dates: October 10, 2013, September 26, 2013
Letter
November 1 9, 2013 Via E -mail Mr. John V. Britti Chief Financial Officer Ocwen Financial Corporation 2002 Summit Boulevard. 6th Floor Atlanta, Georgia 30319
Re: Ocwen Financial Corporation Form 10 -K for the Fiscal Year Ended December 31, 2012 Filed March 1, 2013 Form 10 -Q for the Period Ended September 30, 2013 Filed November 4, 2013 Response dated October 10, 2013 File No. 00 1-13219
Dear Mr. Britti : We have reviewed your response letter dated October 10, 2013 and have the following comments. Form 10 -Q filed for the Period Ended September 30, 2013
Notes to Unaudited Consolidated Financial Statements
Note 2 Securitizations and Variable Interest Entities, page 13
Transfer of Forward Loans
1. Please address the reasons for recording interest income on loans held for sale within Other income (expense).
Note 8 Advances, page 26
2. Given the ongoing sales to HLSS which will continue to impa ct match funded advances, please revise, in future filings, to provide a rollforward of activity which includes the beginning balance, advances made, sales, repayments, ending balances and any other pertinent information. Please provide us with this infor mation for the periods presented in the September 30, 2013 Form 10 -Q.
Mr. John V. Britti Ocwen Financial Corporation November 19, 2013 Page 2
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Segment Results and Financial Condition – Servicing
3. We note your response to prior comment six in our letter dated September 26, 2013. Please address how the amounts remitted to HLSS are allocated between both the financing liability and interest expense. Please address questions regarding all comments t o Marc Thomas, Staff Accountant, at (202) 551 -3452 or, if you thereafter need further ass istance, to me at (202) 551 -3752 .
Sincerely,
/s/ Gus Rodriguez
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November 1 9, 2013
Via E -mail
Mr. John V. Britti
Chief Financial Officer
Ocwen Financial Corporation
2002 Summit Boulevard. 6th Floor
Atlanta, Georgia 30319
Re: Ocwen Financial Corporation
Form 10 -K for the Fiscal Year Ended December 31, 2012
Filed March 1, 2013
Form 10 -Q for the Period Ended September 30, 2013
Filed November 4, 2013
Response dated October 10, 2013
File No. 00 1-13219
Dear Mr. Britti :
We have reviewed your response letter dated October 10, 2013 and have the following
comments.
Form 10 -Q filed for the Period Ended September 30, 2013
Notes to Unaudited Consolidated Financial Statements
Note 2 Securitizations and Variable Interest Entities, page 13
Transfer of Forward Loans
1. Please address the reasons for recording interest income on loans held for sale within
Other income (expense).
Note 8 Advances, page 26
2. Given the ongoing sales to HLSS which will continue to impa ct match funded advances,
please revise, in future filings, to provide a rollforward of activity which includes the
beginning balance, advances made, sales, repayments, ending balances and any other
pertinent information. Please provide us with this infor mation for the periods presented
in the September 30, 2013 Form 10 -Q.
Mr. John V. Britti
Ocwen Financial Corporation
November 19, 2013
Page 2
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Segment Results and Financial Condition – Servicing
3. We note your response to prior comment six in our letter dated September 26, 2013.
Please address how the amounts remitted to HLSS are allocated between both the
financing liability and interest expense.
Please address questions regarding all comments t o Marc Thomas, Staff Accountant, at
(202) 551 -3452 or, if you thereafter need further ass istance, to me at (202) 551 -3752 .
Sincerely,
/s/ Gus Rodriguez
Gus Rodriguez
Accounting Branch Chief