Exhibit,Appendix: Hsbc Bank Usa, National Association, In Its Capacity As Trustee Of Nomura Home Equity Loan, Inc., Asset Backed Certificates, Series 2007-2 v. Nomura Credit & Capital, Inc.

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                                FILED:         NEW     YORK       COUNTY        CLERK        08/04/2022             07:50        PM                 INDEX    NO.   650337/2013
   NYSCEF     DOC.   NO.   2456                                                                               RECEIVED      NYSCEF:     08/04/2022




                                                  Exhibit                                  75
   FILED:         NEW     YORK       COUNTY        CLERK        08/04/2022             07:50        PM                 INDEX    NO.   650337/2013
   NYSCEF     DOC.   NO.   2456                                                                               RECEIVED      NYSCEF:     08/04/2022




                       SUPREME COURT OF THE STATE OF NEW YORK
                       COUNTY OF NEW YORK
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                       NOMURA HOME EQUITY LOAN, INC., HOME
                       LOAN TRUST, SERIES 2007-2,
                       pursuant to a Pooling and Servicing Agreement,
                       dated as of January 1, 2007, by HSBC BANK USA,
                       NATIONAL ASSOCIATION, solely in its capacity as Trustee,

                       Plaintiff,
                                                                                                        Index No.: 650337/2013
                                – against –

                       NOMURA CREDIT & CAPITAL, INC.,

                       Defendant.
                       ------------------------------------------------------------------------x
                       NOMURA CREDIT & CAPITAL, INC.,                                                   Third Party Index No.
                                                                                                             595359/2014


                       Third-Party Plaintiff,

                                – against –

                       WELLS FARGO BANK, N.A. and OCWEN LOAN
                       SERVICING, LLC,

                       Third-Party Defendant.
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                                                 AMENDED EXPERT REPLY REPORT
                                                                            OF

                                             ANTHONY M. LENDEZ, CPA, CFE, CFF

                                                                 BDO USA, LLP

                                                               JANUARY 13, 2021
                                                             HIGHLY CONFIDENTIAL
   FILED:         NEW     YORK       COUNTY        CLERK        08/04/2022             07:50        PM                 INDEX    NO.   650337/2013
   NYSCEF     DOC.   NO.   2456                                                                               RECEIVED      NYSCEF:     08/04/2022




                  of 31 second lien Claim Loans that were identified by Mr. Ross from my analysis which were all
                  liquidated prior to May 1, 2011 and had loss severities in excess of 50%. 333
                           Finally, with respect to the 34 Claim Loans with trailing expenses under $10,000 or any
                  trailing  gains  that  also had   initial losses  that  Mr. Ross    contends   would    have   caused   them   to be
                  removed from the batch approval process, the 2013 Loss Processing Procedure that Mr. Ross cites
                  does not support his position that the trailing expenses/trailing gains were in addition to the loss
                  amount and loss severity criteria. 334      Accordingly, those Claim Loans remained in my analysis.335
                  XI.      Revision To My RFD Analysis
                           In  addressing    certain  of  the  contentions    of the  Servicers’   Experts,   my   Team    identified
                  certain additional servicing comments relating to the Claims Loans.                 We therefore reviewed my
                  RFD analysis and the results are set forth below.
                           My   Team    identified   a total of  583  Claim    Loans   with  RFDs    out  of  a total  of 701   Claim
                  Loans for which Ocwen produced either servicing comments or hardship letters.                     RFDs identified
                  fell into one of the eight hardship categories shown in Table 3.               Of these 583 Claim Loans, we
                  determined     that change    of  life events   likely  caused   defaults   for 431.    See  Table   2  below    and
                  Appendix C, CRES Exhibit 4.




                  333
                     See Appendix C, CRES Exhibit 3 for an updated list of Claim Loans subject to the batch approval process.
                  334
                     Mr. Ross also appears to have eliminated Claim Loans from his analysis if either the applicable loss amount or loss
                  severity were met.   See Ross Rebuttal Report, ¶ 303.    Wells Fargo’s 2013 Loss Processing Procedure, however,
                  requires that, where loss severities were applicable, the loan had to meet both the loss amount and the loss severity
                  criteria for batch approval.See 2013 Loss Processing Procedure at WF_NOMURA_000000634-0635.
                  335
                     In his Rebuttal Report, Mr. Ross also asserts that the Mortgage Loans did not “suffer[] greater losses because they
                  were batch approved (as opposed by being manually reviewed by an analyst).”     Ross Rebuttal Report, ¶ 306; see also
                  Ross Rebuttal Report, ¶¶ 305, 307.   Notably, however, Mr. Ross fails to address the fact that the necessary detail to
                  make such assessments was not produced.     See, e.g., Email from Casey Howard, Esq. to Joel Chernov, Esq., et al.,
                  dated June 18, 2018; Order of Special Master Katz, dated July 11, 2018; Email from Joel Chernov, Esq., to Stan
                  Chelney, Esq., et al., dated July 23, 2019; Order of Special Master Katz, dated March 3, 2017; Order of Special Master
                  Katz, dated September 27, 2017.    Furthermore, Wells Fargo’s failure to “supervise, monitor and oversee” servicing
                  activities (PSA § 4.01 at p. 125), including its failure to do so by virtue of an appropriate review of the loss claim
                  packages submitted by the Servicers, resulted in increased losses to the Trust.
                                                                                                See also Amended Lendez Report at p.
                  58.
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   FILED:         NEW     YORK       COUNTY        CLERK        08/04/2022             07:50        PM                 INDEX    NO.   650337/2013
   NYSCEF     DOC.   NO.   2456                                                                               RECEIVED      NYSCEF:     08/04/2022




                                                                        Table 2
                                                      Results of the RFD Analysis
                                                               Number of         % of           Realized            % of
                                Description                       Loans         Loans            Losses            Losses
                   Loans with Hardship Letters
                   and/or Servicing Comments                             701      100%        $   99,047,644          100%
                   Produced

                   Loans with RFDs Identified                            583       83%        $   80,834,054           82%

                   Loans with RFDs Filtered for the
                                                                         431       62%        $   60,307,595           61%
                   Two Time-Based Criteria


                                                                        Table 3
                                                                                                 Number of
                                                   RFD Hardship Categories                       Loans with
                                                                                                    RFDs
                                           1    Death (Borrower)                                       2
                                           2    Job Loss                                              168
                                           3    COI                                                   216
                                           4    Medical (Borrower)                                    30
                                           5    Natural Disaster                                       0
                                           6    Divorce                                                5
                                           7    Death (Family Member)                                  5
                                           8    Medical (Family Member)                                5
                                                Total                                                 431


                           These 431 Claim Loans defaulted for identifiable reasons that came into play years after
                  they were originated.      This is not to suggest that other defaults were the result of problems existing
                  at origination.    To the contrary, it is likely that a substantial percentage of other defaults were for
                  similar reasons, even though there was insufficient information recorded in the servicing files, or
                  the servicing files were not usable, to make those determinations on a loan-by-loan basis.



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