“When we were small and just making a few loans, it was easy enough to do our loan servicing using an excel spreadsheet. However, as we grew this was no longer practical for three reasons. First, there were too many loans for excel to be our servicing software; second, servicing regulations were changing so rapidly that we were not confident that we were in compliance with the latest regs; and third, everybody got busier doing their “primary job” and we did not have the staff time to cover loan servicing.”