Exhibit 10.31

SECOND ADDENDUM TO SERVICING AGREEMENT

This Second Addendum dated as of April 1, 2005 (the
Addendum) is made to the Servicing Agreement dated as of August 21, 2001 and amended as of July 1, 2004 (the Agreement) by and between GMAC Mortgage Corporation (GMACM or Servicer), a
Pennsylvania corporation with its principal office at 100 Witmer Road, Horsham, Pennsylvania 19044-0963 and GMAC Bank (the Bank), a federal savings bank with its principal office at 3710 Kennett Pike, Greenville, Delaware 19807.

Explanatory Statement

1. GMACM and the Bank have entered into the Agreement, whereby GMACM will service certain residential mortgage loans and lines of credits originated or acquired by the Bank.

2. GMACM and the Bank wish to amend Exhibit A to the Agreement as it applies to Servicing Compensation payable to GMACM for its Servicing Activities with
respect to loans held for investment.

3. It is the intent of the Bank and GMACM that this Addendum comply with the requirements of
Sections 23A and 23B of the Federal Reserve Act, the applicable provisions of the Home Owners Loan Act, and the implementing OTS regulations.

NOW, THEREFORE, in consideration of the mutual covenants and promises contained herein, the parties hereto, intending to be legally bound, hereby agree as follows:

1. The capitalized terms used herein, unless otherwise defined, shall have the meanings set forth in the Agreement.

2. Exhibit A to the Agreement is hereby amended and replaced in its entirety by the Servicing Fee Schedule for Held for Investment Loans attached as
Exhibit A hereto.

3. Any conflict between the provisions of this Addendum and those of the Agreement shall be resolved in favor of the
provisions of this Addendum. Except as expressly set forth in this Addendum, no modification of the Agreement is made or intended to be made by this Addendum, and the Agreement, as amended by this Addendum, is confirmed and reaffirmed by GMACM and
the Bank and shall be and remain in full force and effect.



---

IN WITNESS WHEREOF, each of the undersigned parties to this Addendum has caused this Addendum to be duly
executed in its corporate name by one of its duly authorized officers, all as of the date first above written.



|             |  |  |      |                           |                       |                      
|------------ |  |  | ---- | ------------------------- | --------------------- | ---------------------
|ATTEST:      |  |  |      | GMAC MORTGAGE CORPORATION
|             |  |  |     
|             |  |  |      | By:                       |                       | LOGO                 
|             |  |  |      |                           |                       | William Maguire      
|             |  |  |      | Its:                      |                       | Senior Vice President
|             |  | 
|ATTEST: LOGO |  |  |      | GMAC BANK                
|             |  |  | By:  |                           | LOGO                 
|             |  |  |      |                           | Peter A. Simon       
|             |  |  | Its: |                           | Senior Vice President



|1. | As defined in the GMACM service level template attached hereto.
|-- | ---------------------------------------------------------------



---

Exhibit A

Servicing Fee Schedule for Held for Investment (HFI) Loans



|                                   |  |                                                                                                                                                                                                                                                                                               
|---------------------------------- |  | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|Pricing                            |  | GMACB has chosen not to use the Private Label service offered by NLA, and consequently, the following prices are for servicing with GMACM branding. GMACB will be charged on a pass-thru basis
for certain Firsts and on a sub-servicing invoice basis for certain HFI Firsts, HELs and HELOCs
|                                   | 
|Sub-servicing Program Set-upCharge |  | No Charge                                                                                                                                                                                                                                                                                     
|                                   | 
|Set Up Fee Per Loan/Line           |  |                                                                                                                                                                                                                                                                                               
|From GMACM                         |  | No Charge                                                                                                                                                                                                                                                                                     
|From Other Parties                 |  | Actual out-of-pocket expenses passed through to GMACB plus reasonable GMACM personnel costs on a case-by-case basis.                                                                                                                                                                          
|                                   | 
|Borrower Web Access                |  | No Charge                                                                                                                                                                                                                                                                                     
|                                   | 
|Service Fee Per Loan/Line          |  | Monthly service fee per product                                                                                                                                                                                                                                                               



| | 1) | For first mortgage loans funded prior to July 1, 2004, classified as HFI and serviced under Investor # 50230 Block # 10003, and for first mortgages classified as HFS; there is
no change from the practice of passing through net interest after deducting the applicable servicing fee (25.0 or 37.5 basis points per annum depending on the loan type) on the outstanding unpaid principal balance.
| | -- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 2) | For HEL  16.18 basis points and HELOC  23.43 basis points based on the daily average outstanding balance for
the month, to be invoiced monthly effective July 1, 2004. All HEL and HELOC loans will be serviced using the consumer/HELOC service level process.1
| | -- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 3) | For first mortgage Prime loans funded subsequent to June 30, 2004, classified as HFI and serviced under
newly established blocks (These will be communicated with the effective date announcement): 1.62 basis points per annum on the daily average outstanding balance for the month, to be invoiced monthly effective when announced on a date to be
determined. All Prime loans will be serviced using the Prime/Base service level process.1
| | -- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 4) | For first mortgage Alt-A loans funded subsequent to March 1, 2005, classified as HFI and serviced under
newly established blocks (these will be communicated with the effective date of the announcement): 2.00 basis points per annum on the daily average outstanding balance for the month, to be invoiced monthly effective when announced on a date to be
determined. All Alt-A loans will be serviced using the Alt-A/Enhanced service level process.1
| | -- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

Daily average outstanding balances will be obtained from the servicing system for the affected investor/blocks. GMACM NLA will prepare the invoice and
forward to GMAC Bank Accounting for approval by noon on the second business day of each month for information regarding the prior month.



|               |  |                |  |                 |  |                
|-------------- |  | -------------- |  | --------------- |  | ---------------
|Firsts (Prime) |  | Firsts (Alt-A) |  | HEL             |  | HELOC          
|               |  |                | 
|1.62 bps/annum |  | 2.00 bps/annum |  | 16.18 bps/annum |  | 23.43 bps/annum



|                             |  |                                                                                       
|---------------------------- |  | --------------------------------------------------------------------------------------
|Ancillary Income             |  |                                                                                       
|Line Fees and Late Charges   |  | For account of GMACB                                                                  
|Principal and Interest Float |  | For account of GMACB (P&I receipts are passed to GMACB on an actual basis as received)
|Escrow and Interest Float    |  | For account of GMACM (T&I value is given to GMACM)                                    



|1. | As defined in the GMACM service level template attached hereto.
|-- | ---------------------------------------------------------------



---

|                                                              |  |                                                                                            
|------------------------------------------------------------- |  | -------------------------------------------------------------------------------------------
|Servicing Activity Fees                                       |  | For account of GMACM (e.g. payoff statements, fax fees) if paid by the Borrower.           
|Optional Products                                             |  | Revenue of non-banking products retained by GMACM                                          
|Customer Prepayment Fees                                      |  | For account of GMACB                                                                       
|De-Boarding Fee Per Loan for HFI assets sold to a third party |  | Actual out-of-pocket expenses passed through to GMACB plus reasonable GMACM personnel costs



---

Service Level Template For HFI Loans



|   |  |                                 |  |                                                                                 |  |                                                                           |  |                                                                         |  |                                                                                             |  |                                                                                             |  |                                            |  |                                                                                             |  |                                                                
|-- |  | ------------------------------- |  | ------------------------------------------------------------------------------- |  | ------------------------------------------------------------------------- |  | ----------------------------------------------------------------------- |  | ------------------------------------------------------------------------------------------- |  | ------------------------------------------------------------------------------------------- |  | ------------------------------------------ |  | ------------------------------------------------------------------------------------------- |  | ---------------------------------------------------------------
|#  |  |                                 |  | Service Level Name                                                              |  | Specific Measure Definition                                               |  | Prime Base                                                              |  | Alt-A/Enhanced                                                                              |  | Sub Prime                                                                                   |  | Consumer/HELOC                             |  | Sp Serv/Aggressive                                                                          |  | Comments                                                       
|   |  |                                 |  | Commitment                                                                      |  | Commitment                                                                |  | Commitment                                                              |  | Commitment                                                                                  |  | Commitment                                                                                  | 
|1  |  | Boarding Default Data           |  | Data Entry                                                                      |  | Data loaded within x days of data delivery                                |  | 100% in 7 business days                                                 |  | 100% in 7 business days                                                                     |  |                                                                                             |  |                                            |  | 100% in 7 business days                                                                     |  |                                                                
|2  |  | Collections                     |  | Welcome Call                                                                    |  | available,% made within # of days                                         |  | Not Applicable                                                          |  | Not Applicable                                                                              |  | 100% within 10 days (post boarding)                                                         |  | Not Applicable                             |  | 100% within 10 days upon receipt of data                                                    |  |                                                                
|3  |  | Collections                     |  | Outbound Call Starts                                                            |  | First delinquency day for contact                                         |  | Per Freddie Mac Early Indicator Score, Day 17                           |  | Per Freddie Mac Early Indicator Score, Day 8                                                |  | Day 5                                                                                       |  | Day 2                                      |  | Day 2                                                                                       |  | EI scoring model driven                                        
|4  |  | Collections                     |  | Outbound Call Attempts                                                          |  | # of attempts in 30 day delinquency cycle                                 |  | 4 attempts, 30 days                                                     |  | 4 attempts, 30 days                                                                         |  | 10 attempts, 30 days                                                                        |  | 10 attempts, 30 days                       |  | Daily                                                                                       |  | Prime, Alt-A, sub-prime are EI driven, Consumer are FICO driven
|6  |  | Collections                     |  | Outbound Penetration Rate                                                       |  | % of loans with attempted contact from eligibility date                   |  | 95% within 30 days of eligibility date                                  |  | 95% within 30 days of eligibility date                                                      |  | 95% within 5 days of eligibility date                                                       |  | 95% within 5 days of eligibility date      |  | 95% daily                                                                                   |  | score, campaigns can start between day 2 and day 31            
|7  |  | Collections                     |  | Failed Promise of Payment Recontact Date                                        |  | # of days between fail date and recontact attempt date                    |  | not to exceed 10 days                                                   |  | not to exceed 10 days                                                                       |  | Daily                                                                                       |  | Daily                                      |  | Daily                                                                                       |  | Promises to pay and repayment plans                            
|8  |  | Correspondence                  |  | Late Charge Notices Sent                                                        |  | % notified of late charge assessed per month                              |  | 95% per month                                                           |  | 95% per month                                                                               |  |                                                                                             |  |                                            |  | 95% per month                                                                               |  |                                                                
|9  |  | Correspondence                  |  | Intent to Foreclose/ Breach Letter                                              |  | % notified by x day of delinquency                                        |  | 95% by 63rd day of delinquency                                          |  | 95% by 32nd day of delinquency                                                              |  | 95% by 32nd day of delinquency                                                              |  | 95% by 63rd day of delinquency             |  | 95% by 32nd day of delinquency                                                              |  |                                                                
|10 |  | Correspondence                  |  | Breach Letter Expiration Notice                                                 |  | % sent by x day of delinquency                                            |  | 95% by 95th day of delinquency                                          |  | 95% sent 30 days after breach expiration                                                    |  | 95% sent 30 days after breach expiration                                                    |  | Not Applicable                             |  | 95% sent 30 days after breach expiration                                                    |  |                                                                
|11 |  | Property Inspections            |  | Initial Inspection                                                              |  | % completed by x day of delinquency                                       |  | 95% by 45th day of delinquency                                          |  | 95% by 45th day of delinquency                                                              |  |                                                                                             |  |                                            |  | 95% by 45th day of delinquency                                                              |  |                                                                
|12 |  | Property Inspections            |  | Subsequent Inspections                                                          |  | % completed monthly until resolution                                      |  | Per FNMA Guides                                                         |  | Per FNMA Guides                                                                             |  |                                                                                             |  |                                            |  | 95% per month                                                                               |  |                                                                
|13 |  | Property Valuations             |  | Initial BPO ordered                                                             |  | % ordered by x day of delinquency                                         |  | 95% by 65th day of delinquency                                          |  | 95% by 65th day of delinquency                                                              |  |                                                                                             |  |                                            |  | 95% by 65th day of delinquency                                                              |  |                                                                
|14 |  | Property Valuations             |  | Subsequent BPOs                                                                 |  | % ordered every 6 months                                                  |  | 95% once every 6 months                                                 |  | 95% once every 6 months                                                                     |  |                                                                                             |  |                                            |  | 95% once every 6 months                                                                     |  |                                                                
|15 |  | Foreclosure                     |  | Referral to Attorney                                                            |  | % completed within x days of breach expiration                            |  | 95% within 15 days                                                      |  | 95% within 15 days                                                                          |  |                                                                                             |  |                                            |  | 95% within 15 days                                                                          |  |                                                                
|16 |  | Foreclosure                     |  | Timeline Guidelines                                                             |  | % completed within Freddie Mac or Insurer guidelines                      |  | 90%                                                                     |  | 90%                                                                                         |  |                                                                                             |  |                                            |  | 95%                                                                                         |  |                                                                
|17 |  | Foreclosure                     |  | Title Delay Resolution                                                          |  | % of delays resolved within x days unless documentation for delay written |  | 95% in 60 days                                                          |  | 95% in 60 days                                                                              |  |                                                                                             |  |                                            |  | 95% in 60 days                                                                              |  |                                                                
|18 |  | Foreclosure                     |  | Assignment Delays Resolution                                                    |  | % of delays resolved within x days unless documentation for delay written |  | 95% in 60 days                                                          |  | 95% in 60 days                                                                              |  |                                                                                             |  |                                            |  | 95% in 60 days                                                                              |  |                                                                
|19 |  | Bankruptcy                      |  | Loading new Bankruptcies                                                        |  | % loaded within x days of detection                                       |  | 95% in 2 business days                                                  |  | 95% in 2 business days                                                                      |  |                                                                                             |  |                                            |  | 95% in 2 business days                                                                      |  |                                                                
|20 |  | Bankruptcy                      |  | Proof of Claim Referral                                                         |  | % referred to attorney                                                    |  | 95% referred in 15 business days of detection                           |  | 95% referred in 15 business days of detection                                               |  |                                                                                             |  |                                            |  | 95% referred in 15 business days of detection                                               |  |                                                                
|21 |  | Bankruptcy                      |  | Chapter 7 Motion for Relief                                                     |  | % referred to attorney                                                    |  | 95% referred in 15 business days of assignment to bankruptcy processor  |  | 95% referred in 15 business days of assignment to bankruptcy processor                      |  |                                                                                             |  |                                            |  | 95% referred in 15 business days of assignment to bankruptcy processor                      |  |                                                                
|22 |  | Bankruptcy                      |  | Chapter 13 Motion for Relief                                                    |  | % referred to attorney                                                    |  | 95% at earliest date, not to exceed 90 days past post petition due date |  | 95% at earliest date, not to exceed 90 days past post petition due date                     |  |                                                                                             |  |                                            |  | 95% at earliest date, not to exceed 90 days past post petition due date                     |  |                                                                
|23 |  | Bankruptcy                      |  | Referral for Next Appropriate Action (Foreclosure, Collection, Loss Mitigation) |  | % referred for next action                                                |  | 95% in 3 business days                                                  |  | 95% in 3 business days                                                                      |  |                                                                                             |  |                                            |  | 95% in 3 business days                                                                      |  |                                                                
|24 |  | Bankruptcy                      |  | Receipt of Chapter 13 Proposed Plans                                            |  | % reviewed/objected to by confirmation date                               |  | 95%                                                                     |  | 95%                                                                                         |  |                                                                                             |  |                                            |  | 95%                                                                                         |  |                                                                
|25 |  | Loss Mitigation                 |  | Solicitation Attempts                                                           |  | # of solicitation attempts per month, commencing x                        |  | 2 calling attempts per month after foreclosure referral                 |  | 2 calling attempts per month after foreclosure referral, solicitation card mailed at Day-90 |  | 2 calling attempts per month after foreclosure referral, solicitation card mailed at Day-60 |  | 2 calling attempts per month after Day-120 |  | 2 calling attempts per month after foreclosure referral, solicitation card mailed at Day-60 |  |                                                                
|26 |  | Loss Mitigation                 |  | Follow-up Packages Sent                                                         |  | % called within x business days                                           |  | 95% within 15 business days                                             |  | 95% within 10 business days                                                                 |  | 95% within 10 business days                                                                 |  | 95% within 10 business days                |  | 95% within 10 business days                                                                 |  | -                                                              
|27 |  | Loss Mitigation                 |  | Follow-up on Repayment Plans                                                    |  | % follow-end up x days prior to plan due date                             |  | 95% within 10 days of plan due date                                     |  | 95% within 10 days of plan due date                                                         |  | 95% within 10 days of plan due date                                                         |  | 95% within 10 days of plan due date        |  | 95% within 10 days of plan due date                                                         |  |                                                                
|28 |  | Loss Mitigation                 |  | Equity Evaluation                                                               |  | # of completed evaluations by Day 120                                     |  | Not Applicable                                                          |  | Not Applicable                                                                              |  | 90% by the 120th day of default                                                             |  | 90% by the 120th day of default            |  | 90% by the 120th day of default                                                             |  |                                                                
|29 |  | REO                             |  | Marketing-Available for Sale to List                                            |  |                                                                           |  | 30 days 95% rolling average                                             |  | 30 days 95% rolling average                                                                 |  |                                                                                             |  |                                            |  | 30 days 95% rolling average                                                                 |  |                                                                
|30 |  | REO                             |  | Marketing-List Date to Sale                                                     |  |                                                                           |  | 120 days 95% rolling average                                            |  | 120 days 95% rolling average                                                                |  |                                                                                             |  |                                            |  | 120 days 95% rolling average                                                                |  |                                                                
|31 |  | REO                             |  | Marketing-Executed contract to close date                                       |  |                                                                           |  | 45 days 95% rolling average                                             |  | 45 days 95% rolling average                                                                 |  |                                                                                             |  |                                            |  | 45 days 95% rolling average                                                                 |  |                                                                
|32 |  | REO                             |  | Cash Proceeds-Sales Price to Market Value                                       |  |                                                                           |  | 97% average                                                             |  | 97% average                                                                                 |  |                                                                                             |  |                                            |  | 97% average                                                                                 |  |                                                                
|33 |  | REO                             |  | less Closing Costs and Concessions to Market Value                              |  |                                                                           |  | 87% average                                                             |  | 87% average                                                                                 |  |                                                                                             |  |                                            |  | 87% average                                                                                 |  |                                                                
|34 |  | Post Sale                       |  | Claim to Insurer                                                                |  | % within x days of disposition                                            |  | 95% within 30 days                                                      |  | 95% within 30 days                                                                          |  |                                                                                             |  |                                            |  | 95% within 30 days                                                                          |  |                                                                
|35 |  | Post Sale                       |  | Claim to Investor                                                               |  | % within x days of disposition                                            |  | 95% within 30 days                                                      |  | 95% within 30 days                                                                          |  |                                                                                             |  |                                            |  | 95% within 30 days                                                                          |  |                                                                
|36 |  | Post Sale                       |  | Liquidation Reports                                                             |  | % within x days of disposition                                            |  | 95% within days                                                         |  | 95% within 5 days                                                                           |  |                                                                                             |  |                                            |  | 95% within 5 days                                                                           |  |                                                                
|37 |  | Cash Posting                    |  | Posting of Funds (Forbearance and Bankruptcy plans)                             |  | % within x business days                                                  |  | 95% in 2 business days                                                  |  | 95% in 2 business days                                                                      |  |                                                                                             |  |                                            |  | 95% in 2 business days                                                                      |  |                                                                
|38 |  | Lien Release and Subordinations |  | Subordinations                                                                  |  | % completed in x business days                                            |  | 95% within 15 business days                                             |  | 95% within 12 business days                                                                 |  |                                                                                             |  |                                            |  | 95% within 10 business days                                                                 |  |