EX-99.1 2 d235162dex991.htm CONSOLIDATED ANALYTICS, INC. ("CONSOLIDATED ANALYTICS") DUE DILIGENCE EXECUTIVE Consolidated Analytics, Inc. ("Consolidated Analytics") Due Diligence Executive

EXHIBIT 99.1

CONSOLIDATED ANALYTICS, INC. (“CONSOLIDATED ANALYTICS”) DUE

DILIGENCE EXECUTIVE SUMMARY


 

LOGO

EXECUTIVE SUMMARY

THIRD PARTY DUE DILIGENCE REVIEW

Overview

Consolidated Analytics, Inc (“Consolidated Analytics”), a third-party due diligence provider, performed the review described below on behalf of its client, PennyMac Corp. The review included a total of 371 newly originated residential mortgage loans, in connection with the securitization identified as PMT Loan Trust 2021-INV2 (the “Securitization”). The review began on October 1, 2021, and concluded in December 1, 2021.

Scope of Review

Credit Review

Consolidated Analytics performed a “Credit Review” to verify compliance with guidelines in effect at the time of loan origination, or other guidelines provided by Client prior to review, and ensure the characteristics used by the underwriter are supported by the file documentation; and determine whether any loans outside of those guidelines contain legitimate and approved exceptions with compensating factors.

The Credit Review attempted to confirm the following:

 

  a.

QM or ATR Validation / Review of 8 Key Underwriting Factors

 

  i.

Income / Assets

 

   

Validate borrower(s) monthly gross income

 

   

Validate funds required to close, required reserves

 

   

Review file documentation for required level of income and asset verifications

 

  ii.

Employment Status

 

   

Review file documentation for required level of employment

 

  iii.

Monthly Mortgage Payment

 

   

Confirm program, qualifying rate, terms

 

  iv.

Simultaneous Loans

 

   

Validate all concurrent loans are included in the DTI to properly assess the ability to repay

 

  v.

Mortgage Related Obligations: PITI, HOA, PMI, etc.

 

   

Validate subject loan monthly payment (PITI) and associated obligations

 

  vi.

Debts / Obligations

 

   

Validate monthly recurring liabilities

 

  vii.

DTI and/or Residual Income

 

   

Validate debt-to-income ratio (DTI) based upon income and debt documentation provided in the file

 

   

Documentation meets Appendix Q requirements for QM Loans

 

  viii.

Credit History

 

   

Review credit report for credit history and required credit depth including any / all inquiries

 

   

Determine representative credit score from credit report

 

  b.

Validate loan-to-value (LTV) and combined loan-to-value

 

  c.

Review borrower’s occupancy

 

  d.

Validation through third party resource of the subject properties most recent twelve (12) month sales history


  e.

Confirm sufficient evidence in loan file, by reviewing the underwriter’s decision to approve the loan based upon the borrows income, debt, and credit history, to support borrower’s willingness and ability to repay the debt

 

  f.

Confirm that Final 1003 is sufficiently completed

 

  g.

Provide Audit 1008 with accurate data based on file documentation

 

  h.

Confirm Loan Approval conditions were met

 

  i.

Review condominium questionnaire to verify all information is complete, prepared by an authorized representative, and address any red flags that may deem condominium project ineligible

Compliance Review

Consolidated Analytics performed a “Compliance Review” to determine, as applicable, to the extent possible and subject to the caveats below, whether the loan complies with applicable regulatory requirements as noted blow, each as amended, restated and/or replaced from time to time. The Compliance Review included the following:

 

  a.

Recalculation of APR and Finance Charge

 

  b.

Testing of:

 

  i.

Federal High Cost Mortgage provisions

 

  ii.

Federal Higher Priced Mortgage Loans provisions

 

  iii.

Local and/or State Anti-predatory and High Cost provisions

 

  c.

Determine whether specified federal disclosures were provided timely based upon comparison of the application date to the dates on such disclosures:

 

  i.

Right to Receive Copy of Appraisal

 

  d.

National Flood Insurance Program (NFIP) Review:

 

  i.

Adherence to flood insurance coverage

 

  ii.

Identification of flood zones

 

  iii.

Evidence of adequate coverage amounts

 

  e.

Fair Credit Reporting Act (FCRA)

 

  f.

Home Mortgage Disclosure Act (HMDA)

 

  g.

Confirm through NMLS the loan originator and originating firm’s license status was active and properly disclosed on appropriate loan documents

 

  h.

Check the Loan participants against the exclusionary list provided by Client or by the purchaser of the Loan(s)

 

  i.

Review closing documents to ensure that the Mortgage Loan information is complete, accurate, and consistent with other documents; Confirm collateral documents have been recorded or sent for recording

The Compliance Review did not include any federal, state or local laws, constitutional provisions, regulations or ordinances that are not expressly enumerated above. Furthermore, the findings reached by Consolidated Analytics are dependent upon its receiving complete and accurate data regarding the loans from loan originators and other third parties upon which Consolidated Analytics is relying in reaching such findings.


Valuation Review

Consolidated Analytics performed a “Valuation Review,” which included the following:

 

  a.

Review original appraisal, determination that property is in “average” condition or better, or property requires cosmetic improvements (as defined by the appraiser) that do not affect habitability. Should an area of concern be identified with the condition of the property, Consolidated Analytics will alert Client.

 

  b.

Review appraisal, determination that property is completely constructed and appraisal is on an “as is basis,” or property is identified as not completely constructed by originating appraiser.

 

  c.

Review and determine if the appraisal report was performed on appropriate GSE forms and if the appraiser indicated in the body of the subject appraisal that the appraisal conforms to USPAP standards.

 

  d.

Review and determine the relevance of the comparable properties and ensure that a rational and reliable value was provided and supported as of the effective date of the Origination Appraisal.

 

  e.

Review adjustments (line item, net and gross adjustments) to ensure they are reasonable.

 

  f.

Ensure that the appraisal conforms to the guidelines provided from the Client.

 

  g.

Review appraisal to ensure all required documents were included.

 

  h.

Review location map provided within the appraisal for external obsolescence.

 

  i.

Ensure highest and best use and zoning complies with guidelines.

 

  j.

Confirm there are no marketability issues that affect the subject property.

 

  k.

Ensure subject property does not suffer any functional obsolescence.

 

  l.

Where applicable, determine if the file did not contain the appraisal or other valuation method and a review could not be performed.

 

  m.

Additional valuation products (Desktop Reviews and Field Reviews) were obtained to confirm the value was supported within 10% tolerance. This population was obtained by the client and ordered by Consolidated Analytics.

 

  n.

For all loans within the population, additional valuation products were not required when the CU score provided was below or equal to 2.5. In the event the CU score was not provided or was greater than 2.5, an additional valuation product was obtained to confirm value was supported within 10% tolerance.

Consolidated Analytics applied a cascade methodology to determine if the original appraised value was reasonably supported when compared to an independent third-party valuation product.

For loans reviewed in a post-close valuation review scenario (371 loans in total):

15 loans had a Broker Price Opinion (BPO) which was performed by Consolidated Analytics.

1 loan had a BPO that did not support value, another product was not provided.

134 loans had Desktop Reviews which were performed by Consolidated Analytics. Consolidated Analytics has independent access to the Desktop Reviews ordered by the Aggregator or Consolidated Analytics.

5 loans with a Desktop Review fell outside of a -10% tolerance or was inconclusive. A Field Review was completed on 1 of the loans and the value was supported. Another product was not obtained for the remaining 4 loans that fell outside of a -10% tolerance.


Product totals may not sum due to multiple products for each loan.

TAPE INTEGRITY REVIEW RESULTS SUMMARY

Of the 371 mortgage loans reviewed, 4 unique mortgage loans (by loan count) had a total of 5 different tape discrepancies across 3 data fields (some mortgage loans may have had more than one). A blank or zero value on the data tape when an actual value was captured by Consolidated Analytics was not treated as a data variance.

 

Fields Reviewed    Discrepancy Count    Percentage
     

Property_City

   3    0.81%
     

Property_Zip

   1    0.27%
     

Property_State

   1    0.27%


Summary of Results

OVERALL RESULTS SUMMARY

After giving consideration to the grading criteria of the relevant NRSROs, Kroll Bond Rating Agency, LLC and Moody’s Investors Service, Inc., 97.30% of the loans received a grade “B” or higher with 90.30% of the pool receiving an Overall “A” grade.

Final Loan Grades

 

Overall Loan Results:

 

    

 

Event Grade    Loan Count    Original Principal Balance   

Percent of

Sample

     

Event Grade A

   335    $126,540,985    90.30%
       

Event Grade B

   26    $9,610,544    7.01%
     

Event Grade C

   9    $2,930,740    2.43%
       

Event Grade D

   1    $337,500    0.27%
     

Total Sample

   371    $139,419,769    100%

 

Credit Results:

 

Event Grade    Loan Count    Percent of Sample
     

Event Grade A

   365    98.38%
     

Event Grade B

   1    0.27%
     

Event Grade C

   4    1.08%
     

Event Grade D

   1    0.27%
     

Total Sample

   371    100%


Compliance Results:

 

Event Grade    Loan Count    Percent of Sample
     

Event Grade A

   358    96.50%
     

Event Grade B

   11    2.96%
     

Event Grade C

   2    0.54%
     

Event Grade D

   0    0%
     

Total Sample

   371    100%

 

Valuation Results:

 

Event Grade    Loan Count    Percent of Sample
     

Event Grade A

   352    94.88%
     

Event Grade B

   14    3.77%
     

Event Grade C

   5    1.35%
     

Event Grade D

   0    0%
     

Total Sample

   371    100%

Exception Category Summary

The table below summarizes the individual exceptions which carried an associated “B”, “C”, or “D” level exception grade. One loan may have carried more than one exception. In such cases, the exception with the lowest grade would drive the loan grade for that particular area of the review. The overall loan grade is the lowest grade for any one particular review scope (ex. a loan with a Compliance Grade of “B”, a Credit Grade of “A”, and a Property Grade of “A” would receive an overall Loan Grade of “B”).

 

Exception Type   Exception Level Grade   Exception Category   Total
             

Credit

  B   Hazard Insurance Indicator is Partial   1
        Total Credit Grade (B) Exceptions:   1
             

Credit

  C   CoBorrower Income Verification does not match Approval   2


        DTI Exceeds AUS Maximum Allowable   1
        Hazard Insurance Coverage is Not Sufficient.   1
        Number of Mortgage Properties Exceeds Max Allowable Per Guidelines   1
        Total Credit Grade (C) Exceptions:   5
             
Credit   D   Borrower Liabilities Verification Indicator is Partial   1
        Total Credit Grade (D) Exceptions:   1
             
Compliance   B   Charges That Cannot Increase Test   3
        Charges That In Total Cannot Increase More Than 10% Test   1
        Consummation or Reimbursement Date Validation Test   2
        Higher-Priced Mortgage Loan Right to Receive Appraisal Disclosure Was Not Provided Within 3 Days (12 CFR 1026.35(c)(5)).   1
        Initial Closing Disclosure Delivery Date Test   3
        Initial Loan Estimate Delivery Date Test (from application)   1
        Original PI Payment on Note does not equal PI Payment on Final Closing Disclosure   1
        Prohibited Fees Test   1
        Reimbursement Amount Test   2
        Reimbursement Amount Validation Test   1
        Right to Cancel is Missing   1


        TRID “Section A. Origination Charges” Validation Test   1
      TRID “Section C. Services You Can Shop For / Services Borrower Did Shop For” Validation Test   1
      TRID “Section H. Other” Validation Test   1
      TRID Post-Consummation Reason for Redisclosure Validation Test   1
      TRID Post-Consummation Revised Closing Disclosure Data Validation Test   1
      Written List of Service Providers Disclosure Date Test   2
        Total Compliance Grade (B) Exceptions:   24
             
Compliance   C   ATR/QM Status is Pending   2
        Total Compliance Grade (C) Exceptions:   2
             

 

Valuation   B   Informational Only - Property Inspection Waiver used at origination.   15
        Total Valuation Grade (B) Exceptions:   15
Valuation   C   Third Party BPO variance to appraised value exceeds 10%   1
        Third Party Desk Review variance to appraised value exceeds 10%   4
        Total Valuation Grade (C) Exceptions:   5


Event Grade Definitions

 

Final Loan Grade

 

A

 

 

Loan meets Credit, Compliance, and Valuation Guidelines

 

B

 

 

The loan substantially meets published Client/Seller guidelines and/or eligibility in the validation of income, assets, or credit, is in material compliance with all applicable laws and regulations, and the value and valuation methodology is supported and substantially meets published guidelines.

 

C

 

 

The loan does not meet the published guidelines and/or violates one material law or regulation, and/or the value and valuation methodology is not supported or did not meet published guidelines.

 

D

 

 

Loan is missing documentation to perform a sufficient review.

 

 

Credit Event Grades

 

A

 

 

The loan meets the published guidelines without any exceptions. The employment, income, assets and occupancy are supported and justifiable. The borrower’s willingness and ability to repay the loan is documented and reasonable.

 

B

 

 

The loan substantially meets the published guidelines but reasonable compensating factors were considered and documented for exceeding published guidelines. The employment, income, assets and occupancy are supported and justifiable. The borrower’s willingness and ability to repay the loan is documented and reasonable.

 

C

 

 

The loan does not substantially meet the published guidelines. There are not sufficient compensating factors that justify exceeding the published guidelines. The employment, income, assets or occupancy are not supported and justifiable. The borrower’s willingness and ability to repay the loan were not documented or are unreasonable.

 

D

 

 

There was not sufficient documentation to perform a review or the credit file was not furnished.

 


Compliance Event Grades

 

A

 

 

The loan is in compliance with all applicable laws and regulations. The legal documents accurately reflect the agreed upon loan terms and are executed by all applicable parties.

 

B

 

 

The loan is in material compliance with all applicable laws and regulations. The legal documents accurately reflect the agreed upon loan terms and are executed by all applicable parties. Client review required.

 

C

 

 

The loan violates one material law or regulation. The material disclosures are absent or the legal documents do not accurately reflect the agreed upon loan terms or all required applicants did not execute the documents.

 

D

 

 

There was not sufficient documentation to perform a review or the required legal documents were not furnished.

 

 

Valuation Event Grades

 

A

 

 

The value is supported within 10% of the original appraisal by the AVM or there are other supporting documents in the originators loan file package (CDA, Field Review or Second Appraisal). The appraisal was performed on an “as-is” basis and the property is complete and habitable at origination. The appraiser was appropriately licensed and used GSE approved forms.

 

B

 

 

The value is not supported within 10% of the original appraisal by the AVM and there are no other valuation support documents in the loan file provided by the Seller. The valuation methodology substantially meets the published guidelines but reasonable compensating factors were considered and documented for exceeding guidelines. The appraisal was performed on an “as-is” basis and the property is complete and habitable. The appraiser was appropriately licensed and used GSE approved forms.

 

C

 

 

The value is not supported within 10% of the original appraisal. The valuation methodology did not meet the published guidelines and there were not sufficient compensating factors for exceeding published guidelines. The property is in below “average” condition or the property is not complete or requires significant repairs. The appraisal was not performed on an “as is” basis. The appraiser was not appropriately licensed or did not use GSE approved forms.

 

D

 

 

The file was missing the appraisal or there was not sufficient valuation documentation to perform a review.