SEC Comment Letter for ONITY GROUP INC. (ONIT) (CIK 0000873860) (ONIT) — Feb 4, 2015
ONITY GROUP INC. (ONIT) (CIK 0000873860)
Date: Feb. 4, 2015 · CIK: 0000873860 · Accession: 0000000000-15-006995
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 18, 2014
Letter
February 4, 2015 Via E -mail Mr. Michael R. Bourque, Jr. Executive Vice President and Chief Financial Officer Ocwen Financial Corporation 1000 Abernathy Road NE, Suite 210 Atlanta, Georgia 30328
Re: Ocwen Financial Corporation Amendment #1 to Form 10 -K for the Fiscal Year Ended December 31, 2013 Filed August 18, 2014 Form 10 -Q for Fiscal Quarter Ended September 30, 2014 Filed October 31, 2014 File No. 00 1-13219
Dear Mr. Bourque :
We have reviewed your supplemental response s and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten busines s days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe future revisions are appropriate, please tell us why in your response.
After reviewing the information you provide in response to these comments, we may have additional comments.
Form 10 -K/A for the Fiscal Year Ended December 31, 2013
Note 1A – Restatement and Revision of Previously Issued Consolidated Financial Statements, page F -17
1. We acknowledge your response to prior comment one in the letter dated December 18, 2014. The fair value of an asset or liability is the best available poin t estimate of fair value under ASC 820. Please tell us how determined and concluded that your GAAP accounting policy for the mortgage servicing right s financing liability approximated its carrying value as long as the carrying value was within 5% of the f air value of the liability. Please also tell us the factors considered in subsequently concluding that the use of the 5% threshold to approximate the carrying value of your mortgage servicing right
Mr. Michael R. Bourque, Jr. Ocwen Financial Corporation February 4, 2015 Page 2
financing liability was an error that resulted in the res tatements of the December 31, 2013 audited financial statements and March 31, 2014 interim financial statements.
2. We acknowledge your response to prior comment two in the letter dated December 18, 2014. Please tell us how you determined the annual materiality threshold referred to in your response was appropriate to your fact pattern. Please provide us with your materiality analysis for each quarter in 2012 and the annual period ended December 31, 2012. Please explain the quantitative and qualitative factors considered in your determination that the uncorrected misstatements were immaterial each quarter and for the annual period ending December 31, 2012. Please refer to ASC 250 -10-S99. Please address questions regarding all comments to 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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February 4, 2015
Via E -mail
Mr. Michael R. Bourque, Jr.
Executive Vice President and Chief Financial Officer
Ocwen Financial Corporation
1000 Abernathy Road NE, Suite 210
Atlanta, Georgia 30328
Re: Ocwen Financial Corporation
Amendment #1 to Form 10 -K for the Fiscal Year Ended December 31, 2013
Filed August 18, 2014
Form 10 -Q for Fiscal Quarter Ended September 30, 2014
Filed October 31, 2014
File No. 00 1-13219
Dear Mr. Bourque :
We have reviewed your supplemental response s and have the following comments. In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter within ten busines s days by providing the requested
information, or by advising us when you will provide the requested response. If you do not
believe our comments apply to your facts and circumstances or do not believe future revisions
are appropriate, please tell us why in your response.
After reviewing the information you provide in response to these comments, we may
have additional comments.
Form 10 -K/A for the Fiscal Year Ended December 31, 2013
Note 1A – Restatement and Revision of Previously Issued Consolidated Financial Statements,
page F -17
1. We acknowledge your response to prior comment one in the letter dated December 18,
2014. The fair value of an asset or liability is the best available poin t estimate of fair
value under ASC 820. Please tell us how determined and concluded that your GAAP
accounting policy for the mortgage servicing right s financing liability approximated its
carrying value as long as the carrying value was within 5% of the f air value of the
liability. Please also tell us the factors considered in subsequently concluding that the use
of the 5% threshold to approximate the carrying value of your mortgage servicing right
Mr. Michael R. Bourque, Jr.
Ocwen Financial Corporation
February 4, 2015
Page 2
financing liability was an error that resulted in the res tatements of the December 31, 2013
audited financial statements and March 31, 2014 interim financial statements.
2. We acknowledge your response to prior comment two in the letter dated December 18,
2014. Please tell us how you determined the annual materiality threshold referred to in
your response was appropriate to your fact pattern. Please provide us with your
materiality analysis for each quarter in 2012 and the annual period ended December 31,
2012. Please explain the quantitative and qualitative factors considered in your
determination that the uncorrected misstatements were immaterial each quarter and for
the annual period ending December 31, 2012. Please refer to ASC 250 -10-S99.
Please address questions regarding all comments to 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