FORM ABS-15G
|
||
☐ |
Rule 15Ga-1(c)(1) under the Exchange Act (17 CFR 240.15Ga-1(c)(1)) for the reporting period [________________] to [________________]
|
☐ |
Rule 15Ga-1(c)(2)(i) under the Exchange Act (17 CFR 240.15Ga-1(c)(2)(i)) for the quarterly reporting period [________________] to [________________]
|
☐ |
Rule 15Ga-1(c)(2)(ii) under the Exchange Act (17 CFR 240.15Ga-1(c)(2)(ii)) for the annual reporting period [________________] to [________________]
|
☒ |
Rule 15Ga-2 under the Exchange Act (17 CFR 240.15Ga-2)
|
Date of Report (Date of earliest event reported):
|
||
May 11, 2017
|
||
__________________________________
|
||
SOFI LENDING CORP.1
(Exact name of securitizer as specified in its charter)
|
||
025-02080
(Commission File Number of securitizer)
|
0001555110
(Central Index Key Number of securitizer)
|
|
Robert Lavet, General Counsel, (703) 972-2039
Name and telephone number, including area code, of the person to contact
in connection with this filing
|
||
__________________________________
|
||
(99.1) |
Report of Independent Accountants on Applying Agreed-Upon Procedures, dated May 11, 2017.
|
·
|
The completeness, accuracy, appropriateness, quality or integrity of any of the information provided by the Responsible Party, or any other party for purposes of PwC performing the procedures agreed to by the Specified Parties. The procedures performed would not necessarily reveal any material misstatement of the amounts, balances, ratios, percentages or other relationships of the information included in the data provided to us;
|
·
|
The conformity of the origination of the assets to stated underwriting or credit extension guidelines, standards, criteria or other requirements;
|
·
|
The value of collateral securing such assets; and
|
·
|
The compliance of the originator of the assets with federal, state, and local laws and regulations.
|
·
|
The interpretation of Transaction documents (including, but not limited to, indenture agreements or offering documents) included in connection with our procedures;
|
·
|
Your compliance with Rule 15Ga-2 of Securities Exchange Act of 1934;
|
·
|
The reasonableness of any of the assumptions provided by the Company; and
|
·
|
The adequacy of the sample size, as provided by the Specified Parties, nor do we draw any conclusions about the entire Data Tape based on the sample size and results of the procedures performed.
|
·
|
The phrase "compared" refers to the comparison of one or more data elements to underlying documentation.
|
·
|
The phrase "recalculated" refers to a recalculation of one of more data elements using a prescribed methodology.
|
·
|
An electronic data file labeled "2017-C Cut Off Tape_as of 4.14.2017 v2_Sent BAML.xlsx" (the "Data Tape")
|
·
|
An electronic data file labeled "2017-C_borrower_file.xls" (the "Borrower Name File")
|
·
|
An electronic data file labeled "2017C Data File.csv" (the "Servicing Information Support File")
|
·
|
Certain promissory note, loan agreement and Truth in Lending Act disclosure statements (collectively, the "Originating Documents")
|
·
|
For each of the Sample Loans, an export from the underwriting system (collectively, the "Underwriting System Export Files")
|
·
|
For each of the Sample Loans, and for each borrower or co-borrower, as applicable, the following data files (collectively, the "Income Verification Documentation"):
|
o
|
W-2s, pay statements, personal tax returns, business tax returns, employer offer letters, and/or other documents relating to income,
|
o
|
Certain additional supporting documentation from the auto-verification of employment and income through the Equifax product "WorkNumber" and the InVerify Reports.
|
·
|
An electronic document labeled "3.1.eIncomeGuidelinesandProcedures-100117-1414.pdf" (the "Gross Income Calculation Methodology File")
|
Sample Characteristics
|
|
1. Loan type (In-School, REFI, PLUS, PARENT)
|
10. Last day of enrollment (In-School Only)
|
2. Borrower first name
|
11. Deferment end date (if applicable)
|
3. Borrower last name
|
12. Forbearance end date (if applicable)
|
4. Borrower state
|
13. First disbursement date
|
5. Original loan balance
|
14. Loan status
|
6. Current interest rate
|
15. Borrower credit score
|
7. Current loan balance
|
16. Gross income
|
8. Repayment begin date
|
17. School name
|
9. Repayment end date
|
18. Graduation date
|
✓
|
Sample Characteristics 1, 15, 17 and 18: the Underwriting System Export Files
|
✓
|
Sample Characteristics 2-4 and 6-14: the Servicing Information Support File
|
✓
|
Sample Characteristics 5: the Originating Documents
|
✓
|
Sample Characteristic 16: a recalculated value derived using the Income Verification Documentation and the Gross Income Calculation Methodology File
|
Sample Characteristic
|
Loan ID
|
Data File Value
|
Source File Value
|
15. Credit Score
|
2571536
|
730
|
774
|
16. Gross income
|
3259648
|
238,003.68
|
193,272.74
|
16. Gross income
|
2978720
|
100,000.00
|
81,370.12
|
16. Gross income
|
3203474
|
100,750.46
|
93,762.55
|
16. Gross income
|
3332949
|
110,366.24
|
100,203.22
|
16. Gross income
|
2701537
|
195,000.00
|
164,999.90
|
16. Gross income
|
3441270
|
350,000.00
|
329,100.04
|
i)
|
Rely upon this report, and any use of this report by that Non-Specified Party is its sole responsibility and at its sole and exclusive risk;
|
ii)
|
Acquire any rights or claims against PwC, and PwC assumes no duties or obligations to such Non-Specified Party.
|
Sample Characteristics
|
Data File
|
Data Field
|
Source File
|
Source Field
|
1. Loan type (In-School, REFI, PLUS, PARENT)
|
Data Tape
|
app_type
|
Underwriting System Export Files
|
N/A
|
2. Borrower first name
|
Borrower Name File
|
first_name
|
Servicing Information Support File
|
FNAME
|
3. Borrower last name
|
Borrower Name File
|
last_name
|
Servicing Information Support File
|
LNAME
|
4. Borrower state
|
Data Tape
|
state
|
Servicing Information Support File
|
State
|
5. Original loan balance
|
Data Tape
|
original_prin
|
Originating Documents
|
N/A
|
6. Current interest rate
|
Data Tape
|
cur_int_rate
|
Servicing Information Support File
|
IRATE
|
7. Current loan balance
|
Data Tape
|
current_prin
|
Servicing Information Support File
|
CURRENTPRINCIPAL
|
8. Repayment begin date
|
Data Tape
|
repay_begin_dt
|
Servicing Information Support File
|
LNREPAYSTART
|
9. Repayment end date
|
Data Tape
|
maturity_dt
|
Servicing Information Support File
|
LNEXPPAYOFF
|
10. Last day of enrollment (In-School Only)
|
Data Tape
|
enrollment_mo_rmn
|
Servicing Information Support File
|
N/A (no In-School loans)
|
11. Deferment end date (if applicable)
|
Data Tape
|
deferment_end_dt
|
Servicing Information Support File
|
DEFRENDDT
|
12. Forbearance end date (if applicable)
|
Data Tape
|
grace_end_dt
|
Servicing Information Support File
|
FORENDDT
|
13. First disbursement date
|
Data Tape
|
first_disb_dt
|
Servicing Information Support File
|
FIRSTDSBDATE
|
14. Loan status
|
Data Tape
|
loan_status_detail_desc
|
Servicing Information Support File
|
LOANSTATUS
|
15. Borrower credit score
|
Data Tape
|
credit_score
|
Underwriting System Export Files
|
N/A
|
16. Gross income
|
Data Tape
|
gross_income
|
Income Verification Documentation, Gross Income Calculation Methodology File
|
N/A
|
17. School name
|
Data Tape
|
school_name
|
Underwriting System Export Files
|
N/A
|
18. Graduation date
|
Data Tape
|
graduation_dt
|
Underwriting System Export Files
|
N/A
|
·
|
With respect to our comparison of Characteristics 2 and 3, in the event that the borrower name, as set forth on the Borrower Name file, did not match the Servicing Information Support File, the Originating Documents were used to perform the Procedures;
|
·
|
With respect to our comparison of Characteristic 4, in the event that the borrower state, as set forth on the Data Tape, did not match the Servicing Information Support File, the Originating Documents were used to perform the Procedures;
|
·
|
With respect to our comparison of Characteristic 9, differences of 30 days or less are noted to be "in agreement";
|
·
|
With respect to our comparison of Characteristic 12, in the event that the forbearance end date, as set forth on the Data Tape, is a date preceding the April 14, 2017 as of date of the Data Tape, a null value was used in place of the Data Tape value to compare with the value set forth on the Servicing Information Support File;
|
·
|
With respect to our comparison of Characteristic 14, a loan status of (i) "IN REPAY", "1-9 DAYS DELNQ", or "01-29 DAYS DELNQ" as set forth on the Data Tape is noted to be "in agreement" with a loan status of "3" as set forth on the Servicing Information Support File and (ii) "REFI GRACE" as set forth on the Data Tape is noted to be "in agreement" with a loan status of "5" as set forth on the Servicing Information Support File;
|
·
|
With respect to our comparison of Characteristic 15, if multiple credit scores are observed in the Underwriting System Export Files, the highest score is used;
|
·
|
With respect to our recalculation of Characteristic 16, if a Sample Loan included a co-signer or co-borrower, we were instructed to include the gross income of such co-signer or co-borrower in the calculation of gross income for the purposes of the Procedures;
|
·
|
With respect to our comparison of Characteristic 16, differences of 3.5% or less of the gross income amount indicated on the Data Tape are noted to be "in agreement", however, the Company noted 30 borrowers (Loan IDs 3128919, 3360291, 3308579, 3143958, 3149833, 3241161, 3247481, 3248303, 1888404, 3170639, 2571536, 3395851, 3399102, 2987305, 2993794, 3021553, 2925456, 2767111, 2969830, 3423716, 3196540, 3417409, 3409365, 3406411, 3166187, 3170419, 3323485, 2900130, 2902195 and 3024712) that qualified for their loans with a gross income value that was lower than the PwC recalculated value and the difference between the PwC recalculated value and the Data Tape value was greater than 3.5%. For these loans, "Gross income" is noted to be "in agreement" if the Data Tape value matches the "gross income" value listed in the Underwriting System Export Files;
|
·
|
With respect to our comparison of Characteristic 17, School name is noted to be "in agreement" if a borrower's school name is listed as "Other" on the Data Tape and the Underwriting System Export Files also lists the school name as "Other";
|
·
|
With respect to our comparison of Characteristics 17 and 18, if a borrower earned multiple degrees (i.e. Bachelor's and Master's degrees), the values for those characteristics set forth on the Data Tape are noted to be "in agreement" if they correspond to any of the values in the Underwriting System Export Files (i.e. it is not considered to be a difference if Characteristic 17 corresponded to a Bachelor's degree while Characteristic 18 corresponded to a Master's degree);
|
·
|
With respect to our comparison of Characteristics 17 and 18, we did not perform our Procedures for the 65 Parent and Plus Loans included in the Sample Loans, since the Company does not verify these characteristics in the underwriting process; and
|
·
|
With respect to our comparison of Characteristic 18, differences of 60 days or less are noted to be "in agreement".
|
HZ\4 8G@S MPIK/Q;^-DGC*XTV>RT(7XO'FF7 94(\N)3_$Q"J#C@:I.YRQD8.0F?102/3);'6CX(^%=1\?Z#H\7B"'R_"7AZ>26&W.< M:C=,Y; U
"H/#OBR MUO!)IY9;>:VC#[T+$[6!((()(],8Z5].55.EZ>US]H:QMC/G/FF%=V?KC- ' M.^ /&TWCK3;O4?["O=)LTF"6IO5VO<)M!W@8P!DXX)Z=:ZRBB@ HHHH **** C "BBB@ HHHH **** "BBB@ HHHH **** "BBB@ HHHH _]D! end