HfS Blueprint Report. Mortgage Services BPO Excerpt for Wipro. May Charles Sutherland EVP, Research

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1 Architects of Global Business HfS Blueprint Report Mortgage Services BPO Excerpt for Wipro May 2014 Charles Sutherland EVP, Research

2 Table of Contents Topic Page Executive Summary 3 Research Methodology 12 Service Provider Capabilities 20 Service Provider Profile 27 About the Author HfS Research Ltd. Proprietary Page 2

3 Executive Summary

4 Introduction to the HfS Blueprint Report: Mortgage Services BPO The Mortgage Services BPO HfS Blueprint Report is the first application of HfS Blueprint methodology to the mortgage services marketplace. Unlike other quadrants and matrices, the HfS Blueprint identifies relevant differentials between service providers across numerous facets in two main categories: innovation and execution. HfS Blueprint Report ratings depend on a broad range of stakeholders with specific weightings based on 1,355 crowd-sourced responses. Stakeholders include: BPO Enterprise Buyers BPO Service Providers BPO Industry Influencers (sourcing advisors) HfS Analysts 2014 HfS Research Ltd. Proprietary Page 4

5 A Shift is Underway in the Mortgage Services BPO Market From Origination to Servicing and Default. Prior to the collapse of the US residential real estate market in , the Mortgage Services BPO market could be characterized as one of a focus on volume and speed. There was so much lending activity that service providers existed to take on the volumes that lenders couldn t cover out of their own centers. In doing so, they largely (at least for the largest lenders) operated using the lender s origination systems and the lender s processes. While servicing was an important part of the market, most of the activity was in origination (and refinancing which is another form or origination) and very little service provider interest was in default or foreclosure. From Volume Volatility to Process Excellence. In the heady days or mortgage origination (and later post crash refinancing boom created by the dip in 30 year rates), many lenders were focused less on process excellence than speed. The market was looking for service providers who could back-stop the lender s internal operations and respond to spikes in activity. Today with origination costs on the rise and volumes declining, lenders are looking at waste in their processes and looking to service providers who can help them maximize the efficiency and cost of their processes through operational excellence, transformation and technology support. From Labor to Technology and Insights. Since 2008 acquisitions (i.e., Zenta, Mortgage Cadence, Gallagher, FiServ, Opus CMC, Corelogic and Wilshire Credit) have either brought new service providers into the market or have expanded capabilities and in particular technology platforms. Where previously mortgage services was about having pools of qualified people on tap, now it s about the combination of technology, analytics and insight to drive an improved and more cost effective process for major lenders HfS Research Ltd. Proprietary Page 5

6 Lenders Have Seen Declining 30 Year Rates Average 30 Year Mortgage Rates (%), United States % 8.00% 8.05% 7.00% 6.97% 6.54% 6.00% 5.00% 4.00% 3.00% 2.00% 1.00% 5.83% 5.94% 5.87% 6.41% 6.34% 6.03% 5.04% 4.69% 4.45% 3.66% 3.98% 4.34% 0.00% Source: Freddie Mac data is for April 2014, all others are annual average rates 2014 HfS Research Ltd. Proprietary Page 6

7 The Refinancing Era is Forecasted to End in 2014 Mortgage Origination Estimates ($ Billions), One- to four-family homes $3,000 Purchase Refinance $2,500 $1,326 $2,000 $1,166 $1,331 $1,456 $1,500 $1,399 $777 $1,168 $931 $1,103 $1,000 $1,140 $419 $411 $500 $731 $664 $530 $505 $587 $652 $646 $808 $ e 2015e Source: Mortgage Bankers Association, The net cost to originate includes all production operating expenses and commissions minus all fee income 2014 HfS Research Ltd. Proprietary Page 7

8 While the Costs of Mortgage Origination Climb Net Cost to Originate A New Mortgage ($) $6,000 $5,000 $4,000 $3,000 $2,000 $1,000 $- 1Q Q Q Q Q Q Q Q Q Q Q Q 2013 Source: Mortgage Bankers Association, The net cost to originate includes all production operating expenses and commissions minus all fee income 2014 HfS Research Ltd. Proprietary Page 8

9 And Delinquency Rates on US Mortgages Remain High Delinquency Rate on Loans Secured by Real Estate, Top 100 Banks 14.0% 12.0% 10.0% 8.0% 6.0% 4.0% 2.0% 0.0% Source: Federal Reserve Bank of St Louis 2014 HfS Research Ltd. Proprietary Page 9

10 The Rankings of the Largest US Residential Lenders has been Changing as some Lenders Failed or have Changed Strategy 2009 Rank: Lending Institutions 1. Wells Fargo 2. Bank of America 3. JP Morgan Chase 4. Citigroup 5. GMAC 2013 Rank: Lending Institutions 1. Wells Fargo 2. JP Morgan Chase 3. Bank of America 4. Quicken Loans 5. US Bancorp Source: Company Reports 2014 HfS Research Ltd. Proprietary Page 10

11 How Lenders are Responding to these Conditions in Ways that Impact the Strategies and Capabilities of BPO Service Providers Financial Institutions Are Changing The Mortgage Services Market Today By: Rethinking Strategies And Operations In Origination, Servicing and Foreclosure-Default Management Removing Cost Across The Board But Especially In Origination. Scaling Internal Capacities To New Market Volumes And Sourcing For Volatility. Addressing Broken Or Inefficient Processes. Replacing Existing Loan/Servicing Platforms Or Finding Enabling Technologies To Solve For Gaps. Looking For Deeper Insights On Their Operations And Their Portfolios. All of Which Impact The Strategies and Capabilities of the Mortgage Services BPO Service Providers Profiled In This Blueprint Also Impacted The Weightings We Used To Evaluate Those Providers in HfS Research Ltd. Proprietary Page 11

12 Research Methodology

13 Research Methodology for the Mortgage Services BPO Blueprint Data Summary More than 8,000 data points were collected from more than 500 live mortgage services BPO contracts, covering 14 major service providers. Data was collected in Q to Q1 2014, covering buyers, providers, and advisors/influencers of core mortgage services BPO. Participating Service Providers This Report Is Based On: Tales from the Trenches: Interviews with buyers who have evaluated service providers and experienced their services. Some are supplied by service providers, but many are interviewed through interviews conducted with HfS Executive Council members and participants in our extensive market research. Sell-Side Executive Briefings: Structured discussions with service providers were intended to collect data necessary to evaluate their innovation, execution and market share, and deal counts. HfS State of Outsourcing Survey: The industry s largest quantitative survey, conducted with the support of KPMG, covering the views, intentions, and dynamics of 1,355 buyers, providers, and influencers of outsourcing. Publicly Available Information: Financial data, website information, presentations given by senior executives, and other marketing collateral HfS Research Ltd. Proprietary Page 13

14 Key Factors Driving the HfS Blueprint Two major factors: Evaluation Criteria Execution represents service providers ability to deliver services. It includes: Solutions in the Real World Quality of Customer Relationships Market Share Innovation represents service providers ability to improve services. It includes: Vision for End-to-End Process Lifecycle Integration of BPO and ITO Vision to Tailor Solution for Specific Industries Leveraging External Drivers Criteria Weighting Criteria are weighed by crowdsourcing weightings from the four groups that matter most: Enterprise Buyers [$5B+] (20%) Buyers (20%) Service Providers (30%) HfS Research Analysts Team (20%) Advisors, Consultants, and Industry Stakeholders (10%) Weightings from this report come from HfS s January 2013 State of Outsourcing Study 2014 HfS Research Ltd. Proprietary Page 14

15 How the HfS Blueprint Scores are Compiled Provider A Provider B Provider G vs. vs. vs. Provider B Provider G Provider J After service providers respond to HfS s Blueprint RFI, and after client references and fact checking have been completed, HfS analysts conduct a paired comparisons survey of service providers in each category of evaluation. This can be as many as 1,100+ unique service provider comparisons. The data/rankings are compiled and compared across all provider comparisons to identify inconsistencies within the scores. After a further data refinement, the criteria weightings are used to give each service provider a score in each evaluation criteria component. Once aggregation and scoring are complete, the service providers scores are plotted, producing the HfS Blueprint HfS Research Ltd. Proprietary Page 15

16 HfS Blueprint Scoring Percentage Breakdown EXECUTION 71.35% Quality of Customer Relationships 24.95% Quality of Account Management Team 8.83% How Service Providers Engage Customers and Develop Communities 8.00% How Service Providers Incorporate Customer Feedback 8.12% Real-World Delivery Solutions 30.90% Actual Delivery of Services for Each Sub-Process 17.52% Origination 7.36% Servicing 7.36% Foreclosure and Default Management 2.80% Geographic Footprint and Scale 3.58% Usefulness of Services to Specific Client Needs of All Sizes 9.80% Flexibility to Deliver End-to-End Solutions and Point Solutions 4.83% Experience Delivering Solutions To Top 50 Lenders 4.97% Flexible Pricing Models to Meet Customer Needs 15.50% INNOVATION 28.65% Vision for End-to-End Process Lifecycle 9.56% Concrete Plans to Deliver Value Beyond Cost and Investment in Future Capabilities 3.96% Integration of Technology Into Business Process 3.70% Continuous Improvement Methodology and Capability 1.90% Vision for Where the Mortgage Market is Headed and How To Respond as a Service Provider 10.09% Ability to Leverage External Value Drivers 9.00% Integrated Analytics and Insights Into Delivery 3.50% Incorporate Regulatory Requirements Quickly and Proactively 5.50% TOTAL % 2014 HfS Research Ltd. Proprietary Page 16

17 Execution Definitions EXECUTION Quality of Customer Relationships Quality of Account Management Team How Service Providers Engage Customers and Develop Communities How Service Providers Incorporate Customer Feedback Real-World Delivery Solutions Actual Delivery of Services for Each Sub- Process Geographic Footprint and Scale Usefulness of Services to Specific Client Needs of All Sizes Flexibility to Deliver End-to-End Solutions and Point Solutions Experience Delivering Solutions to Top 50 Lenders Flexible Pricing Models to Meet Customer Needs How well does the provider execute on it's contractual agreement and how well does the provider manage the client/provider relationship? How engaged are providers in managing the client relationship based on the following metrics: quality of account management, service provider / client engagement, and incorporation of feedback? What is the quality level of professional skills in the account management team? How well does the service provider engage clients and develop client communities? How have service providers taken feedback and incorporated that feedback into their product/solution? Does the solution provided compare favorably to the service agreed upon when taking into account delivery of services for each sub-process and geographic footprint and scale? Taking into account each sub process and the entire macro process, does each sub-process sum to successful delivery of the service being provided For example in the Mortgage Services macro process of Origination, are all sub-processes being delivered upon successfully? Specific to the category, to what degree do service providers have geographic locations that offer strategic value and do they have scale? How flexible and experienced are providers when tailoring solutions based on client size, location, and type of solution (end-to-end and single point)? How flexible are providers with delivering multi-process end-to-end solutions vs. single point solutions? How experienced are providers at delivering solutions to the specific needs of the largest lenders? How flexible are providers when determining pricing of contracts? Are they willing to make investments into the client s firm for long term growth? 2014 HfS Research Ltd. Proprietary Page 17

18 Innovation Definitions INNOVATION Vision for End-to-End Process Lifecycle Concrete Plans to Deliver Value Beyond Cost and Investment in Future Capabilities Integration of Technology Into Business Process Continuous Improvement Methodology and Capability Vision for Where The Mortgage Market is Headed and How to Respond as a Service Provider Ability to Leverage External Value Drivers Integrated Analytics and Insight into Delivery Incorporate Regulatory Requirements Quickly and Proactively Innovation is the combination of improving both services and business outcomes. The strategy for delivery services to each part of the processes "value chain". For example, in Finance and Accounting, the components of the value chain may include order to cash, record to report, and procure to pay. In Customer Relationship Management, the components may include outbound service, inbound service, quality, training, workforce management, call routing, self service, and customer insights/analytics. Clear understanding of what value levers exist and how the service provider will deliver that value. Examples of value may include labor arbitrage, technology, analytics, quality, revenue, global scale, and flexibility. How the service provider integrates applications with manual labor to improve value to clients. Service providers may provide cloud-enabled technology, SaaS, workflow, or analytics applications. How well does the provider execute on improving business process and capabilities of their solutions? Does the provider have a vision for how the mortgage market is developing and how they need to respond as a service provider to these changes both in terms of specific capabilities and in their commercial and operating approach? How well have providers integrated external value drivers into their services? Examples include: cloud solutions, security enhancements, incorporation of regulatory changes, and use of new collaborative tools. How well does the provider leverage analytics and insights into their solutions? How well does the provider incorporate the latest regulatory requirements and proactively integrates future regulatory requirements? 2014 HfS Research Ltd. Proprietary Page 18

19 Mortgage Services BPO Definitions Residential Mortgage Value Chain Core Processes HfS did not include the Commercial Mortgage market in this assessment and instead will cover that in future standalone reports Sales & Marketing Pre-Underwriting Processing Underwriting Closing Servicing Defaults Product Development Prospect and Lead Generation Direct Sales LOS Data Entry LOS Data Validation Data Lock in LOS Document Checks Ordering External Data VOE/VOM/VOR Initial Disclosure and Truth In Lending Preparation Automated Underwriting Manual Underwriting Document Prep Scheduling Closing Funding Trailing Documentation Appraisal and other Risk Reviews Payment Processing Taxes and Escrow Management Customer Care Investor Reporting Management Collections Default and Property Identification Foreclosure Loan Modifications Dispositions Securitization Reviews Analytics Loan Origination System (LOS) Licensing and Maintenance Document Management HfS Value Chain Definition: Value chain refers to the series of departments that carry out valuecreating activities to design, produce, market, deliver, and support a company s product or service. In this usage, we refer to the range of primary processes and support services that providers offer to their clients HfS Research Ltd. Proprietary Page 19

20 Service Provider Capabilities

21 Winners Circle and High Performers Methodology To distinguish providers that have gone above and beyond within a particular line of delivery, HfS awards these providers a Winner s Circle or High Performer designation. Below provides a brief description of the general characteristics of each designation: Winner's Circle: Organizations that demonstrate excellence in both execution and innovation. From an execution perspective, providers have developed strong relationships with clients, execute services beyond the scope of hitting green lights, and are highly flexible when meeting clients needs. From an innovation perspective, providers have a strong vision, concrete plans to invest in future capabilities, a healthy cross-section of vertical capabilities, and have illustrated a strong ability to leverage external drivers to increase value for their clients. High Performers: Organizations that demonstrate strong capabilities in both execution and innovation, but are lacking in an innovative vision or execution against their vision. From an execution perspective, providers execute some of the following areas with excellence, but not all areas: high performers have developed worthwhile relationships with clients, execute their services and hit all of the green lights, and are very flexible when meeting clients needs. From an innovation perspective, providers typically execute some of the following areas with excellence, but not all areas: have a vision and demonstrated plans to invest in future capabilities, have experience delivering services over multiple vertical capabilities, and have illustrated a good ability to leverage external drivers to increase value for their clients HfS Research Ltd. Proprietary Page 21

22 INNOVATION HfS Blueprint 2014: Mortgage Services BPO Winner s Circle High Performers WNS Wipro TCS Accenture ISGN IBM Xerox Sutherland Cognizant Infosys Genpact EXL Firstsource igate EXECUTION 2014 HfS Research Ltd. Proprietary Page 22

23 Major Service Provider Dynamics Highlights EXECUTION Accenture Delivers (Winner s Circle) Accenture came out at the top of the service providers for the depth of capabilities in delivering both origination and servicing processes the way that large clients want them done. The greatest challenge for Accenture is to further build out the existing capabilities in mortgage analytics to match the overall branding that the corporate marketing has created. ISGN Thrives On Process and Technology (Winner s Circle) ISGN is thriving as a mortgage pure-play by understanding the process and technology needs of their core clients who include Regional and Local lenders across the US. The greatest challenge for ISGN is re-investing in the required technology and analytics to compete with deep-pocketed competitors who have chosen to pursue aggressive growth in mortgage services BPO. TCS Has Scale (Winner s Circle) TCS has scale in mortgage processing to a level most other service providers can only dream of with significant large scale anchor clients. The greatest challenge for TCS is to go beyond excellent execution and bring more vision to the future of mortgage as well. Genpact Does What Genpact Does Best (High Performer) Executing on transactional process delivery and pleasing clients by meeting their operational expectations is what Genpact does best and that is as evident in the mortgage services market as it is in their other process areas. INNOVATION Wipro Focuses on Vision and End to End (Winner s Circle) Wipro was our innovation leader in no small part due to a recent focus both on the broader vision for where the mortgage market is going and in making the acquisitions (e.g. Opus CMC) and investments to support that vision with end to end capabilities. The greatest challenge for Wipro is now to convert that innovation into even more outstanding process execution. IBM Has A Vision (High Performer) IBM has a technology led vision for mortgage services and where the market is headed and that vision is significantly differentiated from what we broadly see occurring in the market. Xerox Has The Platform For Innovation (High Performer) Xerox with the BlitzDocs platform has the basis for digitizing mortgage processes much further than they have gone today and truly building out Mortgage Processing as a Service. Cognizant Bringing Big Picture Thinking (High Performer) Acquiring CoreLogic India got Cognizant into transactional mortgage processing and now bringing big picture consulting led thinking about the future of lending can further drive their growth in this market segment HfS Research Ltd. Proprietary Page 23

24 We Saw Significant Variance Between Mortgage BPO Service Providers in Their Mix of Work and Their Focus Origination Servicing Default Other 100% 25% 10% 5% 2% 25% 6% 5% 20% 20% % of Revenue 75% 50% 25% 10% 20% 45% 55% 35% 30% 65% 65% 35% 80% 50% 50% 41% 75% 45% 24% 70% 45% 55% 30% 65% 59% 5% 36% 25% 55% 35% 45% 0% 14% Source: Service Provider RFI Submissions to HfS and HfS Estimates 2014 HfS Research Ltd. Proprietary Page 24

25 We Also Saw Differences Between Service Providers Whether a Proprietary Loan Origination System is Part of the Offering Does Not Offer Proprietary Loan Origination System (LOS) Offers Proprietary Loan Origination System (LOS) 2014 HfS Research Ltd. Proprietary Page 25

26 By our Next Blueprint for Mortgage Services, we Expect Solutions for Process Automation in the mix as well Process Automation Process Automation Is Being Tested In Other Process Areas Now Over the last 6 months, BPO service providers have become very active in piloting the deployment of new third party and proprietary process automation tools. These tools are seen as a way of removing labor from existing processes by smoothing out processes where existing platforms (such as ERPs) are creating gaps and unnecessary manual efforts through for instance the creation of virtual FTEs or robots. The Same Conditions Appear In Top 50 Lenders Most of the largest mortgage lenders have to operate with legacy loan origination (and servicing) platforms whose gaps and flaws create significant labor intensive workarounds to complete transactions. This is just the sort of environment where process automation tools are relevant. Many Of The Same Service Providers Are Involved Many of the early leaders in piloting process automation are also significant service providers in the mortgage services market. We expect to see them rapidly replicate the capabilities and lessons from functions like F&A and HRO where process automation is today and bring that into their mortgage services offerings in 2H 2014 and beyond. But Will Lenders Accept Increased Process Automation The biggest question in the application of process automation to mortgage services isn t the capabilities of the service providers. Instead, it s whether lenders having in many cases just begun to review their processes to start with will accept the deployment of robots and whether regulators will accept them as well HfS Research Ltd. Proprietary Page 26

27 Service Provider Profile

28 Wipro Winner s Circle Building a comprehensive set of solutions with a vision for the market Origination: 36% Servicing: 5% Default: 59% Blueprint Leading Highlights Geographic Footprint And Scale Experience Delivering End to End Solutions Incorporating Customer Feedback Integration of Technology Into The Business Process Vision For Mortgage Market Strengths Geographic Footprint. Through acquisitions and internal growth, Wipro has been building out a global footprint for solutions delivery across mortgage that includes one of the most substantial US footprints in the market. Wipro has a choice of delivery locations that is valued by clients. Experience Delivering End To End Solutions. Wipro has built a broad set of capabilities across the mortgage services market and has solutions for all client requirements including areas such as risk management and mobility where few other service providers have yet entered. Incorporating Customer Feedback. Client and market commentary is that Wipro is being especially active at taking feedback on mortgage capabilities and then building that into new offerings and solutions. There appears to be pick up in the use of the BVM or Business Value Meter to capture business outcomes that clients seek to achieve in partnership with Wipro. Integration Of Technology Into The Business Process. Wipro has been able to build a substantial stand-alone business for NetOxygen while also integrating the LOS together with other technologies and client tools into delivery where the core LOS used may still be the client s. Vision For Mortgage Market. Wipro has shown a willingness to build a solution set often ahead of the broader market (LendCycle, e.mo, portals, risk management and due diligence platforms) and to share that vision with key clients together with a roadmap for what it will mean to both parties. Challenges Servicing Process. While clients and the market seem satisfied with the servicing capabilities of Wipro, this is a market segment where competition is intensifying and moving beyond partnerships with servicing platform to including more Wipro specific assets will be increasingly important. Integrated Analytics Into Delivery. While a tie-up with Opera for access to high level analytics resources in mortgage creates a substantial capability today, over time Wipro will increasingly see competitors who have developed the same capability entirely in house and so other options may be required I the medium term. Relevant Acquisitions/Partnerships Key Clients Global Operations Centers Technology Offered Opus CMC gives Wipro one of the leading capabilities for mortgage risk and due diligence which is an area of increasing interest (2013). Gallagher Financial Systems (2008) provided Wipro the launching pad for mortgage LOS technology and has been a critical part of Wipro s market success. Tie-up with Opera for high level analytics. 50+ total clients 4 of the top 5 US Banks Mid-sized and regional lenders Mortgage REITs Top-tier sub-servicers Investment management firms Investors Law firms Insurers Hedge funds Headcount: 700+ Locations: US (70%) in 6 centers Philippines (7%) in 2 centers India (23%) in 3 centers NetOxygen (proprietary LOS) Mavent, Fidelity, Cadence and Visual Banker third party LOSs E.MO (Mobility solution for loan origination) Various quality tools like Process Simulator (Simulation and Process Modeling), Epiplex (Knowledge Acquisition), Colossus (Transaction Monitoring), Spectrum (Updates Manager), On-line Assessment, Call Back Tracker, Login Tracker, Workmate (Work Allocation) and Oracle BI (Reporting). Base))) PRISM, Wipro s analytical platform, Proprietary platform risk assessment and due diligence platform - Opus First 2014 HfS Research Ltd. Proprietary Page 28

29 About the Author

30 Charles Sutherland EVP, Research Dallas, Texas Overview Over 18 years business experience in strategy development and delivery in the global outsourcing industry across US, Europe and Asia An industry advisor, strategist, author, speaker, practitioner and blogger Previous Experience Chief Strategy Officer, SourceHOV Managing Director, Growth & Strategy, Accenture BPO Managing Director, Strategy, Accenture Infrastructure Outsourcing Strategy Partner, Accenture Media & Entertainment Practice Marketing Director, Olivetti Education MBA, INSEAD, Fontainebleau France Honors BA, Political Science and Economics, University of Toronto 2014 HfS Research Ltd. Proprietary Page 30

31 About HfS Research HfS Research is the leading independent analyst authority and community for the global business services and outsourcing industry. HfS serves the research, governance and strategy needs of business operations and IT leaders across finance, supply chain, human resources, marketing, and core industry functions. The firm provides insightful and meaningful analyst coverage of the best business practices and innovations that impact successful business outcomes, namely talent development, process automation and outsourcing, global business services frameworks, mobility, analytics and social collaboration. HfS applies its acclaimed crowdsourced Blueprint Methodology TM to evaluate the performance of service providers in terms of innovating and then executing against those business outcomes. In addition to researching business operations strategies and their technology enablement, HfS educates and facilitates discussions among the world's largest knowledge community of enterprise services professionals, currently comprising 145,000 subscribers. HfS Research facilitates the HfS Sourcing Executive Council, the acclaimed elite group of sourcing practitioners from leading organizations that meets bi-annually to share the future direction of the global services industry and to discuss the future enterprise operations framework. HfS provides sourcing executive council members with the HfS Governance Academy and Certification Program to help its clients improve the governance of their global business services and vendor relationships. In 2013, HfS was named first in rising influence among leading analyst firms, according to the 2013 Analyst Value Survey, and second out of the 44 leading industry analyst firms in the 2013 Analyst Value Index. In 2010 and 2011, HfS was named Analyst of the Year by the International Institute of Analyst Relations (IIAR), the premier body of analyst-facing professionals and achieved the distinctive award of being voted the research analyst industry's Most Innovative Analyst Firm in Now in its seventh year of publication, HfS Research s acclaimed blog Horses for Sources is widely recognized as the leading destination for unfettered collective insight, research and open debate about sourcing industry issues and developments. To learn more about HfS Research, please research@hfsresearch.com HfS Research Ltd. Proprietary Page 31