Subject: File No. 4-497
From: Robert W Brown
Affiliation: President CEO, MACC-TRAC Mortgage Quality Assurance

March 1, 2005

Specific to financial institutions with mortgage loan servicing divisions.

It is our understanding that many firms are having difficulty complying with Sarbanes-Oxley Act, Section 404. This is no surprise to us inasmuch as our statistics reveal a fairly consistent error rate in servicing: 30 percent for adjustable and variable rate loans, 10 percent for fixed rate loans and over 50 percent where the customer submits curtailments.

Over the past 15 years, we have reviewed, analyzed and audited in the range of 60 billion in loan assets for the FDIC, RTC, major accounting and investment banking firms and financial institutions. We have developed the only technology solution, to our knowledge that can be used for both highly grainular audits of individual loans and also electronically conduct a bulk audit of large loan portfolios. The bulk audit reveals anomalies for specific drill-down analysis. This process is available by license directly to institutions, through professional consulting and accounting firms or outsourced.

Having first hand knowledge of the aforementioned statistics, it is understandable why individuals are wary of attesting to the internal controls of loan servicing.

I can be available for further discussion.