Rating Agencies

“IHE has instituted a more robust QC and audit review since Fitch’s last review. The servicing division created a separate internal QC group, complementing audits customarily conducted by the compliance unit. Also, the servicing module of Cogent was implemented this year … which provides highly customizable statistical sampling and detailed reports. IHE’s servicing plan includes at least two audits of each function in servicing, for a total of 70 audits per year. All functions are audited against IHE’s policies and procedures.

Fitch views IHE’s new QC and audit programs, various internal layers of scrutiny, and regulatory oversight favorably.”

Standard & Poor's

“The company implemented the Servicing Quality Control System from Cogent Systems [sic] in October 2000 that facilitates reviews through statistical sampling, analysis and reporting. All Cogent reports are provided to the parent. … Standard and Poor’s believes Irwin’s auditing and compliance practices provide a solid foundation to guard against risk of loss to itself and its investors due to servicing errors or inefficiencies.”